filber Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how filber ("filber," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of players and visitors ("you" or "your") who access or use the filber online gaming platform at filber.app.

filber is committed to protecting your privacy and handling your personal data with transparency, integrity, and care. This Policy is designed to comply 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.

By registering a filber account, accessing the platform, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please do not use the filber platform.

02 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, filber is the personal information controller responsible for the personal data collected through the filber platform.

filber determines the purposes and means of processing your personal data. All data processing activities conducted by filber are carried out in accordance with the principles of transparency, legitimate purpose, and proportionality as required under Philippine data protection law.

Where filber engages third-party service providers to process personal data on its behalf, those providers act as personal information processors and are contractually bound to process data only in accordance with filber's instructions and applicable law.

03 Data We Collect

filber collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

3.1 Registration Data

When you create a filber account, we collect:

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Residential address (including city, province, and postal code)
• Email address
• Mobile phone number
• Username and encrypted password

3.2 Identity Verification (KYC) Data

To comply with anti-money laundering regulations and verify your identity, filber may collect:

• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilHealth ID, UMID, or driver's license)
• Proof of address documents (e.g., utility bill, bank statement)
• Selfie or facial image for identity matching purposes
• Source of funds documentation where required by applicable regulations

3.3 Financial Data

• Deposit and withdrawal transaction records
• Payment method details (e.g., GCash account reference, PayMaya reference, BPI, BDO, or Metrobank account details — stored in tokenized or reference form only)
• Transaction amounts in Philippine Peso (PHP)
• Account balance history

3.4 Gaming Activity Data

• Game session logs, including games played, wagers placed, and outcomes
• Bonus and promotion usage history
• Responsible gaming tool settings (e.g., deposit limits, self-exclusion status)

3.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps and duration
• Cookie identifiers and similar tracking data (see Section 7)

3.6 Communications Data

• Records of your communications with filber support, including live chat transcripts and email correspondence
• Feedback, complaints, and survey responses submitted to filber

04 How We Use Your Data

filber uses your personal data for the following purposes:

filber will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable Philippine law.

05 Legal Basis for Processing

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

• Consent: Where you have given your explicit, informed consent to the processing of your personal data for a specific purpose, such as receiving marketing communications from filber. You may withdraw your consent at any time by contacting filber support or updating your account preferences.
• Contract Performance: Where processing is necessary to perform the contract between you and filber — that is, to provide you with access to the filber platform and its gaming services, process your transactions, and manage your account.
• Legal Obligation: Where processing is required to comply with applicable Philippine laws and regulations, including the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and any directives issued by PAGCOR or other relevant regulatory authorities.
• Legitimate Interest: Where processing is necessary for filber's legitimate business interests, such as fraud prevention, platform security, responsible gaming monitoring, and improving the quality of our services — provided that such interests are not overridden by your rights and interests.

06 Data Sharing and Disclosure

filber does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only where necessary and in accordance with applicable law:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals. These providers receive only the data necessary to complete your transaction.
• Identity Verification Providers: Third-party KYC and identity verification service providers engaged by filber to assist with age verification and anti-money laundering compliance checks.
• Fraud Prevention Services: Specialist fraud detection and prevention providers who assist filber in identifying and preventing fraudulent activity on the platform.
• Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law, court order, or regulatory directive.
• Law Enforcement: Philippine law enforcement authorities, where disclosure is required in connection with a criminal investigation or legal proceeding.
• Technology and Infrastructure Providers: Cloud hosting, data storage, and platform technology providers who process data on filber's behalf under strict data processing agreements.
• Professional Advisors: Legal, accounting, and auditing firms engaged by filber, subject to professional confidentiality obligations.

All third-party service providers engaged by filber are contractually required to implement appropriate technical and organizational measures to protect your personal data and to process it only in accordance with filber's instructions and applicable Philippine law.

07 Cookies and Tracking Technologies

filber uses cookies and similar tracking technologies to operate the platform, enhance your experience, and analyze platform usage. By using the filber platform, you consent to the use of cookies as described in this section.

