Privacy Policy

1 About This Policy

This Privacy Policy ("Policy") describes how filbe ("filbe," "we," "us," or "our") collects, processes, stores, and protects the personal information of users ("you," "Player," or "Data Subject") who access or use the filbe online casino and sports betting platform (the "Platform"), including through the filbe website, mobile interface, live chat, and any associated services.

filbe operates in the Philippines and processes the personal data of Filipino players in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines of the National Privacy Commission (NPC) of the Philippines. Where filbe processes data of players located in other jurisdictions, we apply equivalent data protection standards.

This Policy should be read alongside filbe's Terms & Conditions, which govern your use of the Platform as a whole . By registering an account or using the filbe Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection regulations, filbe acts as the Personal Information Controller (PIC) in respect of the personal data of players registered on the Platform.

As PIC, filbe determines the purposes and means by which your personal data is processed. Third-party service providers engaged by filbe to support platform operations — such as payment processors, KYC verification providers, and game software suppliers — act as Personal Information Processors (PIPs) and process your data solely on filbe's documented instructions.

filbe has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data privacy laws. You may contact our DPO directly at [email protected] for any data privacy-related enquiries or requests.

3 Data We Collect

filbe collects the following categories of personal data from players on the Platform:

4 How We Collect Your Data

filbe collects personal data through the following means:

• Directly from you — when you register a filbe account, complete KYC verification, make deposits or withdrawal requests, contact support, or update your profile settings.
• Automatically through the Platform — when you browse the filbe website or use the mobile interface, our servers and analytics tools automatically collect technical data such as your IP address, device identifiers, session logs, and clickstream data.
• From third-party verification partners — when you submit KYC documents, filbe's verification providers may cross-reference your identity data against government or credit bureau databases to confirm authenticity and age.
• From payment providers — GCash, Maya, BPI, BDO, UnionBank, and other payment partners may share transaction confirmation data with filbe to enable deposit crediting and withdrawal processing.
• From regulatory and law enforcement authorities — filbe may receive data from PAGCOR, the AMLC, or other Philippine regulatory bodies in connection with compliance investigations or mandated reporting obligations.

5 How We Use Your Data

filbe processes your personal data for the following purposes:

• Account management: Creating and maintaining your filbe account, verifying your identity and age (21+ requirement), and authenticating your logins.
• Platform operation: Enabling gameplay, processing bets, calculating and crediting winnings, and delivering live dealer and slot game functionality.
• Payment processing: Crediting deposits, processing withdrawal requests, verifying payment method ownership, and preventing payment fraud.
• Regulatory compliance: Fulfilling obligations under the Data Privacy Act of 2012, PAGCOR gaming regulations, Anti-Money Laundering Act (AMLA), and related Philippine laws, including mandatory transaction reporting to the AMLC.
• Responsible gaming: Monitoring gameplay patterns to identify potential problem gambling behaviour, administering self-exclusion and limit-setting tools, and providing appropriate interventions where warranted.
• Customer support: Responding to queries, resolving disputes, and maintaining records of support interactions for quality and compliance purposes.
• Security & fraud prevention: Detecting and preventing unauthorised account access, bonus abuse, collusion, money laundering, and other prohibited conduct.
• Platform improvement: Analysing aggregated, anonymised usage data to improve game offerings, interface design, and overall player experience on the filbe platform.
• Marketing communications: Sending promotional offers, bonus notifications, and VIP programme updates to players who have opted in to receive such communications. You may opt out at any time.

6 Legal Basis for Processing

filbe processes your personal data on one or more of the following legal bases as recognised under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfil our obligations under the filbe Terms & Conditions, including account management, payment processing, and game operation.
• Legal obligation: Processing required to comply with applicable Philippine laws, including KYC obligations, AML reporting requirements, PAGCOR regulatory directives, and data subject rights requests.
• Legitimate interests: Processing necessary for filbe's legitimate business interests in fraud prevention, security monitoring, and platform improvement, where these interests are not overridden by your rights as a data subject.
• Consent: Processing for purposes such as marketing communications and optional personalisation features, where we have obtained your express prior consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7 Data Sharing & Disclosure

filbe does not sell, rent, or trade your personal data to third-party marketers. We share your personal data only in the following circumstances and with the following categories of recipients:

• Payment service providers: GCash, Maya, BPI, BDO, UnionBank, Coins.ph, and other payment partners receive the minimum personal and financial data necessary to process your transactions. These providers are bound by their own data protection obligations and are not permitted to use your data for any purpose other than transaction processing.
• KYC and identity verification providers: Accredited third-party verification services receive your identity documents and personal details solely for the purpose of performing mandatory age and identity verification checks.
• Game software providers: Licensed game content providers may receive anonymised or pseudonymised gaming session data necessary to operate live dealer streams, RNG games, and jackpot networks.
• Regulatory and law enforcement authorities: filbe is required by Philippine law to disclose personal and financial data to PAGCOR, the AMLC, the NPC, and other competent authorities upon receipt of a valid legal request or as mandated by applicable reporting obligations.
• Professional advisers: Legal counsel, auditors, and compliance consultants engaged by filbe may access player data on a strictly need-to-know basis, subject to professional confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of filbe's business assets, player data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

8 International Data Transfers

filbe's primary operations and data storage infrastructure are based in the Philippines. Certain third-party service providers engaged by filbe — including game software suppliers and cloud infrastructure partners — may process personal data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, filbe ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. Such safeguards include contractual data processing agreements incorporating the NPC's standard contractual clauses, binding corporate rules where applicable, and transfers only to jurisdictions recognised as providing adequate data protection.

