filbe Privacy Policy

1. Introduction

filbe ("the Operator," "we," "us," or "our") operates the online gaming platform accessible at filbe.cam and is committed to protecting the privacy and personal data of all users ("you," "your," or "User") who access or register on our platform. This Privacy Policy describes the types of personal information we collect, how we use and protect that information, under what circumstances we share it, and what rights you have in relation to your data.

This Privacy Policy is issued in compliance with Republic Act No. 10173, known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and applicable regulations issued by the National Privacy Commission (NPC) of the Philippines. It also reflects obligations arising from our license under the Philippine Amusement and Gaming Corporation (PAGCOR) and from Philippine Anti-Money Laundering Act (AMLA) requirements.

By creating a filbe account and using the filbe platform, you acknowledge that you have read, understood, and agreed to the practices described in this Privacy Policy. This Policy forms part of the filbe Terms and Conditions and should be read together with that document.

2. Personal Data We Collect

2.1 Information You Provide Directly

When you register for a filbe account, verify your identity, use our services, or communicate with our support team, we collect the following categories of personal data:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification numbers (e.g., Philippine passport number, driver's license number, national ID number).
• Contact Data: Email address, mobile phone number, and residential address (including barangay, city or municipality, province, and region).
• Verification Documents: Copies or images of government-issued identity documents and proof of address submitted for Know Your Customer (KYC) verification.
• Financial Data: Payment method details (e.g., GCash-registered mobile number, BPI or BDO account details used for bank transfers), transaction history, deposit and withdrawal records. filbe does not store full credit or debit card numbers directly.
• Account Credentials: Username and hashed password. We do not store your password in plain text.
• Communications: Records of your interactions with filbe customer support, including chat logs, email correspondence, and complaint submissions.

2.2 Information Collected Automatically

When you access the filbe platform, certain technical and behavioral data is collected automatically through the operation of our systems and third-party analytics tools:

• Device and Technical Data: IP address, device type, operating system version, browser type and version, screen resolution, and mobile network operator.
• Usage Data: Pages visited on filbe, game sessions initiated, session duration, features accessed, betting history, and navigation patterns within the platform.
• Location Data: Approximate geographic location inferred from your IP address, used to verify compliance with territorial gaming restrictions.
• Cookie and Tracking Data: Data collected through cookies, web beacons, and similar tracking technologies as described in Section 6 of this Policy.

2.3 Information from Third Parties

filbe may receive personal data about you from third-party sources in limited circumstances, including:

• Identity verification service providers engaged to assist with KYC and AML compliance checks.
• Payment processors and e-wallet providers (GCash, Maya, banks) who share transaction confirmation data with us.
• PAGCOR or other regulatory and law enforcement authorities, in the course of regulatory audits or legal investigations.

The following table summarizes the main categories of personal data filbe processes:

3. How We Use Your Personal Data

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

• Account Registration and Management: To create and maintain your filbe account, authenticate your identity at login, and administer your account settings and preferences.
• Identity Verification and KYC Compliance: To verify that you are who you claim to be, that you meet the minimum age requirement of 21 years, and to comply with PAGCOR-mandated KYC procedures.
• Service Delivery: To allow you to access and play games on the filbe platform, process bets and game outcomes, credit winnings, and display your transaction and gameplay history.
• Payment Processing: To facilitate deposits to and withdrawals from your filbe wallet using your registered payment methods.
• Anti-Money Laundering (AML) Compliance: To monitor transactions and gameplay patterns for indicators of money laundering, fraud, or other financial crimes, and to report suspicious transactions to relevant Philippine authorities as required by the AMLA.
• Customer Support: To respond to your queries, complaints, and support requests, and to maintain records of those interactions for service quality and dispute resolution purposes.
• Security and Fraud Prevention: To detect, investigate, and prevent unauthorized access, fraudulent activity, bonus abuse, collusion, and other activities that undermine platform integrity.
• Responsible Gaming: To monitor usage patterns that may indicate problem gambling behavior and to proactively engage responsible gaming tools where warranted. If you have set deposit limits or self-exclusion, your data is used to enforce those restrictions.
• Platform Improvement: To analyze aggregated usage data to improve the filbe platform, user interface, game selection, and service quality. This analysis uses anonymized or pseudonymized data where possible.
• Legal and Regulatory Compliance: To comply with applicable Philippine law, PAGCOR directives, NPC requirements, and any other regulatory obligations binding upon filbe.
• Marketing Communications: Subject to your consent and applicable law, to send you promotional offers, bonuses, and platform updates relevant to your filbe account. You may withdraw marketing consent at any time through your account settings.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, filbe processes your personal data on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform the contract between you and filbe — specifically, to register your account and deliver gaming services as described in the Terms and Conditions.
• Legal Obligation: Processing is required to comply with Philippine law, including PAGCOR licensing conditions, AMLA requirements, tax reporting obligations, and NPC regulations.
• Legitimate Interests: Processing is necessary for the legitimate business interests of filbe, including fraud prevention, security, platform improvement, and responsible gaming monitoring, provided these interests are not overridden by your privacy rights.
• Consent: For specific activities such as direct marketing communications, filbe will seek your explicit consent prior to processing. You have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing and Disclosure

5.1 Service Providers

filbe engages trusted third-party service providers to assist in delivering and improving our services. These providers may process your personal data on our behalf under strict data processing agreements that require them to protect your data and use it only for the specified purpose. Categories of service providers include payment processors, KYC and identity verification providers, cloud infrastructure and hosting providers, game software providers, and customer support platform vendors.

