filslot Privacy Policy

Definitions

The following terms are used throughout this Privacy Policy and carry the meanings defined below:

• "filslot," "we," "us," or "our" refers to the operator of the filslot.club platform and all associated digital services.
• "Data Subject," "User," "Player," or "you" refers to any identified or identifiable natural person whose personal data is processed by filslot — in particular, registered Account holders and visitors to filslot.club.
• "Personal Data" means any information from which a living individual can be identified or identifiable, directly or indirectly, including data that makes an individual distinct from others, as defined under Section 3(g) of Republic Act No. 10173 (the Data Privacy Act of 2012, or DPA).
• "Sensitive Personal Information" refers to personal data about an individual's race, ethnicity, health, education, genetic or sexual life, or legal proceedings, as defined under Section 3(l) of the DPA. filslot processes limited categories of sensitive personal information for KYC identity verification.
• "Processing" means any operation performed on personal data, including collection, recording, storage, use, modification, disclosure, transfer, or erasure.
• "Data Controller" means filslot, which determines the purposes and means of processing your personal data.
• "Data Processor" means a third party that processes personal data on behalf of and under the instruction of filslot, pursuant to a data processing agreement.
• "NPC" refers to the National Privacy Commission, the Philippine government agency responsible for administering and implementing the DPA.
• "PAGCOR" refers to the Philippine Amusement and Gaming Corporation, filslot's primary gaming regulatory authority.
• "KYC" refers to the Know Your Customer identity verification process required of all filslot Account holders prior to their first withdrawal.

Data Controller Identity

filslot acts as the Data Controller for all personal data collected through the filslot.club platform and its associated digital services. As Data Controller, filslot determines the purposes for which personal data is processed and the means by which that processing is carried out.

filslot operates its data processing activities in accordance with the requirements of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations issued by the National Privacy Commission. filslot's gaming operations are additionally subject to data handling requirements imposed by PAGCOR as a condition of its licensing.

Categories of Personal Data We Collect

filslot collects personal data across several categories, depending on the nature of your interaction with the platform. The table below summarises the main categories of personal data filslot processes:

filslot does not intentionally collect any Special Categories of Personal Data beyond what is strictly required for identity verification (which may include a photograph on a government-issued ID). filslot does not collect biometric templates, political opinions, religious beliefs, or health data beyond what is necessary to administer self-exclusion and responsible gaming obligations.

How We Collect Your Personal Data

filslot collects personal data through the following channels and mechanisms:

4.1 Direct Collection

The majority of personal data filslot holds is provided directly by you through your interactions with the platform:

• Completing the account registration form on the filslot Login page;
• Submitting KYC verification documents in response to filslot's identity verification request;
• Initiating deposit or withdrawal transactions through linked payment methods;
• Contacting filslot's customer support team via live chat or email;
• Setting responsible gaming limits or submitting a self-exclusion request;
• Updating your Account profile, preferences, or notification settings.

4.2 Automated Collection

When you access and use the filslot platform, certain data is collected automatically by our systems:

• Technical data including your IP address, device type, operating system, and browser version is logged each time you access filslot.club;
• Game session data — including game round IDs, wager amounts, timestamps, and outcomes — is recorded automatically for every game round played while logged into your Account;
• Cookies and similar tracking technologies may be used to maintain your logged-in session state, record preferences, and support platform analytics as described in Section 8 of this Policy.

4.3 Third-Party Sources

In limited circumstances, filslot may receive personal data from third parties for purposes directly related to your Account:

• Payment providers (including GCash, Maya, and partner banks) may transmit transaction confirmation data to filslot upon processing of deposits or withdrawals;
• Identity verification service providers may return verification outcomes and document authentication results as part of the KYC process;
• PAGCOR and other regulatory authorities may share compliance-relevant information in connection with licensing obligations.

Purposes of Processing Your Personal Data

filslot processes your personal data for the following defined purposes only. We do not process your data for purposes incompatible with those disclosed below without first obtaining your explicit consent:

Legal Bases for Processing

Under the Philippine Data Privacy Act, filslot relies on the following legal bases to process your personal data:

6.1 Contractual Necessity

The processing of your identity data, contact data, financial data, and transaction data is necessary for the performance of the contract between you and filslot — specifically, the Terms and Conditions you accept upon registration. Without this processing, filslot cannot create your Account, process payments, or deliver game services.