9 Data Retention

filbe retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specific retention periods by data category are as follows:

• Identity and KYC data: Retained for a minimum of five (5) years following account closure, as required by the Anti-Money Laundering Act and PAGCOR record-keeping requirements.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of each transaction for AML compliance and tax record purposes.
• Gaming session logs: Retained for a minimum of three (3) years for dispute resolution and regulatory audit purposes.
• Support and communications data: Retained for two (2) years from the date of last interaction, unless longer retention is required for an ongoing dispute or legal proceeding.
• Marketing preference data: Retained until you withdraw consent or close your account, whichever occurs first.

Upon expiry of the applicable retention period, filbe will securely delete or anonymise your personal data in accordance with its data disposal procedures, unless further retention is required by a specific legal obligation or active legal proceeding.

10 Cookies & Tracking

The filbe Platform uses cookies and similar tracking technologies to support platform functionality, security, and performance analytics. The categories of cookies used on the Platform are as follows:

• Strictly necessary cookies: Essential for the Platform to function, including session authentication, security tokens, and load balancing. These cannot be disabled without preventing your use of the Platform.
• Functional cookies: Remember your preferences such as language settings, game filters, and responsible gaming limit configurations between sessions.
• Analytics cookies: Collect anonymised or aggregated data on how players interact with the Platform, which pages are visited most frequently, and where technical errors occur. This data is used exclusively for internal platform improvement.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and account takeover attempts by analysing behavioural patterns during your session.

filbe does not use third-party advertising or tracking cookies that share your data with external ad networks. You may manage your cookie preferences through your browser settings; however, disabling strictly necessary cookies may impair your ability to access certain platform features.

11 Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in respect of your personal data held by filbe:

To exercise any of the above rights, please contact filbe's Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." filbe will acknowledge your request within five (5) business days and respond in full within thirty (30) calendar days, as required by the Data Privacy Act.

12 Security Measures

filbe implements a layered set of technical and organisational security measures designed to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

• Encryption: All data transmitted between your device and the filbe Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest — including financial records and KYC documents — is encrypted using AES-256 encryption.
• Access controls: Personal data is accessible only to filbe personnel and authorised third-party processors who have a legitimate, documented need to access it. Access is governed by role-based permissions and reviewed regularly.
• Two-factor authentication: filbe offers and encourages the use of two-factor authentication (2FA) for player accounts to reduce the risk of unauthorised access resulting from compromised credentials.
• Penetration testing and audits: The filbe Platform undergoes regular third-party security assessments, penetration testing, and vulnerability scans to identify and remediate potential weaknesses before they can be exploited.
• Incident response: filbe maintains a documented data breach response procedure. In the event of a personal data breach affecting Filipino players, filbe will notify affected individuals and the National Privacy Commission within the timeframes prescribed by the Data Privacy Act.

13 Minors

The filbe Platform is strictly intended for adults aged 21 years and above. filbe does not knowingly collect personal data from individuals under the age of 21. Age verification is a mandatory step in the filbe KYC process, and accounts found to have been registered by persons under 21 will be immediately closed.

If you are a parent or guardian and believe that a minor has registered a filbe account or provided personal data to filbe, please contact us immediately at [email protected]. filbe will investigate and, where confirmed, promptly delete all data associated with the underage account.

14 Changes to This Policy

filbe reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, filbe will notify registered players via the email address on file or through a prominent notice on the Platform prior to the changes taking effect.

The revised Policy will display an updated "Last Updated" date at the top of this page. Your continued use of the filbe Platform after the effective date of any revised Policy constitutes your acknowledgment of the changes. We encourage you to review this Policy periodically to stay informed about how filbe protects your personal information.

15 Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or filbe's handling of your personal data, please contact our Data Protection Officer through the following channels:

• Email: [email protected] (Subject: "Privacy Policy Enquiry" or "Data Subject Rights Request")
• Live Chat: Available in-platform 24 hours a day, 7 days a week
• Coverage: Serving Filipino players nationwide across Metro Manila, Cebu, Davao, Quezon City, and all regions of the Philippines

If you are not satisfied with filbe's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the independent government body responsible for administering and enforcing the Data Privacy Act of 2012.