fillbet Privacy Policy

1. Scope & Application

1.1 This Privacy Policy applies to all personal data processed by fillbet in connection with the operation of the fillbet online gaming platform at fillbet.vip (the "Platform"), including its mobile-optimised interface and all related services offered to Members.

1.2 For the purposes of this Policy, fillbet acts as the Personal Information Controller with respect to data collected through the Platform, as that term is defined under the Philippine Data Privacy Act of 2012 (RA 10173).

1.3 By registering an Account on the fillbet Platform or by continuing to use the Platform after this Policy has been published or updated, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein.

1.4 This Policy should be read together with the fillbet Terms & Conditions, which govern your overall use of the Platform. In the event of conflict between this Policy and the Terms & Conditions on matters relating to personal data, this Privacy Policy shall prevail.

2. Personal Data We Collect

fillbet collects the following categories of personal data from Members and prospective Members:

2.1 Registration & Identity Data:

• Full legal name as it appears on a valid government-issued ID
• Date of birth (required to verify the 21+ age requirement under PAGCOR-aligned responsible gaming standards)
• Nationality and country of residence
• Gender (optional, where provided)
• Registered email address and mobile number
• Username and encrypted account password

2.2 Identity Verification (KYC) Data:

• Copies of government-issued identification documents (e.g., Philippine National ID, Passport, Driver's License, SSS/UMID card, Voter's ID)
• Proof of address (e.g., utility bill, bank statement, barangay certificate)
• Selfie or live photo for facial verification, where required

2.3 Financial & Transaction Data:

• GCash number, PayMaya number, bank account details, or other payment method references registered to your fillbet Account
• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method used
• Wagering history — games played, bet amounts, win/loss records, and session durations

2.4 Technical & Device Data:

• IP address at the time of registration and each login
• Device type, operating system, and browser version
• Unique device identifiers
• Geographic location data (country and region level, derived from IP address)
• Session logs, including login timestamps and pages visited on the Platform

2.5 Communications Data:

• Records of support interactions, including emails and live chat transcripts
• Complaint and dispute records
• Survey responses and feedback, where voluntarily provided

3. How We Collect Your Data

3.1 Directly from You. The majority of personal data fillbet holds is provided directly by Members during the registration process, KYC verification, deposit or withdrawal requests, and support interactions. When you contact fillbet at [email protected], we retain records of that correspondence.

3.2 Automatically. When you access the fillbet Platform, certain technical data is collected automatically through server logs, cookies, and similar tracking technologies. This includes your IP address, device information, and session activity. See Section 5 (Cookies & Tracking Technologies) for further detail.

3.3 From Payment Processors. When you make a deposit or withdrawal via GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, or any other accepted payment method, fillbet receives transaction confirmation data from the relevant payment processor. fillbet does not store full payment credentials such as complete bank account numbers or card numbers on its own servers.

3.4 From Identity Verification Partners. Where fillbet uses third-party KYC or identity verification services to assist in verifying Member identity and age, those services may process and return verification results to fillbet. fillbet selects KYC partners that comply with applicable data protection standards.

4. Purpose & Legal Basis for Processing

fillbet processes personal data only for specific, legitimate purposes. The table below summarises the primary processing purposes and the legal basis under the Data Privacy Act of 2012:

• Account registration and authentication — Performance of contract; consent
• Age and identity verification (KYC) — Legal obligation (PAGCOR-aligned regulatory compliance); legitimate interest in fraud prevention
• Processing deposits and withdrawals — Performance of contract
• Wagering activity and game history — Performance of contract; legal obligation (transaction records for regulatory purposes)
• Anti-money laundering (AML) and fraud monitoring — Legal obligation; legitimate interest in platform integrity
• Responsible gaming monitoring and intervention — Legal obligation; protection of vital interests of the Member
• Customer support and dispute resolution — Performance of contract; legitimate interest
• Platform security and abuse prevention — Legitimate interest
• Sending promotional communications (with consent) — Consent (Members may opt out at any time)
• Compliance with legal and regulatory requests — Legal obligation

fillbet does not process personal data for purposes incompatible with those listed above without first obtaining the explicit consent of the relevant Member or as otherwise required by law.

5. Cookies & Tracking Technologies

5.1 The fillbet Platform uses cookies and similar technologies (including local storage and session tokens) to operate and improve the Platform experience. Cookies are small data files placed on your device when you access the Platform.

5.2 fillbet uses the following types of cookies:

• Strictly Necessary Cookies: Required for the Platform to function, including maintaining your logged-in session and remembering your account preferences. These cannot be disabled without breaking Platform functionality.
• Performance & Analytics Cookies: Used to understand how Members use the Platform — which game categories are most visited, how long sessions last, and where technical errors occur. This data is aggregated and anonymised.
• Functional Cookies: Used to remember preferences such as your last-visited game category or display language.

