filbelt Privacy Policy

filbelt is committed to protecting the privacy and personal data of every player, visitor, and user who interacts with our platform. This Privacy Policy has been drafted in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission (NPC) of the Philippines.

This Policy applies to:

• All registered Account holders of the filbelt platform.
• Visitors to the filbelt website who have not yet registered an Account.
• Individuals who contact filbelt through any support or communication channel.
• Any individual whose personal data is otherwise processed by filbelt in connection with the provision of our services.

This Policy covers personal data collected through the filbelt website, mobile-optimised platform, live chat support system, email communications, and any other channel through which you interact with filbelt. It does not cover third-party websites or services that may be linked to or from the filbelt platform — those are governed by their own privacy notices.

For the purposes of RA 10173 and this Privacy Policy, filbelt acts as the Personal Information Controller (PIC) in respect of all personal data collected and processed through the filbelt platform.

Our designated Data Protection Officer (DPO) is responsible for overseeing filbelt's compliance with data privacy obligations and for handling data subject requests and inquiries. You may contact our DPO through the following channel:

• Email: [email protected] (plain text — not a clickable link)
• Subject line: "Data Privacy Request – [Your Account Username]"
• Response commitment: Acknowledgement within 48 hours; substantive response within 15 business days as required under RA 10173.

filbelt is registered with and operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). Data collected and processed by filbelt may also be subject to PAGCOR's reporting and record-keeping requirements.

filbelt collects the following categories of personal data in connection with the provision of our services:

filbelt collects personal data through the following means:

• Direct Submission: When you register an Account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in a promotion, you directly provide us with personal data.
• Automated Collection: When you access or use the filbelt platform, we automatically collect certain technical data through cookies, log files, and similar tracking technologies. See Section 8 for full details on our cookie practices.
• Third-Party Sources: filbelt may receive data about you from third-party identity verification services (such as KYC providers), payment processors (such as GCash and PayMaya), fraud prevention databases, and credit reference agencies, where lawfully permitted and necessary for compliance purposes.
• Publicly Available Sources: In limited circumstances, filbelt may supplement its records with information available from public registers or publicly accessible sources where this is necessary for AML or fraud prevention purposes.

filbelt will always make clear at the point of collection which data fields are mandatory and which are optional. Providing optional data is entirely at your discretion, though it may affect your ability to access certain features of the platform.

filbelt processes your personal data only when a valid legal basis exists under RA 10173. The primary legal bases on which filbelt relies are:

• Contract Performance: Processing is necessary to perform our contractual obligations to you — including Account management, game delivery, payment processing, and customer support — under the filbelt Terms and Conditions you agreed to at registration.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) obligations, and the mandatory KYC and age verification requirements under Republic Act No. 9160 (as amended).
• Legitimate Interests: Processing is necessary for filbelt's legitimate interests, provided those interests are not overridden by your rights — including fraud detection, platform security, responsible gaming monitoring, and business analytics.
• Consent: Where processing is based on your consent — for example, for direct marketing communications or the use of non-essential cookies — you have the right to withdraw that consent at any time without affecting the lawfulness of processing that occurred prior to withdrawal.

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

• Account Registration & Management: Creating and maintaining your filbelt Account, verifying your identity and age (21+ requirement), and managing your Account settings and preferences.
• Game Delivery: Providing access to our full range of games — including slots, Playtech Live tables, bingo, lottery, and other products — and ensuring a personalised and seamless gaming experience.
• Payment Processing: Facilitating deposits via GCash, PayMaya, BPI, BDO, Metrobank, InstaPay, and PESONet, and processing withdrawal requests to your verified payment method.
• KYC & Regulatory Compliance: Verifying your identity and source of funds as required by PAGCOR, AMLA, and other applicable Philippine regulatory frameworks.
• Fraud Detection & Platform Security: Monitoring Account activity for signs of fraud, money laundering, prohibited conduct, or other security threats, and taking appropriate enforcement action where necessary.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behaviour, providing responsible gaming tools, and complying with PAGCOR's responsible gaming requirements.
• Customer Support: Responding to your queries, resolving disputes, and improving the quality of our support services through quality assurance reviews.
• Marketing & Promotions: Sending you information about filbelt bonuses, promotions, and new games — but only where you have given your consent and not opted out.
• Analytics & Platform Improvement: Analysing aggregated usage data to understand how our platform is used, identify performance issues, and make improvements to the user experience.

