filiplay Privacy Policy

1. Introduction

filiplay ("filiplay," "we," "us," or "our") is committed to protecting the privacy and personal data of all players who use the filiplay platform at filiplay.club. This Privacy Policy ("Policy") describes how filiplay collects, uses, discloses, stores, and protects personal information in connection with the operation of our online casino and sports betting services.

This Policy applies to all registered players, visitors to the filiplay website, and any individual whose personal data is processed by filiplay in connection with the provision of our services. By registering a filiplay account or using the platform, you acknowledge that you have read and understood this Privacy Policy.

filiplay processes personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable guidelines issued by the National Privacy Commission of the Philippines.

2. Data We Collect

filiplay collects personal data that is necessary to provide our services, comply with legal obligations, and maintain the security and integrity of the platform. The categories of personal data we collect include:

2.1 Registration Data

• Full legal name as it appears on a government-issued Philippine ID
• Date of birth (to verify the 21+ age requirement)
• Philippine mobile number and email address
• Residential address in the Philippines
• Username and encrypted password

2.2 Identity Verification Data

• Copies of government-issued Philippine identification documents (e.g., PhilSys ID, passport, driver's license, SSS/GSIS ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Proof of payment method ownership (e.g., GCash account screenshot, bank statement)
• Selfie or facial verification image where required for KYC purposes

2.3 Financial Data

• GCash account number, PayMaya account details, or bank account information used for deposits and withdrawals
• Transaction history including deposit amounts, withdrawal requests, and bonus activity

2.4 Gaming Activity Data

• Game session history, wager amounts, game outcomes, and account balance history
• Responsible gaming settings including deposit limits and self-exclusion status

2.5 Technical Data

• IP address, device type, operating system, and browser information
• Session timestamps, login history, and platform interaction logs
• Cookie identifiers and similar tracking data as described in Section 7

3. How We Use Your Data

filiplay uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and administer your filiplay account, including processing your filiplay Login and managing account security.
• Service Delivery: To provide access to games, process deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, and deliver customer support.
• Identity Verification: To verify your identity and age (21+) in compliance with KYC requirements and to prevent fraud and unauthorized account access.
• Legal Compliance: To comply with applicable Philippine laws and regulations, including AML obligations, tax reporting requirements, and PAGCOR regulatory requirements.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools including deposit limits and self-exclusion.
• Platform Improvement: To analyze usage patterns, troubleshoot technical issues, and improve the performance and features of the filiplay platform.
• Communications: To send account-related notifications, security alerts, and promotional communications where you have consented to receive them.
• Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, bonus abuse, and other prohibited activities on the filiplay platform.

4. Legal Basis for Processing

filiplay processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and filiplay, including providing gaming services and processing financial transactions.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, KYC requirements, and PAGCOR regulatory obligations.
• Legitimate Interests: Processing is necessary for filiplay's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights.
• Consent: For certain processing activities, such as marketing communications, filiplay relies on your explicit consent, which you may withdraw at any time.

5. Data Sharing

filiplay does not sell, rent, or trade your personal data to third parties for their own marketing purposes. filiplay may share your personal data with the following categories of recipients only to the extent necessary:

5.1 Service Providers

filiplay engages trusted third-party service providers to assist in operating the platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, game software providers, and IT infrastructure providers. These providers are contractually bound to process your data only on filiplay's instructions and in accordance with applicable data protection laws.

5.2 Regulatory Authorities

filiplay may disclose personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities where required by law or in response to a lawful request.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of filiplay's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

6. Data Retention

filiplay retains your personal data for as long as your account remains active and for such additional period as is required to comply with applicable legal and regulatory obligations. Specifically:

• Account and transaction records are retained for a minimum of five (5) years following account closure, in compliance with Philippine AML regulations.
• KYC and identity verification documents are retained for the period required by applicable PAGCOR and AMLC regulations.
• Gaming activity logs are retained for a minimum of three (3) years for regulatory compliance and dispute resolution purposes.
• Marketing consent records are retained for the duration of your consent and for a reasonable period thereafter as evidence of consent.

Upon expiry of the applicable retention period, filiplay will securely delete or anonymize your personal data in accordance with its data disposal procedures.

7. Cookies & Tracking Technologies

filiplay uses cookies and similar tracking technologies on the filiplay platform to enhance your user experience and collect technical data about platform usage. The types of cookies used include:

• Essential Cookies: Required for the platform to function correctly, including maintaining your filiplay Login session and remembering your preferences.
• Performance Cookies: Used to collect anonymized data about how players use the platform, helping filiplay identify and fix technical issues and improve performance.
• Functional Cookies: Used to remember your settings and preferences, such as language and display options, to provide a more personalized experience.

You can manage or disable cookies through your browser settings. Please note that disabling essential cookies may affect the functionality of the filiplay platform, including your ability to log in and access games.

8. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the filiplay platform
• Encrypted storage of passwords and sensitive personal data
• Two-factor authentication (2FA) available for all filiplay accounts
• Regular security audits and penetration testing of the filiplay platform
• Strict access controls limiting employee access to personal data on a need-to-know basis
• Segregated storage of player funds separate from filiplay's operational accounts

While filiplay takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, filiplay will notify you and the National Privacy Commission in accordance with applicable requirements.

9. Your Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by filiplay:

• Right to be Informed: The right to be informed of how your personal data is collected, used, and processed by filiplay.
• Right of Access: The right to request a copy of the personal data filiplay holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to applicable legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact filiplay at [email protected]. filiplay will respond to your request within the timeframe required by applicable law.

10. Children's Privacy

The filiplay platform is strictly intended for persons aged 21 years and older. filiplay does not knowingly collect personal data from individuals under the age of 21. If filiplay discovers that personal data has been collected from a person under 21 years of age, such data will be deleted immediately and the associated account will be suspended pending investigation.

Parents and guardians who believe their child may have registered on the filiplay platform are encouraged to contact [email protected] immediately so that appropriate action can be taken without delay.

11. Changes to This Policy

filiplay reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via the contact details associated with their filiplay account or by prominent notice on the platform.

Your continued use of the filiplay platform following notification of any amendment constitutes your acknowledgment of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how filiplay protects your personal data.

12. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by filiplay, please contact our Data Privacy Officer:

Email: [email protected]

Live chat support is available 24/7 inside your filiplay account dashboard. Our team is ready to assist players across Manila, Cebu, Davao, Quezon City, Makati, and all across the Philippines.