filgame Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how filgame ("filgame," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal data of individuals ("you," "Player," or "Data Subject") who access or use the filgame Platform at filgame.club (the "Platform").

This Policy applies to all personal data collected through the Platform, including data submitted during account registration, identity verification, deposits and withdrawals, customer support interactions, and general use of the Platform's services. By accessing the filgame Platform and creating an account, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

filgame is committed to compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission (NPC).

2. Data Controller Information

filgame acts as the Data Controller with respect to the personal data processed through the Platform. As Data Controller, filgame determines the purposes and means of processing your personal data and bears primary responsibility for ensuring that such processing is lawful, fair, and transparent.

For all data privacy-related inquiries, requests, or complaints, please contact the filgame Data Privacy Officer via the contact details set out in Section 14 of this Policy.

3. Personal Data We Collect

filgame collects the following categories of personal data from players:

Category	Data Elements
Identity Data	Full legal name, date of birth, gender, nationality, government-issued ID type and number (e.g., PhilSys, passport, driver's license, SSS ID, UMID)
Contact Data	Mobile number, email address, home address (city/province, Philippines)
Financial Data	GCash / Maya account details, BPI / BDO / UnionBank / Metrobank account references, transaction history, deposit and withdrawal records
KYC Documents	Scanned or photographed copies of government-issued ID, selfie with ID, proof of address, source-of-funds documentation (where required)
Technical Data	IP address, device type, browser type and version, operating system, session data, login timestamps
Usage Data	Games played, wagers placed, betting history, promotion participation, session duration, feature interactions
Communications Data	Live chat transcripts, support ticket content, email correspondence, feedback submissions

filgame does not collect sensitive personal information beyond what is strictly required for KYC, age verification, and regulatory compliance. We do not collect data on religious beliefs, political affiliations, health records (except for responsible gaming self-disclosures), or other sensitive categories unless you voluntarily disclose such information in a support or responsible gaming context.

4. How We Collect Your Data

filgame collects personal data through the following means:

• Direct submission — data you provide when registering an account, completing KYC, making deposits or withdrawals, or contacting support;
• Automated collection — technical and usage data collected automatically when you access the Platform (see Section 9 on Cookies);
• Third-party sources — identity verification data returned by licensed KYC/AML service providers; payment confirmation data from GCash, Maya, and Philippine banking partners; and fraud-prevention data from third-party risk management systems.

5. Purposes and Legal Bases for Processing

filgame processes your personal data for the following purposes, each grounded in a recognized lawful basis under the Data Privacy Act:

• Account creation and management — processing is necessary for the performance of the contract between you and filgame (i.e., providing Platform services);
• Age verification and KYC compliance — processing is required by Philippine gaming regulations and applicable AML/CTF laws, constituting a legal obligation;
• Processing deposits and withdrawals — necessary for contract performance and financial regulatory compliance;
• Fraud prevention and security monitoring — necessary for the legitimate interests of filgame in protecting the Platform and its players from fraudulent activity;
• Responsible gaming monitoring — processing is in the vital interests of players and constitutes a legal obligation under applicable gaming regulations;
• Customer support — necessary for contract performance;
• Marketing and promotions — based on your consent (which may be withdrawn at any time) or, where applicable, our legitimate interest in communicating with existing customers about related services;
• Regulatory reporting — required by applicable Philippine law, including AML/CTF reporting obligations.

6. Disclosure and Sharing of Personal Data

filgame does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may disclose your personal data to the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors and e-wallet providers — GCash (GXI), Maya (Voyager Innovations), BPI, BDO, UnionBank, Metrobank, and other Philippine payment partners, for the purpose of processing financial transactions;
• KYC and identity verification providers — licensed third-party providers engaged to assist with identity verification and AML/CTF screening;
• Technology and platform partners — game software providers and platform infrastructure providers who process data solely on filgame's instructions and under binding data processing agreements;
• Regulatory and law enforcement authorities — Philippine regulatory bodies, law enforcement agencies, and courts, where filgame is legally required or compelled to disclose information;
• Professional advisers — legal counsel, auditors, and compliance consultants engaged by filgame, under obligations of professional confidentiality.

