fillbet Privacy Policy

This Privacy Policy ("Policy") is issued by fillbet ("we," "us," "our"), the operator of the online casino and sports betting platform at fillbet.club. It applies to all personal data collected, processed, stored, and used in connection with your access to and use of the fillbet website, account, and services (collectively, the "Platform").

This Policy is designed to comply with the Republic of the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, the directives of the National Privacy Commission (NPC), and the data handling requirements imposed by PAGCOR as a condition of fillbet's operating license.

By registering a fillbet account or using any part of the Platform, you acknowledge that you have read and understood this Policy and that you consent to the collection and use of your personal data as described herein. If you do not agree with this Policy, you should not create or continue using a fillbet account.

For the purposes of the Data Privacy Act of 2012 and this Policy, fillbet is the Personal Information Controller (PIC) in respect of all personal data collected through the Platform. fillbet determines the purposes for which and the manner in which your personal data is processed.

fillbet has appointed a Data Protection Officer (DPO) as required under the Data Privacy Act. The DPO is responsible for overseeing fillbet's data protection strategy, ensuring compliance with applicable law, and serving as the primary point of contact for data subject requests and NPC inquiries. Contact details for the DPO are provided in Section 13 of this Policy.

fillbet collects the following categories of personal data in connection with your use of the Platform. Some data is provided directly by you; other data is collected automatically through your use of the service.

fillbet does not collect sensitive personal information as defined under the Data Privacy Act (such as health data, biometric data beyond identity verification, or political opinions) except where required for specific regulatory compliance purposes and with your explicit consent.

fillbet collects personal data through the following channels and methods:

• Direct submission: Data you provide during registration, KYC document uploads, account updates, payment transactions, and customer support interactions.
• Automated collection: Technical data such as IP address, device identifiers, and session data collected automatically when you access the Platform via cookies, web beacons, and server logs.
• Third-party payment processors: Transaction confirmation and account verification data received from GCash, PayMaya, BPI, BDO, and Metrobank when you make deposits or request withdrawals.
• Identity verification providers: Identity confirmation data returned by fillbet's KYC and AML screening service providers when processing your government-issued ID documents.
• Fraud prevention and security services: Risk scoring data generated by fillbet's fraud detection partners based on behavioral and technical signals during account activity.
• PAGCOR and regulatory authorities: In limited circumstances, fillbet may receive data from or be required to share data with PAGCOR and other Philippine regulatory bodies as required by law.

Under the Data Privacy Act of 2012, fillbet processes your personal data only where one or more of the following lawful bases applies:

• Contract performance: Processing is necessary to register your account, process deposits and withdrawals, deliver games, resolve disputes, and fulfil all other obligations under the fillbet Terms & Conditions.
• Legal obligation: Processing is required to comply with PAGCOR licensing conditions, Philippine AML regulations, PAGCOR's KYC requirements, and any other applicable Philippine laws.
• Legitimate interests: Processing is necessary for fillbet's legitimate business interests, including fraud prevention, platform security, responsible gaming enforcement, and improving the fillbet Platform — where these interests are not overridden by your data protection rights.
• Consent: Where you have given explicit, freely given, specific, informed, and informed consent — primarily for direct marketing communications. You may withdraw consent at any time by updating your account communication preferences.

fillbet uses your personal data for the following specific purposes:

• Account creation and management: To register your fillbet account, verify your identity and age, maintain your account profile, and process fillbet login authentication.
• KYC and regulatory compliance: To satisfy PAGCOR's mandatory Know Your Customer requirements, verify that you meet the 21+ age requirement, and comply with Philippine AML and counter-terrorism financing obligations.
• Payment processing: To process GCash deposits, PayMaya deposits, bank transfers, and withdrawal requests to your verified Philippine payment accounts.
• Game delivery and account management: To provide access to fillbet's game library, record game session history, calculate and apply bonuses, and maintain your transaction ledger in Philippine pesos.
• Customer support: To respond to your inquiries, process complaints, investigate disputes, and maintain records of support interactions for quality assurance and dispute resolution.
• Fraud prevention and security: To detect and prevent unauthorized account access, fraudulent transactions, money laundering, and other prohibited activities on the Platform.
• Responsible gaming: To monitor gaming behavior for signs of problem gambling as required by PAGCOR's responsible gaming standards, to apply self-exclusion restrictions, and to administer responsible gaming tools.
• Marketing communications: To send you promotional offers, bonus announcements, and fillbet news — only where you have opted in. You may opt out at any time.
• Platform improvement: To analyze aggregated, anonymized usage data to improve fillbet's game library, interface design, and service performance.
• Legal proceedings: To establish, exercise, or defend legal claims involving fillbet and to cooperate with lawful requests from Philippine courts and regulatory authorities.

fillbet does not sell, rent, or trade your personal data to third parties. fillbet may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• PAGCOR and Philippine regulatory authorities: fillbet is legally required to share certain player data with PAGCOR and, where applicable, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government bodies upon lawful request.
• KYC and identity verification providers: Third-party service providers that process your government-issued ID documents and perform AML screening on fillbet's behalf, under strict data processing agreements.
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and their respective processors — solely for the purpose of completing your requested deposits and withdrawals.
• Game software providers: Licensed game providers whose titles are hosted on the fillbet Platform may receive a pseudonymous player identifier and game session data for the purpose of game delivery and payout calculation.
• Fraud prevention and security services: Third-party fraud detection and cybersecurity service providers that assist fillbet in identifying and preventing unauthorized account access and financial crime.
• Legal advisors and professional service providers: Lawyers, auditors, and accountants engaged by fillbet under confidentiality obligations, where access to personal data is necessary for the relevant professional engagement.

