filplay Privacy Policy

1. Introduction

filplay ("filplay", "we", "us", "our") is committed to protecting the privacy and personal data of all players who use the filplay platform at filplay.org. This Privacy Policy ("Policy") describes how filplay collects, uses, discloses, retains, and protects personal data in connection with the operation of its online casino and gaming services.

This Policy applies to all individuals who access or use the filplay platform, including registered players, persons who have submitted registration information but have not yet completed registration, and visitors to the filplay website. This Policy applies regardless of the device or location from which the platform is accessed, and covers players across all Philippine regions including Metro Manila, Metro Cebu, Davao City, Quezon City, Makati, and beyond.

filplay's data privacy practices are designed to comply with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the relevant issuances of the National Privacy Commission (NPC). Where other applicable laws impose additional obligations, filplay will comply with those obligations to the extent they apply.

2. Data Controller

For the purposes of the Philippine Data Privacy Act and this Policy, filplay is the personal information controller in respect of the personal data processed in connection with the filplay platform. filplay determines the purposes and means of processing personal data collected from its players and website visitors.

For data privacy inquiries, requests to exercise your rights, or concerns about how filplay handles your personal data, you may contact our Data Protection Officer at: [email protected].

3. Personal Data We Collect

filplay collects the following categories of personal data, depending on your level of engagement with the platform:

3.1 Registration and Identity Data

• Full legal name as it appears on a Philippine government-issued identification document
• Date of birth (to verify age eligibility — players must be 21 years of age or older)
• Residential address in the Philippines
• Email address and Philippine mobile phone number
• Username and hashed password (passwords are never stored in plain text)
• Nationality and, where relevant, tax identification number

3.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's licence, UMID, voter's ID, national ID)
• Proof of address documents (e.g., utility bills, bank statements issued to your Philippine address)
• Selfie or facial image where required for enhanced identity verification
• Proof of payment method ownership (e.g., screenshot of GCash account registered in your name)

3.3 Financial and Transaction Data

• Deposit and withdrawal transaction history including amounts, dates, payment methods used, and transaction reference numbers
• GCash, Maya, and bank account details used for deposits and withdrawals (account identifiers, not full account credentials)
• Bonus and promotional activity records
• Account balance history

3.4 Gaming Activity Data

• Game session records including games played, bets placed, winnings, and losses
• Sports betting selections and outcomes
• Timestamps and duration of gaming sessions
• Responsible gaming tool activations (deposit limits, cooling-off periods, self-exclusion requests)

3.5 Technical and Usage Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser version
• Mobile network operator (e.g., Globe, Smart, DITO)
• Session logs including login timestamps, pages visited, and features used
• Cookie identifiers and similar tracking technologies (see Section 10)

3.6 Communications Data

• Records of your communications with filplay customer support via live chat and email
• Feedback, survey responses, and complaints submitted to filplay
• Marketing preferences and communication opt-in/opt-out records

4. How We Collect Personal Data

filplay collects personal data through the following means:

• Direct collection: Information you provide when registering a filplay account, completing KYC verification, making a deposit or withdrawal, contacting support, or responding to a promotion.
• Automated collection: Technical data collected automatically when you access the filplay website, including through cookies, server logs, and similar technologies.
• Third-party sources: Identity verification data obtained from third-party KYC service providers and fraud detection services engaged by filplay. Financial data provided by payment processors such as GCash and Maya when you initiate a transaction.
• Public sources: Publicly available information used to verify player identity or investigate fraud where filplay has a legitimate interest in doing so.

5. How We Use Your Personal Data

filplay uses the personal data it collects for the following purposes:

• To create, manage, and maintain your filplay player account
• To verify your identity and age eligibility in compliance with applicable Philippine gaming regulations
• To process deposits, withdrawals, and other financial transactions on the platform
• To detect, investigate, and prevent fraud, money laundering, and other illegal activity
• To operate and improve the filplay platform, including game performance, user interface, and payment systems
• To provide customer support and respond to your enquiries and complaints
• To send you transactional communications including deposit confirmations, withdrawal notifications, and security alerts
• To send you promotional communications about filplay bonuses and offers, where you have provided consent or where filplay has a legitimate interest in doing so
• To comply with filplay's legal and regulatory obligations under Philippine law
• To enforce filplay's Terms and Conditions and other applicable policies
• To monitor responsible gaming compliance and apply player-requested restrictions

6. Legal Basis for Processing

filplay processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity: Processing necessary to perform the contract between you and filplay (your account agreement and Terms and Conditions).
• Legal obligation: Processing required to comply with applicable Philippine law, including anti-money laundering obligations under Republic Act No. 9160 (as amended) and applicable gaming regulations.
• Legitimate interests: Processing conducted for filplay's legitimate business interests, including fraud prevention, security, platform improvement, and direct marketing, where those interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as for certain types of marketing communications.