All third-party processors engaged by filgame are contractually obligated to process personal data only for the specified purpose, to maintain appropriate security measures, and to comply with applicable data privacy laws.

7. Data Retention

filgame retains personal data for as long as necessary to fulfil the purposes described in this Policy and to comply with legal, regulatory, and business requirements. In general:

• Account data and transaction records are retained for a minimum of five (5) years following account closure, in compliance with Philippine AML/CTF record-keeping requirements;
• KYC documents are retained for the duration of the account relationship and for five (5) years thereafter;
• Live chat and support communications are retained for up to two (2) years;
• Technical and usage logs are retained for up to twelve (12) months for security and platform improvement purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with filgame's data disposal procedures.

8. Data Security

filgame implements appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform;
• Encryption of sensitive data at rest (including KYC documents and financial records);
• Access controls limiting personal data access to authorized personnel on a need-to-know basis;
• Regular security assessments and vulnerability testing;
• Incident response procedures to detect, contain, and notify relevant parties of data breaches within the timeframes required under the Data Privacy Act.

While filgame takes data security seriously, no system is completely impenetrable. You are responsible for maintaining the security of your account credentials and for notifying filgame immediately if you suspect unauthorized access to your account.

9. Cookies and Tracking Technologies

filgame uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential cookies — required for the Platform to function correctly, including session management and login authentication. These cannot be disabled without affecting Platform functionality;
• Analytics cookies — used to understand how players interact with the Platform (e.g., pages visited, session duration) to improve user experience. These are processed in aggregated, anonymized form;
• Fraud prevention cookies — used by our risk management systems to detect and prevent fraudulent access patterns.

You may configure your browser to block or delete cookies. Note that blocking essential cookies will impair your ability to use the Platform. filgame does not use cookies to serve third-party advertising or to track your activity across external websites.

10. Your Rights as a Data Subject

Under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by filgame:

• Right to be informed — the right to know that your personal data is being collected and processed, and the basis and purpose for such processing (fulfilled by this Policy);
• Right of access — the right to request a copy of the personal data filgame holds about you;
• Right to rectification — the right to correct inaccurate or incomplete personal data;
• Right to erasure or blocking — the right to request deletion or blocking of personal data that is unlawfully processed or no longer necessary for its original purpose, subject to filgame's legal retention obligations;
• Right to data portability — the right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to object — the right to object to processing based on legitimate interests, including direct marketing;
• Right to withdraw consent — where processing is based on consent, the right to withdraw consent at any time without affecting the lawfulness of prior processing;
• Right to lodge a complaint — the right to file a complaint with the National Privacy Commission (NPC) if you believe your rights under the Data Privacy Act have been violated.

To exercise any of these rights, please contact the filgame Data Privacy Officer using the contact details in Section 14. filgame will respond to all data subject requests within the timeframes required by applicable law, generally within fifteen (15) business days.

11. Children and Minors

The filgame Platform is strictly for use by individuals aged 21 years and above. filgame does not knowingly collect personal data from persons under the age of 21. If filgame discovers that personal data has been collected from an underage individual, the account will be immediately suspended, personal data will be deleted, and any deposited funds will be returned. If you are a parent or guardian and believe your child has registered on the Platform, please contact filgame support immediately via Live Chat.

12. Cross-Border Data Transfers

In the course of operating the Platform, filgame may transfer certain personal data to service providers located outside the Philippines (including data center operators and platform technology partners). Where such transfers occur, filgame ensures that appropriate safeguards are in place — including contractual data protection clauses and assessments of the recipient country's data protection standards — to provide a level of protection equivalent to that afforded under the Philippine Data Privacy Act.

13. Changes to This Privacy Policy

filgame reserves the right to update this Privacy Policy at any time. Where changes are material, filgame will provide notice via a prominent notification on the Platform or by communication to your registered account. The date of the most recent revision is indicated at the top of this Policy. Your continued use of the Platform following the effective date of any update constitutes your acceptance of the revised Policy.

14. Contact and Data Privacy Officer

For all data privacy inquiries, data subject rights requests, or complaints, please contact:

filgame Data Privacy Officer
Email: support@filgame.club
Support Channel: 24/7 Live Chat accessible on the Platform

filgame aims to resolve all data privacy inquiries promptly. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.