filbey Privacy Policy

filbey ("we", "us", "the Company") is committed to protecting the privacy and personal data of every player who uses the filbey online gaming platform, accessible at filbey.net and all associated mobile-optimised pages (collectively, the "Platform"). This Privacy Policy describes our data collection, use, storage, and sharing practices in clear, plain language that is easy for Filipino players — whether you're logging in from Manila, Cebu, Davao, Makati, or Quezon City — to understand.

This Privacy Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. It is also aligned with PAGCOR's player data protection requirements.

filbey acts as the Personal Information Controller (PIC) for the data described in this policy. Where we engage third-party processors (such as KYC providers, payment gateways, or analytics services), those parties act as Personal Information Processors (PIPs) under our instruction, bound by contractual data processing agreements that meet NPC standards.

filbey collects personal data only where it is necessary, proportionate, and lawful. The categories of personal data we collect from Filipino players are set out in the table below:

We do not collect sensitive personal information (as defined under RA 10173) beyond what is strictly required for KYC compliance and responsible gaming obligations — specifically, age-related data necessary to enforce our 21+ age restriction policy.

filbey processes your personal data only for specific, explicit, and legitimate purposes. We do not use your data in any manner that is incompatible with the purposes for which it was originally collected. The lawful bases and purposes for our data processing activities are as follows:

• Account Registration & Management: To create, maintain, and administer your filbey player account, including verifying your identity and enabling you to log in securely.
• Age & KYC Verification: To confirm that you meet the 21+ age requirement under PAGCOR regulations and to comply with the Anti-Money Laundering Act (AMLA) and its implementing rules.
• Payment Processing: To process PHP deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, and to maintain accurate financial records as required by Philippine law.
• Gameplay & Platform Delivery: To provide access to all filbey games, calculate results, credit winnings, and maintain game integrity and fairness.
• Responsible Gaming Compliance: To monitor your gaming activity and identify patterns that may indicate problem gambling behaviour, enabling us to apply responsible gaming tools or intervene where required by PAGCOR guidelines.
• Fraud Prevention & Security: To detect and prevent fraud, cheating, collusion, money laundering, and unauthorised account access that could harm other players or the integrity of the filbey Platform.
• Customer Support: To respond to your queries, complaints, and requests through live chat and email in Tagalog and English.
• Marketing Communications: To send you promotional offers, bonus notifications, and Platform updates — only where you have provided explicit consent and have not subsequently opted out.
• Legal & Regulatory Compliance: To meet our obligations under PAGCOR, NPC, AMLC, and other relevant Philippine regulatory authorities, including mandatory reporting requirements.
• Platform Improvement: To analyse aggregated, anonymised usage data for the purpose of improving the Platform's performance, user experience, and game selection for Filipino players.

filbey does not sell, rent, or trade your personal data to any third party for commercial purposes. We share your personal data only in the limited circumstances described below, and only to the minimum extent necessary:

• PAGCOR and Philippine Regulatory Authorities: filbey is required by its operating licence to share player transaction data, KYC records, and suspicious activity reports with PAGCOR and, where applicable, the Anti-Money Laundering Council (AMLC) and the National Privacy Commission (NPC).
• KYC Verification Providers: We engage licensed third-party identity verification services to process your KYC documents. These providers act as our Personal Information Processors under strict contractual confidentiality obligations.
• Payment Processing Partners: Your financial data is shared with the relevant payment processor (GCash, PayMaya, BPI, BDO, Metrobank) solely to execute your requested deposit or withdrawal transaction. Each processor maintains its own privacy policy governing their handling of your data.
• Game Content Providers: Where filbey's games are provided by third-party studios, limited gameplay data (such as bet amounts and game outcomes) may be shared with the relevant provider for game operation and integrity auditing purposes. No personal identity data is shared beyond what is operationally required.
• Platform Technology Providers: Cloud infrastructure, cybersecurity, and analytics service providers may process technical and usage data on our behalf, subject to data processing agreements compliant with RA 10173.
• Legal Proceedings: filbey may disclose personal data to courts, law enforcement agencies, or other competent authorities in the Philippines where required by a valid court order, subpoena, or mandatory legal obligation.

filbey uses cookies and similar tracking technologies (such as local storage and session tokens) to operate the Platform efficiently, personalise your experience, and analyse Platform usage. When you first visit filbey.net, you will be presented with a cookie consent notice.