fillbet uses cookies and similar tracking technologies to operate the Platform, maintain your login session, prevent fraud, and analyze usage patterns. The following types of cookies are used:

• Strictly necessary cookies: These are essential for the Platform to function. They maintain your fillbet login session, remember your account preferences, and prevent cross-site request forgery. These cookies cannot be disabled without preventing use of the Platform.
• Performance and analytics cookies: These collect anonymized data about how players navigate the Platform — which pages are visited most, how long sessions last, and which features are used. This data helps fillbet improve the Platform experience.
• Security and fraud prevention cookies: These identify and flag unusual access patterns that may indicate unauthorized login attempts, bot activity, or account compromise.
• Functional cookies: These remember your language preference, notification settings, and game display options across sessions.

You may control cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from using the fillbet Platform, as session management and security functions depend on them.

fillbet retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following retention periods and considerations:

• Active account data: Retained for the duration of your fillbet account registration and for a period of five (5) years following account closure, in accordance with PAGCOR's record-keeping requirements and Philippine AML regulations.
• KYC documents: Retained for a minimum of five (5) years from the date of verification or from the date of your last transaction on the Platform, whichever is later, as required by the Anti-Money Laundering Act.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, consistent with Philippine tax and AML record-keeping obligations.
• Customer support records: Retained for three (3) years from the date of the final interaction, or longer if the subject matter is related to an ongoing dispute or legal proceeding.
• Marketing consent records: Retained for the duration of your opt-in status and for one (1) year following opt-out, as evidence of consent management compliance.

Upon expiry of the applicable retention period, fillbet will securely delete or anonymize your personal data unless retention for a longer period is required by a specific legal obligation or court order.

fillbet implements a comprehensive set of technical, organizational, and physical security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and fillbet's servers — including fillbet login credentials, payment data, and KYC documents.
• Encrypted data storage for all sensitive data fields including passwords (which are hashed using industry-standard algorithms and never stored in plain text), government ID numbers, and financial account details.
• Access control and role-based permissions ensuring that fillbet personnel can only access personal data that is necessary for their specific job function.
• Regular security audits and penetration testing conducted by independent security specialists to identify and remediate vulnerabilities in the Platform's infrastructure.
• Multi-factor authentication available for all fillbet Player accounts and required for all fillbet administrative system access.
• Incident response procedures that comply with the Data Privacy Act's requirements for breach notification to the NPC and affected data subjects within the mandated timeframes.

fillbet's primary data infrastructure is based in the Philippines. In certain circumstances, personal data may be transferred to, stored, or processed by service providers located outside the Philippines — for example, cloud infrastructure providers, game software vendors, or fraud prevention services with international operations.

Any transfer of your personal data outside the Philippines is conducted only where fillbet is satisfied that an adequate level of protection applies to your data in the recipient jurisdiction, whether through:

• The NPC's recognition that the receiving country or organization affords adequate data protection;
• Contractual clauses approved by the NPC or equivalent standard contractual protections binding the recipient to treat your data consistently with the Data Privacy Act;
• Your explicit consent to the specific transfer, where consent is the appropriate mechanism.

fillbet does not transfer KYC document images or government-issued ID data outside the Philippines except where strictly required by applicable law or PAGCOR's regulatory instructions.

Under the Data Privacy Act of 2012, as a Filipino data subject, you have the following rights with respect to your personal data held by fillbet:

For all privacy-related inquiries, data subject access requests, consent withdrawal requests, or data breach notifications, please contact fillbet's Data Protection Officer using the following contact information:

When submitting a data subject request, please include your full name, registered mobile number or email address, and a clear description of the right you are exercising and the specific data or processing activity concerned. fillbet may require identity verification before processing your request to ensure the security of your personal data.

For complaints that cannot be resolved directly with fillbet, you may contact the National Privacy Commission of the Philippines, the independent regulatory authority responsible for data privacy enforcement in the Philippines.

If you are a parent or guardian and believe that a person under 21 has registered a fillbet account or provided personal data to fillbet, please contact our Data Protection Officer immediately using the details in Section 13. fillbet will act promptly to investigate and address the matter.

fillbet reviews this Privacy Policy regularly and reserves the right to update it to reflect changes in Philippine law, PAGCOR regulatory requirements, NPC guidance, or fillbet's data processing activities. When material changes are made to this Policy, fillbet will:

• Update the "Last Reviewed" date at the top of this Policy;
• Notify registered Players via email to their registered address and/or by a prominent notice on the Platform at least 14 days before the updated Policy takes effect;
• Where a change materially affects your rights or the way fillbet uses your data in a way that requires fresh consent, seek that consent from you before the change takes effect.

Your continued use of the fillbet Platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the updated terms. If you do not accept the updated Policy, you should close your fillbet account before the effective date.

Archived versions of previous fillbet Privacy Policies are available upon request from the Data Protection Officer.