filgame Privacy Policy

1. Data Controller

filgame ("we," "us," "our") is the data controller responsible for the personal information collected through the filgame.org platform ("Platform"). filgame operates under the PAGCOR-regulated online gaming framework applicable to the Republic of the Philippines. As data controller, filgame determines the purposes for which and the means by which personal data is processed in connection with Platform services.

Questions or requests relating to this Privacy Policy may be directed to filgame's support team at the contact details provided in Section 13 of this Policy.

2. Personal Data We Collect

2.1 Registration Data

When you create a filgame account, we collect the following information:

• Full legal name as it appears on a government-issued ID;
• Date of birth (for age verification — 21+ only);
• Philippine mobile number (Globe, Smart, or DITO);
• Email address;
• Home address (province/city, including Metro Manila, Cebu, Davao, and other Philippine locations);
• Chosen username and encrypted password.

2.2 Identity Verification (KYC) Data

To comply with PAGCOR regulations and Philippine Anti-Money Laundering Act (AMLA) obligations, filgame may collect copies of government-issued identification documents such as a Philippine passport, SSS/GSIS ID, UMID, driver's license, or PhilSys national ID. Selfie photographs for liveness verification may also be required.

2.3 Transaction Data

We collect records of all deposits, withdrawals, bonus claims, and betting transactions associated with your account. Payment method details (e.g., GCash mobile number, PayMaya account reference) are collected for transaction processing; full payment credentials are not stored by filgame.

2.4 Technical and Usage Data

When you access the Platform, we automatically collect certain technical data including your IP address, device type and operating system, browser type and version, session timestamps, pages visited, games played, and bet amounts. This data is used for security, fraud prevention, platform analytics, and service improvement.

2.5 Communications Data

We retain records of communications between you and filgame customer support, including chat logs, emails, and any documents submitted in connection with complaints or disputes.

3. How We Use Your Personal Data

filgame uses the personal data collected for the following purposes:

• Account management — creating and maintaining your filgame account, processing login requests, and providing access to Platform services;
• Age and identity verification — confirming that you meet the 21-year minimum age requirement and verifying your identity as required by PAGCOR regulations and Philippine law;
• Transaction processing — processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank in Philippine Pesos;
• Regulatory compliance — meeting obligations under PAGCOR licensing requirements, the AMLA, and RA 10173;
• Fraud prevention and security — detecting, investigating, and preventing fraudulent activity, unauthorized account access, and prohibited conduct;
• Customer support — responding to queries, resolving disputes, and providing assistance;
• Platform improvement — analyzing usage patterns to improve game offerings, performance, and user experience;
• Responsible gaming — monitoring play behavior to identify potential problem gambling indicators and administering self-exclusion or limit tools when requested;
• Marketing communications — sending promotional offers, bonus notifications, and platform updates where you have provided explicit opt-in consent.

4. Legal Basis for Processing

filgame processes your personal data on the following legal bases, as recognized under the Data Privacy Act of 2012 (RA 10173):

• Contractual necessity — processing required to fulfill our obligations under the filgame Terms and Conditions, including account management and transaction processing;
• Legal obligation — processing required to comply with PAGCOR regulations, AMLA, NPC requirements, and other applicable Philippine laws;
• Legitimate interests — processing for fraud prevention, security monitoring, and platform analytics where our legitimate interests are not overridden by your data protection rights;
• Consent — processing for marketing communications, which relies on your explicit opt-in consent and which you may withdraw at any time.

5. Data Sharing and Disclosure

filgame does not sell your personal data to third parties. We may share your data with the following categories of recipients in the circumstances described:

• Game providers — JILI, PG Soft, Pragmatic Play, and other licensed game studios receive limited technical session data (e.g., player token, currency, and bet data) necessary to facilitate gameplay. These providers are contractually bound to data confidentiality standards;
• Payment processors — GCash, PayMaya, and banking partners receive transaction data strictly necessary to process deposits and withdrawals;
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law or regulatory order;
• Technical service providers — cloud hosting, security monitoring, and analytics service providers operating under data processing agreements that restrict use of your data to the purposes specified by filgame;
• Law enforcement — Philippine law enforcement agencies where disclosure is required pursuant to a valid legal process or court order.