filbelt will not use your personal data for any purpose that is incompatible with the purposes set out in this Policy without first obtaining your consent or establishing a separate lawful basis for doing so.

filbelt does not sell, rent, or trade your personal data to third parties for their own independent commercial purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis and under appropriate data processing safeguards:

• Game Providers: Third-party game studios and platforms (such as Playtech and other licensed providers) receive the minimum data necessary to deliver games within the filbelt platform and to support fair play verification.
• Payment Processors: GCash, PayMaya/Maya, BPI, BDO, Metrobank, and other payment service providers receive transaction data necessary to process your deposits and withdrawals.
• KYC & Identity Verification Providers: Specialist third-party services may process your identity documents and biometric data on filbelt's behalf to complete age and identity verification.
• Fraud Prevention & AML Services: filbelt shares data with fraud detection and AML compliance services to identify and prevent financial crime.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies as required by law or upon a valid legal request.
• Legal & Professional Advisers: Lawyers, auditors, and other professional advisers engaged by filbelt, subject to professional confidentiality obligations.
• Business Successors: In the event of a merger, acquisition, or sale of all or part of filbelt's business, your data may be transferred to the successor entity, subject to equivalent privacy protections.

All third-party service providers who process personal data on filbelt's behalf are required to enter into appropriate data processing agreements and are prohibited from using your data for any purpose other than the contracted service.

filbelt uses cookies and similar tracking technologies (such as web beacons, pixel tags, and local storage) on its platform to provide a functional, secure, and personalised experience. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies, security tokens, and cookies that remember your login state. These cannot be disabled without affecting core platform functionality.
• Performance & Analytics Cookies: Collect anonymised information about how visitors use the filbelt platform — such as pages visited, time on page, and error occurrences — to help us improve platform performance. These are only deployed with your consent.
• Functional Cookies: Remember your preferences (such as language settings and responsible gaming limits) to provide a more personalised experience. These are only deployed with your consent.
• Marketing & Targeting Cookies: Track your engagement with filbelt promotions and content to deliver relevant offers. These are only deployed where you have explicitly consented.

You may manage your cookie preferences at any time through your browser settings or through the filbelt cookie preference centre accessible via the platform. Please note that disabling strictly necessary cookies will impair your ability to use the filbelt platform.

filbelt does not use cookies to collect personal data from third-party websites or to track your activity outside the filbelt platform.

filbelt takes the security of your personal data seriously and has implemented a comprehensive set of technical and organisational measures to protect your information against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption: All data transmitted between your device and the filbelt platform is encrypted using TLS (Transport Layer Security). Sensitive data at rest — including financial information and KYC documents — is stored using AES-256 encryption.
• Access Controls: Access to personal data within filbelt's systems is restricted on a strict need-to-know basis, with role-based access controls and multi-factor authentication required for all staff with access to production data.
• Network Security: filbelt's infrastructure is protected by enterprise-grade firewalls, intrusion detection systems, and DDoS mitigation controls.
• Regular Security Testing: filbelt conducts regular penetration testing, vulnerability assessments, and security audits of its platform and data infrastructure.
• Staff Training: All filbelt employees who handle personal data receive mandatory data privacy and security training as part of their onboarding and on an annual basis thereafter.
• Incident Response: filbelt maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights, filbelt will notify the NPC and affected data subjects within the timeframes required by RA 10173.