7. Sharing of Personal Data

filplay does not sell your personal data to third parties. filplay may share your personal data with the following categories of recipients, only to the extent necessary for the stated purpose:

• Payment processors: GCash (G-Xchange, Inc.), Maya (Voyager Innovations), BPI, BDO, Metrobank, and other payment service providers, to process your deposits and withdrawals.
• KYC and fraud prevention providers: Third-party identity verification and fraud detection services engaged to support filplay's AML compliance programme.
• Technology service providers: Cloud hosting, database management, and platform infrastructure providers who process data on filplay's behalf under data processing agreements.
• Regulatory and law enforcement authorities: The Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), applicable gaming regulatory bodies, and law enforcement agencies, where filplay is legally required or permitted to disclose.
• Legal and professional advisers: Lawyers, auditors, and other professional advisers engaged by filplay, subject to professional confidentiality obligations.

8. International Data Transfers

filplay's primary data processing infrastructure is located in the Asia-Pacific region. Where personal data is transferred to service providers located outside the Philippines, filplay will ensure that such transfers comply with the requirements of the Philippine Data Privacy Act, including implementing appropriate safeguards such as data transfer agreements, standard contractual clauses, or reliance on adequacy determinations where applicable.

Players based in the Philippines who have concerns about the international transfer of their personal data may contact filplay's Data Protection Officer for more information about the safeguards in place.

9. Data Retention

filplay retains personal data for as long as is necessary to fulfil the purposes for which it was collected, and in any case for the minimum periods required by applicable Philippine law. In general:

• Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of the relevant transaction.
• Gaming activity logs are retained for a minimum of three (3) years.
• Customer support communications are retained for a minimum of two (2) years.
• Marketing consent records are retained until consent is withdrawn plus an additional period sufficient to demonstrate compliance.

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

10. Cookies and Tracking Technologies

filplay uses cookies and similar tracking technologies on its website and platform. Cookies are small text files stored on your device that help filplay recognise returning users, maintain session state, and collect analytical data about platform usage.

filplay uses the following categories of cookies:

• Strictly necessary cookies: Essential for platform operation, including maintaining your login session. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and display options.
• Analytical cookies: Collect aggregate data about how players use the filplay platform to support ongoing improvement and performance optimisation.
• Marketing cookies: Used to deliver relevant promotional content and track the effectiveness of filplay campaigns, where consent has been obtained.

You may control cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the filplay platform. filplay does not use third-party social media tracking pixels on pages that require login.

11. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, filplay players have the following rights in respect of their personal data:

To exercise any of these rights, please contact filplay's Data Protection Officer at [email protected]. filplay will respond to verified requests within thirty (30) calendar days, as required by applicable Philippine data privacy regulations.

12. Children's Privacy

filplay does not knowingly collect personal data from persons under the age of 21. The filplay platform is strictly intended for adult use by players who are 21 years of age or older, in accordance with applicable Philippine gaming regulations. If filplay discovers that it has inadvertently collected personal data from a person under the age of 21, it will take immediate steps to delete that data and close the relevant account.

If you are a parent or guardian and believe your child has provided personal data to filplay, please contact us immediately at [email protected].

13. Data Security

filplay implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include, but are not limited to:

• TLS encryption for all data in transit between your device and the filplay platform
• Encryption at rest for sensitive personal data including identity documents and payment information
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Regular security assessments and penetration testing of the filplay platform
• Multi-factor authentication requirements for staff accessing systems containing personal data
• Incident response procedures for investigating and addressing potential data breaches

While filplay takes data security seriously, no system can guarantee absolute protection. Players are encouraged to use strong, unique passwords for their filplay accounts, enable two-factor authentication, and report any suspected security incidents to filplay support immediately.

14. Changes to This Privacy Policy

filplay may update this Privacy Policy from time to time to reflect changes in its data processing practices, applicable law, or regulatory guidance. When material changes are made, filplay will notify registered players via email to their registered address and display a prominent notice on the platform prior to the changes taking effect.

The date at the top of this Policy indicates when it was last updated. Your continued use of the filplay platform following the effective date of any updated Policy constitutes your acceptance of the updated terms.

15. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or filplay's handling of your personal data, please contact filplay's Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 via the filplay platform
• Response Time: filplay will acknowledge your privacy request within five (5) business days and provide a full response within thirty (30) calendar days.