6. Data Retention

filgame retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC records: five (5) years from account closure, as required by PAGCOR regulations and the AMLA;
• Transaction records: five (5) years from the date of each transaction;
• Customer support records: three (3) years from the date of the communication;
• Marketing consent records: retained until consent is withdrawn plus an additional one (1) year for audit purposes.

Upon expiry of applicable retention periods, personal data will be securely deleted or anonymized in accordance with our data disposal procedures.

7. Cookies and Tracking Technologies

filgame uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential cookies — session management cookies required for login authentication and security. These cannot be disabled without affecting Platform functionality;
• Analytics cookies — used to analyze Platform usage patterns, page performance, and game load times in aggregate, anonymized form;
• Security cookies — used to detect and prevent fraudulent login attempts and bot activity.

filgame does not place third-party advertising or behavioral tracking cookies. You may configure your browser to refuse or delete cookies; however, disabling essential session cookies will prevent you from logging in to your filgame account.

8. Security Measures

filgame implements the following technical and organizational security measures to protect your personal data:

• 256-bit SSL/TLS encryption for all data transmissions between your device and filgame's servers;
• Password hashing using industry-standard one-way hashing algorithms — filgame never stores passwords in plain text;
• Two-factor authentication (2FA) via SMS OTP available for all accounts;
• Access controls restricting personal data access to authorized filgame personnel with a documented business need;
• Regular security audits and penetration testing of Platform infrastructure;
• Automatic session logout after a defined period of inactivity.

Notwithstanding the foregoing, no method of electronic transmission or storage is 100% secure. While we take reasonable and appropriate measures to protect your data, we cannot guarantee absolute security against all possible threats.

9. Your Data Protection Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by filgame:

• Right to be informed — the right to know what personal data filgame holds about you, for what purposes, and how it is used;
• Right of access — the right to request a copy of your personal data held by filgame;
• Right to rectification — the right to have inaccurate or incomplete personal data corrected;
• Right to erasure — the right to request deletion of your personal data, subject to overriding legal retention obligations;
• Right to object — the right to object to processing of your personal data for marketing purposes, with immediate effect;
• Right to data portability — the right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to file a complaint — the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, please contact filgame at [email protected] with the subject line "Data Rights Request." We will respond within fifteen (15) business days of receipt of a complete, verifiable request.

10. Children's Privacy

filgame services are strictly restricted to individuals aged 21 years or older. We do not knowingly collect personal information from persons under 21 years of age. If filgame discovers that an account has been registered by a person under 21, the account will be immediately suspended, all data will be deleted (subject to any mandatory legal retention obligations), and any deposits or winnings will be returned in accordance with applicable regulatory requirements.

If you believe a person under the age of 21 has registered on the Platform, please notify us immediately at [email protected] so that we can take appropriate action.

11. Cross-Border Data Transfers

Certain service providers engaged by filgame — including cloud infrastructure providers and game studios — may be located outside the Philippines. Where personal data is transferred to recipients outside the Philippines, filgame ensures that such transfers are subject to appropriate safeguards in accordance with the Data Privacy Act of 2012 and NPC regulations, including the use of contractual clauses that provide data protection standards equivalent to those applicable in the Philippines.

12. Amendments to This Policy

filgame reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or Platform services. Where amendments are material, we will notify registered players via their registered email address or through an in-platform notification prior to the amendment taking effect. The "Last updated" date at the top of this Policy reflects the date of the most recent revision. Continued use of the Platform following the effective date of an amendment constitutes acceptance of the revised Policy.

13. Contact Information and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or filgame's data practices, please contact us. All data rights requests, privacy complaints, and inquiries should be submitted in writing with your registered account details and a clear description of your request.

Contact: [email protected]

filgame will acknowledge data-related inquiries within two (2) business days and endeavor to provide a substantive response within fifteen (15) business days. For unresolved complaints, you may also lodge a complaint with the National Privacy Commission of the Philippines at www.privacy.gov.ph (for reference only — this is an external government resource and not a clickable link on this page).