The types of cookies used on the filbey Platform are:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens, CSRF protection cookies, and load-balancing cookies. These cannot be disabled without breaking core Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and last game played — making your filbey experience smoother on return visits.
• Performance & Analytics Cookies: Collect anonymised data about how players interact with the Platform — which pages are visited most, where errors occur, and how long sessions last — to help us improve the Platform for Filipino players.
• Security Cookies: Used to detect and prevent fraudulent activity, including bot detection and unusual login pattern identification.

filbey retains your personal data only for as long as is necessary to fulfil the purposes described in this Privacy Policy, comply with our legal and regulatory obligations, and resolve disputes or enforce our agreements. Our standard retention periods are as follows:

When your personal data is no longer required, filbey will securely delete or anonymise it in a manner that prevents reconstruction or re-identification, in accordance with NPC-approved data disposal procedures.

filbey implements robust technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• Encryption: All personal and financial data is encrypted at rest using AES-256 and in transit using TLS 1.3. Your filbey account password is stored as a salted cryptographic hash — filbey staff cannot read your password in plain text.
• Access Controls: Access to personal data within filbey's systems is restricted to authorised personnel on a strict need-to-know basis. All staff with data access undergo annual data privacy training in line with NPC requirements.
• Two-Factor Authentication (2FA): filbey supports 2FA for player account logins. We strongly encourage all Filipino players to enable 2FA for an additional layer of security.
• Penetration Testing: The filbey Platform undergoes regular independent security penetration testing and vulnerability assessments by certified cybersecurity firms.
• Intrusion Detection: Real-time intrusion detection and prevention systems (IDS/IPS) monitor the Platform continuously for suspicious activity, brute-force attempts, and unusual access patterns.
• Data Breach Response: filbey maintains a documented Personal Data Breach Response Plan. In the event of a breach that poses a risk to player rights, filbey will notify the NPC within 72 hours of discovery and notify affected players without undue delay, in accordance with RA 10173.

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights as a data subject. filbey respects and supports each of these rights in full:

• Right to Be Informed: You have the right to be told what personal data filbey collects about you, why it is collected, how it is used, and with whom it is shared — as set out in this Privacy Policy.
• Right to Access: You may request a copy of the personal data filbey holds about you, along with information about how it is being processed. Requests will be responded to within fifteen (15) business days.
• Right to Rectification: If any personal data filbey holds about you is inaccurate or incomplete, you have the right to request correction. You can update many details directly through your filbey account dashboard.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to filbey's legal and regulatory retention obligations (see Section 6).
• Right to Data Portability: You may request your personal data in a commonly used, machine-readable format (such as CSV or JSON) for transfer to another service provider.
• Right to Object: You may object at any time to the processing of your personal data for direct marketing purposes. You may also object to other processing activities where filbey is relying on legitimate interests as its lawful basis.
• Right to Restrict Processing: In certain circumstances (for example, while a rectification request is being assessed), you may request that filbey restrict further processing of your data.
• Right to Lodge a Complaint: If you believe filbey has violated your rights under RA 10173, you may lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.

filbey strictly prohibits access to and use of the Platform by any person under the age of 21 years, as required under PAGCOR regulations and applicable Philippine law. The filbey Platform is not directed at, and does not knowingly collect personal data from, persons under 21 years of age.

As part of our KYC process, filbey verifies the age of every player before enabling full account functionality, including deposits and withdrawals. Documentary proof of age — such as a government-issued Philippine photo ID — is required.

filbey primarily stores and processes your personal data within the Philippines. However, certain service providers — including cloud hosting infrastructure, KYC verification platforms, and cybersecurity services — may process data in data centres located outside the Philippines (for example, in Singapore, Japan, or the United States).

Where such cross-border transfers occur, filbey ensures that your personal data receives an equivalent level of protection by:

• Entering into data processing agreements with overseas processors that incorporate NPC-recognised standard contractual clauses or equivalent protective mechanisms.
• Assessing the data protection laws of the destination country before transferring data, and applying additional safeguards where necessary.
• Ensuring that any overseas processor is contractually prohibited from using your data for any purpose beyond the specific service they provide to filbey.

filbey will not transfer your personal data to a jurisdiction that the NPC has identified as providing inadequate data protection without your explicit prior consent or unless required by Philippine law.

filbey may update or revise this Privacy Policy from time to time to reflect changes in our data processing practices, updates to Philippine data privacy law, new PAGCOR requirements, or improvements to our Platform. The "Last Updated" date at the top of this page will be revised each time a new version of the Privacy Policy is published.

Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — filbey will notify you by:

• Posting a prominent notice on the filbey homepage and your account dashboard for a minimum of thirty (30) days before the changes take effect.
• Sending a notification to your registered email address summarising the key changes and the effective date.

Your continued use of the filbey Platform after the effective date of a revised Privacy Policy constitutes your acknowledgement of the updated policy. If you do not agree with the revised policy, please stop using the Platform and contact us to close your account.

filbey has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012 and the National Privacy Commission's registration and accountability rules. The DPO is responsible for overseeing filbey's data protection strategy, ensuring compliance with RA 10173, and serving as the primary point of contact for data subject rights requests and privacy-related concerns.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way filbey handles your personal data, you may contact us through the following channels:

• Email (Data Privacy Matters): [email protected] — please use the subject line "Privacy / DPO" for the fastest routing.
• Live Chat: Available 24/7 in Tagalog and English directly through the filbey Platform. Select "Account & Privacy" from the support menu.
• Postal Address: Please request our registered postal address by emailing [email protected] if you need to send a formal written request.

If you are not satisfied with filbey's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC), which is the supervisory authority for data protection matters in the Philippines. The NPC can be reached through its official website at privacy.gov.ph.