5.2 Regulatory and Law Enforcement Authorities

filbe will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue (BIR), and other competent Philippine government authorities when required to do so by law, court order, or regulatory directive. filbe will also disclose data where necessary to investigate, prevent, or report suspected fraud, money laundering, or other criminal activity.

5.3 No Sale of Personal Data

filbe does not sell, rent, or license your personal data to third parties for their own marketing or commercial purposes. Any data sharing with partners is limited to what is necessary to deliver filbe services to you.

5.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of filbe's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified via email or a prominent notice on the filbe platform prior to such a transfer and given the opportunity to exercise applicable data rights.

6. Cookies and Tracking Technologies

filbe uses cookies and similar tracking technologies (including web beacons and session identifiers) to operate the platform, remember your preferences, analyze usage, and support security functions. The following types of cookies are used on filbe:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies and security tokens. They cannot be disabled without disrupting core platform functions.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics Cookies: Used to collect anonymized information about how users navigate and interact with the filbe platform, helping us identify areas for improvement. Data collected is aggregated and does not personally identify individual users.
• Security Cookies: Used to detect fraudulent activity, bot traffic, and unauthorized access attempts.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the filbe platform. filbe does not use third-party advertising cookies or tracking pixels for cross-site behavioral advertising.

7. Data Security

filbe implements appropriate technical and organizational measures to protect personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Security measures include, but are not limited to:

• SSL/TLS encryption for all data in transit between your device and the filbe platform.
• Encryption of sensitive data at rest, including identity documents and financial information.
• Role-based access controls limiting employee and contractor access to personal data on a need-to-know basis.
• Regular security assessments and penetration testing of platform infrastructure.
• Two-factor authentication (2FA) available to all filbe users and mandatory for privileged internal accounts.
• Incident response procedures designed to detect, contain, and notify affected users and regulators of any personal data breach in accordance with NPC breach notification requirements.

No security system is completely impenetrable. While filbe takes reasonable precautions, we cannot guarantee that unauthorized third parties will never circumvent our security measures. You are encouraged to use a strong, unique password for your filbe account and to enable two-factor authentication.

8. Data Retention

filbe retains personal data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following considerations:

• Active Account Data: Retained for the duration of your account's active status and for a period thereafter as required by PAGCOR, AMLA, and Philippine tax law — typically a minimum of five (5) years from account closure or the last transaction date.
• Transaction Records: Financial transaction records are retained for the period required under AML regulations and BIR tax record-keeping rules.
• KYC Documents: Copies of identity documents submitted for KYC verification are retained for the period required by PAGCOR and AMLA regulations, currently a minimum of five (5) years from account closure.
• Support Communications: Customer support records are retained for a period reasonably necessary to resolve disputes and comply with consumer protection obligations.
• Marketing Data: Data used for marketing communications is retained until you withdraw consent or request deletion, provided no other legal basis for retention applies.

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

9. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights in relation to your personal data held by filbe:

• Right to Be Informed: The right to be told how your personal data is being collected and processed, as described in this Privacy Policy.
• Right to Access: The right to request a copy of the personal data filbe holds about you and information about how it is being processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data held by filbe.
• Right to Erasure (Right to Be Forgotten): The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to overriding legal obligations.
• Right to Object: The right to object to the processing of your personal data, particularly where filbe relies on legitimate interests as the legal basis for processing or where data is used for direct marketing.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe filbe has violated your data privacy rights.

To exercise any of these rights, please contact the filbe Data Protection Officer (DPO) using the contact information in Section 13 of this Policy. filbe will respond to verified requests within the timeframe required by applicable law.

10. International Data Transfers

filbe's primary operations and data storage infrastructure are located within or managed for the Philippine market. In certain cases, personal data may be processed or accessed by service providers operating in other jurisdictions — for example, cloud infrastructure providers, KYC verification platforms, or game software vendors headquartered outside the Philippines.

When personal data is transferred outside the Philippines, filbe ensures that appropriate safeguards are in place in accordance with the Data Privacy Act of 2012 and NPC guidelines, including contractual data protection clauses with the receiving parties. filbe does not transfer your data to countries that do not provide adequate data protection standards without implementing appropriate safeguards.

11. Minors and Age Restriction

The filbe platform is strictly for individuals aged twenty-one (21) years and older, in compliance with PAGCOR regulations governing casino-style gaming in the Philippines. filbe does not knowingly collect personal data from persons under 21 years of age. If filbe discovers that personal data has been collected from a person below the minimum age, that data will be deleted immediately and the associated account closed.

If you are a parent or guardian and believe your child has registered on filbe or provided personal data to filbe, please contact us immediately using the contact information in Section 13 so that we can take corrective action.

12. Changes to This Privacy Policy

filbe reserves the right to update or modify this Privacy Policy at any time. When material changes are made, we will provide notice by posting the updated Policy on the filbe website with the revised effective date, and where appropriate, by notifying registered users by email. Your continued use of filbe following the posting of changes constitutes your acknowledgment of the revised Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how filbe protects your personal information.

13. Contact Information

If you have questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by filbe, you may contact our Data Protection Officer at:

Data Protection Officer — filbe
Email (non-clickable plain text):
[email protected]

filbe will acknowledge your request within three (3) business days and provide a substantive response within the timeframe required under the Data Privacy Act. For escalated complaints, you may contact the National Privacy Commission of the Philippines through their official channels.