5.3 fillbet does not use third-party advertising or behavioural tracking cookies. No data collected via fillbet cookies is sold to or shared with advertising networks.

5.4 You may configure your browser to reject or delete cookies. Note that doing so may impair the functionality of the fillbet Platform, including preventing you from remaining logged in to your Account.

6. Data Sharing & Third Parties

6.1 fillbet does not sell, rent, or trade your personal data to third parties for their own marketing purposes.

6.2 Service Providers. fillbet shares personal data with third-party service providers who assist in operating the Platform, including: payment processors (GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and others); KYC and identity verification providers; cloud hosting and infrastructure providers; customer support platform providers; and fraud detection and AML monitoring services. All such providers are contractually obligated to process personal data solely on fillbet's instructions and to maintain appropriate security standards.

6.3 Game Providers. Certain game-level data (such as your player ID, session token, and bet amounts within a specific game) is shared with the game software provider to facilitate gameplay and resolve disputes. Game providers do not receive your full identity or payment information.

6.4 Regulatory Authorities. fillbet is required by applicable Philippine law and regulatory obligations to share certain data — including KYC records, transaction logs, and AML-related reports — with PAGCOR or other competent Philippine authorities upon lawful request. fillbet will comply with such obligations and, where legally permitted, will notify affected Members.

6.5 Business Transfers. In the event of a merger, acquisition, or sale of all or part of fillbet's business, Member personal data may be transferred to the acquiring entity as part of that transaction. fillbet will notify affected Members via registered email prior to any such transfer becoming effective.

7. Data Retention

7.1 fillbet retains personal data for as long as your Account remains active and for such additional periods as are necessary to comply with legal obligations, resolve disputes, and enforce agreements.

7.2 Specifically: transaction records and KYC documentation are retained for a minimum of five (5) years after the relevant transaction or Account closure, consistent with Philippine AML and financial record-keeping obligations. Support and complaint records are retained for three (3) years. Technical log data (IP addresses, session logs) is retained for up to twelve (12) months from the date of collection, unless required for an ongoing investigation or legal proceeding.

7.3 Following the expiry of the applicable retention period, personal data will be securely deleted or anonymised such that it can no longer be associated with an identifiable individual.

8. Data Security

8.1 fillbet implements appropriate technical and organisational security measures to protect personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include: TLS/SSL encryption for all data transmitted between your device and the Platform; encrypted storage of passwords using industry-standard hashing algorithms; access controls restricting personal data access to authorised personnel on a need-to-know basis; regular security assessments of Platform infrastructure; and monitoring of login activity for anomalous access patterns.

8.2 While fillbet takes these precautions seriously, no online platform can guarantee absolute security. Members are encouraged to use strong, unique passwords for their fillbet Account and to notify fillbet immediately at [email protected] if they suspect their Account has been compromised.

8.3 Data Breach Response. In the event of a personal data breach that is likely to result in harm to affected Members, fillbet will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected Members without undue delay, as required under the Data Privacy Act of 2012 and NPC Circular No. 16-03.

9. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, fillbet Members have the following rights with respect to their personal data:

• Right to be Informed: You have the right to know what personal data fillbet holds about you, how it is used, and with whom it is shared. This Privacy Policy is fillbet's primary mechanism for fulfilling this obligation.
• Right of Access: You may request a copy of the personal data fillbet holds about you. Requests should be submitted to [email protected]. fillbet will respond within 15 business days.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. For basic account details, you may update information directly from your account profile. For KYC documents, contact support.
• Right to Erasure (Right to be Forgotten): You may request deletion of your personal data where: the data is no longer necessary for the purpose for which it was collected; you withdraw consent (where consent was the basis for processing); or the data was unlawfully processed. Note that erasure requests may be declined where retention is required by law (e.g., AML record-keeping obligations).
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to other processing on grounds relating to your particular situation, subject to fillbet's legitimate interests and legal obligations.
• Right to Data Portability: Where technically feasible, you may request your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: If you believe fillbet has mishandled your personal data, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC).

To exercise any of the above rights, contact fillbet's Data Protection Officer at: [email protected] with the subject line "Data Subject Rights Request."

10. Contact & Complaints

10.1 If you have any questions, concerns, or complaints regarding this Privacy Policy or fillbet's personal data practices, please contact us at: [email protected]

10.2 fillbet will acknowledge receipt of all privacy-related complaints within five (5) business days and will provide a substantive response within fifteen (15) business days of receipt.

10.3 If you are not satisfied with fillbet's response to your complaint, you may escalate the matter to the National Privacy Commission of the Philippines.

10.4 Amendments. fillbet reserves the right to update this Privacy Policy at any time. The most current version will always be available at fillbet.vip/privacy-policy and will display the date of the most recent update. Continued use of the Platform after any update constitutes acceptance of the revised Policy.