filgame Privacy Policy

1. Data Controller

1.1  For the purposes of this Privacy Policy, filgame ("we," "us," or "our") is the data controller responsible for the personal information collected through the filgame platform at filgame.vip ("Platform").

1.2  filgame processes personal data in compliance with Republic Act No. 10173 — the Data Privacy Act of 2012 ("DPA") of the Philippines — and its implementing rules and regulations issued by the National Privacy Commission ("NPC").

1.3  Questions or requests relating to this Privacy Policy may be directed to our Data Protection Officer at: [email protected]

2. Personal Data We Collect

2.1  filgame collects the following categories of personal data:

2.2  filgame does not collect sensitive personal information (as defined under the DPA) beyond what is required for identity verification and regulatory compliance.

3. How We Collect Your Data

3.1  filgame collects personal data through the following means:

• Directly from you: when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or respond to a survey;
• Automatically: through cookies, server logs, and similar technologies as you browse and use the Platform;
• From third parties: identity verification providers, payment processors (e.g., GCash, PayMaya, BPI, BDO), fraud prevention services, and regulatory bodies as required by Philippine law.

4. How We Use Your Personal Data

4.1  filgame uses your personal data for the following purposes:

• Account Management: to create, maintain, and secure your filgame account;
• Identity Verification (KYC): to confirm your identity and age (21+) as required by PAGCOR regulations and the Anti-Money Laundering Act;
• Payment Processing: to process deposits and withdrawals via GCash, PayMaya, and bank channels;
• Gameplay & Platform Operations: to deliver game services, calculate and pay winnings, and maintain game records;
• Fraud Prevention & Security: to detect, investigate, and prevent fraudulent activity, money laundering, and unauthorized account access;
• Regulatory Compliance: to comply with obligations under Philippine law, including reporting requirements to PAGCOR and AMLC;
• Customer Support: to respond to your enquiries, complaints, and support requests;
• Responsible Gaming: to monitor gambling patterns and administer responsible gaming tools where appropriate;
• Service Improvement: to analyze usage patterns, fix technical issues, and improve the Platform experience for Filipino players;
• Marketing (where consented): to send you promotional offers, bonus notifications, and product updates via your registered contact details, only where you have given explicit consent.

4.2  filgame will not use your personal data for any purpose incompatible with those listed above without first obtaining your consent or establishing an alternative lawful basis.

5. Legal Basis for Processing

5.1  filgame processes your personal data on the following legal grounds under the Data Privacy Act of 2012:

• Contract Performance: processing necessary to provide the services you have requested (account registration, gameplay, payments);
• Legal Obligation: processing required to comply with Philippine laws, including PAGCOR licensing conditions and AMLA requirements;
• Legitimate Interests: processing for fraud prevention, security monitoring, and platform improvement, where these interests are not overridden by your privacy rights;
• Consent: for marketing communications and optional data uses where we have sought and obtained your explicit consent — which you may withdraw at any time.

6. Sharing Your Personal Data

6.1  filgame does not sell your personal data. We may share your data with the following categories of third parties strictly as necessary:

• Payment Processors: GCash (Mynt), PayMaya (Voyager), BPI, BDO, Metrobank, Visa, and Mastercard — solely to process your transactions;
• Identity Verification Providers: third-party KYC and age verification services used to confirm your identity documents;
• Game Providers: licensed software providers (e.g., PG Soft, JILI, Pragmatic Play) who need transaction data to deliver game services;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission ("NPC"), and law enforcement agencies — where required by law or valid legal process;
• IT & Cloud Service Providers: hosting, security, and infrastructure providers bound by data processing agreements consistent with the DPA;
• Professional Advisors: lawyers, auditors, and accountants where necessary for legitimate legal and financial compliance purposes.

6.2  All third-party processors engaged by filgame are contractually required to maintain adequate data protection standards consistent with Philippine law.

6.3  filgame does not transfer your personal data outside the Philippines except where legally permitted and subject to appropriate safeguards.

7. Data Retention

7.1  filgame retains your personal data for as long as your account is active and for a minimum period of five (5) years after account closure, in compliance with Philippine anti-money laundering regulations which require retention of customer records for at least five years.

7.2  Gaming records and transaction logs are retained for a minimum of five (5) years from the date of the transaction, as required by PAGCOR and AMLC regulations.

7.3  Where personal data is processed solely on the basis of your consent (e.g., marketing emails), we will retain it only until you withdraw your consent or request deletion, whichever is earlier.

7.4  After the applicable retention period, personal data is securely deleted or irreversibly anonymized.

8. Security of Your Personal Data

8.1  filgame implements industry-standard technical and organizational security measures to protect your personal data, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and filgame servers;
• Encryption of sensitive data at rest, including financial data and identity document copies;
• Access controls ensuring that only authorized filgame personnel can access personal data, on a need-to-know basis;
• Regular security audits and vulnerability assessments of the Platform infrastructure;
• Multi-factor authentication options for Player accounts;
• Automatic session timeout for inactive logins.

8.2  In the event of a personal data breach that is likely to adversely affect your rights and freedoms, filgame will notify you and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, in accordance with the DPA.

9. Cookies & Tracking Technologies

9.1  filgame uses cookies and similar tracking technologies to operate the Platform, including:

• Essential Cookies: required for core Platform functionality — login sessions, security, and account preferences. These cannot be disabled.
• Analytics Cookies: used to understand how Filipino players navigate and use the Platform, enabling us to improve performance and user experience.
• Functional Cookies: used to remember your language settings, game preferences, and responsible gaming limits.

9.2  Non-essential cookies (analytics and functional) are only set with your consent. You may adjust your cookie preferences at any time via your browser settings or by contacting our support team.

10. Your Privacy Rights

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

• Right to Be Informed: to know how your personal data is being collected and processed — addressed by this Privacy Policy;
• Right of Access: to obtain a copy of the personal data filgame holds about you;
• Right to Rectification: to correct inaccurate or incomplete personal data in your filgame account;
• Right to Erasure: to request deletion of your personal data where it is no longer needed for the purposes for which it was collected, subject to our legal retention obligations;
• Right to Object: to object to certain processing activities, including direct marketing;
• Right to Data Portability: to receive a copy of the personal data you provided to filgame in a structured, machine-readable format;
• Right to Withdraw Consent: where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of prior processing.

10.2  To exercise any of the above rights, submit a written request to our Data Protection Officer at: [email protected]. filgame will respond within thirty (30) days of receiving a valid request.

10.3  If you believe your data privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).

11. Minors

11.1  The filgame Platform is strictly restricted to individuals aged 21 years and above. filgame does not knowingly collect personal data from persons under 21 years of age.

11.2  If filgame discovers that personal data has been collected from a person under 21, we will immediately suspend the relevant account, delete the data, and report the incident as required by applicable law.

11.3  If you believe a minor has accessed the filgame Platform, please contact us immediately at [email protected].

12. Changes to This Privacy Policy

12.1  filgame may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or the Platform's features. Material changes will be communicated to registered Players via email or a prominent on-Platform notice at least seven (7) days before taking effect.

12.2  Your continued use of the Platform following the effective date of an updated Privacy Policy constitutes your acceptance of the revised policy. If you do not agree with material changes, you may close your account in accordance with our Terms & Conditions.

13. Contact Us

13.1  For any questions, concerns, or requests relating to this Privacy Policy or filgame's data practices, please contact our Data Protection Officer:

You also have the right to file a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.