While filbelt takes all reasonable measures to protect your data, no online platform can guarantee absolute security. You play an important role in protecting your own data by maintaining the security of your Account credentials and reporting any suspected unauthorised access to our support team promptly.

filbelt retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve any disputes that may arise. The following retention principles apply:

• Active Account Data: Personal data associated with an active filbelt Account is retained for the duration of the Account's existence and for a period thereafter as required by applicable law.
• KYC & Identity Documents: Retained for a minimum of five (5) years from the date of collection, or longer if required by PAGCOR regulations or AMLA obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with AML record-keeping requirements under RA 9160 (as amended).
• Gaming Activity Records: Retained for a minimum of three (3) years from the date of the activity, and for longer periods where required for regulatory reporting or dispute resolution.
• Support Communications: Retained for up to two (2) years from the date of the communication, for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained for the duration of your Account and for one (1) year following Account closure, as evidence of consent compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or permanently anonymised so that it can no longer be associated with you as an individual. filbelt does not retain personal data in identifiable form beyond what is legally required or operationally necessary.

As a data subject under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by filbelt. You may exercise any of these rights by contacting our Data Protection Officer at [email protected].

filbelt will respond to all data subject requests within fifteen (15) business days of receipt, as required under RA 10173. Where a request is complex or involves a large volume of data, we may extend this period by a further thirty (30) days, with prior notice to you.

filbelt is strictly an adults-only platform. In accordance with Philippine law and PAGCOR regulations, participation in online gaming on the filbelt platform is restricted to individuals who are 21 years of age or older. filbelt does not knowingly collect, process, or retain personal data from individuals under the age of 21.

As part of our registration process, all prospective members are required to confirm that they meet the minimum age requirement and to submit valid government-issued identification for KYC verification. filbelt reserves the right to suspend or permanently close any Account where the Account holder is found to be under 21 years of age, and to forfeit any associated balances in accordance with our Terms and Conditions.

If you believe that filbelt has inadvertently collected personal data from a person under 21 years of age, please notify our Data Protection Officer immediately at [email protected]. We will take prompt action to verify the claim and, where confirmed, to delete the relevant data without undue delay.

In the course of providing our services, filbelt may need to transfer your personal data to recipients located outside of the Philippines — for example, to third-party game providers, technology infrastructure partners, or KYC service providers whose operations are based in other jurisdictions.

Where personal data is transferred outside the Philippines, filbelt ensures that appropriate safeguards are in place to protect your data in accordance with the standards required under RA 10173. These safeguards may include:

• Contractual data processing agreements incorporating the NPC's standard contractual clauses or equivalent protections.
• Transfers to jurisdictions that the NPC has determined provide an adequate level of data protection.
• Other appropriate technical and organisational measures to ensure the security of data in transit and at rest.

filbelt will not transfer your personal data to a foreign jurisdiction unless adequate safeguards are in place and the transfer is necessary for the purposes described in this Privacy Policy. You may request further information about cross-border data transfers by contacting our Data Protection Officer.

filbelt reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, regulatory requirements, or business operations. The effective date at the top of this Policy will be updated whenever a material change is made.

Where changes are material — meaning they significantly affect your rights or how your personal data is used — filbelt will notify registered Account holders by email to the address on file, by a notice prominently displayed on the filbelt platform, or by both methods. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your data.

Your continued use of the filbelt platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with any amendments to this Policy, you should cease using the filbelt platform and may request Account closure by contacting our support team.

filbelt is committed to handling all privacy-related queries, requests, and complaints promptly and transparently. If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or wish to raise a concern about how filbelt has handled your personal data, please contact our Data Protection Officer using the details below:

• Email: [email protected]
• Subject Line: "Privacy Policy Query" or "Data Subject Request – [Your Username]"
• Languages Accepted: English and Filipino
• Response Time: Acknowledgement within 48 hours; full response within 15 business days

If you are not satisfied with filbelt's handling of your privacy complaint, you have the right to escalate your complaint to the National Privacy Commission of the Philippines, which is the competent supervisory authority for data protection matters in the Philippines.

filbelt values the trust you place in us when you share your personal data, and we remain committed to protecting that data with the highest standards of care and transparency. Thank you for taking the time to read this Privacy Policy.