Types of Cookies Used by filber:

• Strictly Necessary Cookies: These cookies are essential for the filber platform to function. They enable core features such as account login, session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Functional Cookies: These cookies remember your preferences and settings (such as language and display preferences) to provide a more personalized experience on the filber platform.
• Analytics Cookies: These cookies collect aggregated, anonymized data about how players use the filber platform, helping us understand usage patterns and improve our services. Individual players are not identified through analytics data.
• Security Cookies: These cookies assist in fraud detection and prevention by identifying unusual patterns of behavior that may indicate unauthorized access or fraudulent activity.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the filber platform. For more information on managing cookies, refer to your browser's help documentation.

08 Data Retention

filber retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations.

The following general retention periods apply:

• Account and Registration Data: Retained for the duration of your active filber account, plus a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements under Philippine law.
• KYC and Identity Verification Data: Retained for a minimum of five (5) years from the date of verification, or longer if required by applicable regulatory obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with the Anti-Money Laundering Act (AMLA) and related regulations.
• Gaming Activity Data: Retained for a minimum of three (3) years from the date of each gaming session, for the purposes of dispute resolution, responsible gaming monitoring, and regulatory compliance.
• Communications Data: Retained for a minimum of two (2) years from the date of each communication, for the purposes of customer support quality assurance and dispute resolution.
• Marketing Data: Retained until you withdraw your consent to receive marketing communications, after which it will be deleted or anonymized within a reasonable period.

Upon expiry of the applicable retention period, filber will securely delete or anonymize your personal data in accordance with its data disposal procedures. Where data is anonymized rather than deleted, the anonymized data may be retained indefinitely for statistical and analytical purposes.

09 Data Security

filber implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction.

Our security measures include, but are not limited to:

• SSL/TLS Encryption: All data transmitted between your device and the filber platform is encrypted using industry-standard SSL/TLS protocols.
• Data Encryption at Rest: Sensitive personal data stored on filber's servers is encrypted using strong encryption algorithms.
• Access Controls: Access to personal data is restricted to authorized filber personnel and service providers on a strict need-to-know basis. All access is logged and monitored.
• Two-Factor Authentication: filber supports and encourages the use of two-factor authentication (2FA) for player accounts to provide an additional layer of security.
• Regular Security Audits: filber conducts regular security assessments and penetration testing to identify and address potential vulnerabilities in the platform.
• Incident Response: filber maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, filber will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Data Privacy Act of 2012.

10 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by filber:

To exercise any of the above rights, please contact filber's Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy. filber will respond to all data subject requests within the timeframes required by applicable Philippine law — generally within fifteen (15) business days of receiving a valid request.

Please note that certain rights are subject to limitations under applicable law. For example, filber may be required to retain certain data for regulatory compliance purposes even where you request its deletion. filber will inform you of any such limitations when responding to your request.

11 Children's Privacy

The filber platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations. filber does not knowingly collect personal data from individuals under the age of 21.

If filber discovers or has reason to believe that personal data has been collected from an individual under the age of 21, filber will immediately suspend the associated account, delete the personal data in question, and handle any funds in accordance with applicable regulations.

12 International Data Transfers

filber primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or technology partners operating in other jurisdictions.

Where personal data is transferred outside the Philippines, filber ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012 and the standards set by the National Privacy Commission. These safeguards may include:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law;
• Transfers to jurisdictions that have been assessed as providing an adequate level of data protection;
• Other legally recognized transfer mechanisms as approved by the National Privacy Commission.

filber will not transfer your personal data to jurisdictions that do not provide adequate data protection safeguards without your explicit consent or as otherwise permitted by applicable law.

13 Changes to This Privacy Policy

filber reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements.

When filber makes material changes to this Policy, we will notify you by sending an email to your registered email address and by posting a prominent notice on the filber platform prior to the changes taking effect. The updated Policy will include a revised effective date at the top of the document.

Your continued use of the filber platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Policy, you must stop using the filber platform and may request account closure by contacting filber support.

14 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or filber's handling of your personal data, please contact filber's Data Protection Officer (DPO):

• Role: Data Protection Officer (DPO), filber
• Email: [email protected]
• General Support: [email protected]
• Support Channel: Live chat, available 24/7 via the filber platform
• Response Time: filber aims to respond to all privacy-related inquiries within 15 business days
• Language: English

If you are not satisfied with filber's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.