6.2 Legal Obligation

filslot is required by Philippine law — including the Data Privacy Act, the Anti-Money Laundering Act (Republic Act No. 9160 as amended), and PAGCOR's licensing conditions — to collect, retain, and in certain circumstances disclose personal data. This legal obligation basis applies to KYC verification, AML monitoring, and regulatory reporting obligations.

6.3 Legitimate Interests

filslot processes certain categories of data — particularly technical data, gaming activity data, and communication data — on the basis of its legitimate interests in operating a secure, fair, and compliant online casino platform. This includes fraud prevention, platform security monitoring, and responsible gaming program administration. filslot has assessed that these legitimate interests do not override your rights and freedoms under the DPA.

6.4 Consent

Where filslot processes your personal data for direct marketing purposes, this processing is based on your freely given, specific, informed, and unambiguous consent obtained at the point of registration or through subsequent preference settings. You may withdraw your consent to marketing communications at any time through your Account Settings or by contacting filslot support — withdrawal of consent will not affect any processing that occurred prior to withdrawal.

Sharing Your Personal Data with Third Parties

filslot does not sell your personal data. We share your personal data with third parties only in the following defined circumstances, and only to the extent strictly necessary for each purpose:

7.1 Payment Service Providers

When you initiate a deposit or withdrawal on filslot, transaction data is shared with the relevant payment provider (GCash, Maya, QR Ph, BPI, BDO, or Metrobank) to process the transaction. The data shared is limited to what the payment provider requires to complete the specific transaction. Each payment provider is an independent data controller for their portion of the transaction and operates under their own privacy policies.

7.2 Game Providers

When you launch a game on filslot, a session token and account reference are passed to the game provider (such as Evolution Gaming, PG Soft, JILI, or Pragmatic Play) to authenticate your session. Game providers process this data as Data Processors under contractual terms that restrict their use of your data to game session delivery only. Game providers do not receive your full name, contact details, or payment information.

7.3 Identity Verification Partners

To complete KYC verification, filslot works with certified identity verification service providers who process your submitted identity documents and return a verification outcome. These providers act as Data Processors under binding data processing agreements and are prohibited from using your identity data for any purpose other than verification.

7.4 Regulatory and Law Enforcement Authorities

filslot may be legally required to share personal data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other Philippine government bodies in compliance with our regulatory obligations, court orders, or lawful requests. Such disclosures will be made only to the extent required by the applicable legal obligation.

7.5 Platform Service Providers

filslot uses trusted third-party service providers to support platform operations — including cloud hosting, content delivery, customer support tooling, and analytics. These providers act as Data Processors under binding agreements that limit their processing to the specific services they deliver to filslot and prohibit independent use of your data. All service providers processing personal data on behalf of filslot are subject to data processing agreements compliant with NPC requirements.

Cookies and Similar Tracking Technologies

filslot uses cookies and similar browser-based technologies on the filslot.club website. This section explains how and why we use these technologies.

8.1 What Are Cookies

Cookies are small text files placed on your device when you visit filslot.club. They allow the platform to recognise your device across page visits and sessions, store your preferences, and maintain your logged-in state.

8.2 Types of Cookies Used

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication tokens that keep you logged in during a visit to filslot. These cookies cannot be disabled as they are essential to the service.
• Functional Cookies: Store your preferences — such as game lobby view settings, preferred language, and notification preferences — to personalise your experience across sessions.
• Analytics Cookies: Collect aggregated, anonymised data about how players use filslot.club — which pages are visited, how long sessions last, and which game categories are most used. This data helps us improve the platform. These cookies do not identify individual players.
• Security Cookies: Used to detect and prevent fraudulent session behaviour, including detection of automated bots and simultaneous session anomalies.

Data Retention Periods

filslot retains your personal data for only as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where data must be retained for legal reasons beyond its primary use period, it is segregated from active processing systems and access is restricted to compliance personnel only.

Data Security Measures

filslot implements a comprehensive set of technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

10.1 Technical Safeguards

• Transport Encryption: All data transmitted between your device and filslot's servers is encrypted using TLS 1.3 protocol. Connections on outdated TLS versions (TLS 1.0 and 1.1) are refused;
• Data-at-Rest Encryption: Databases containing personal data, including KYC documents and financial records, are encrypted at rest using AES-256 encryption;
• Access Controls: Staff access to personal data is governed by role-based access control (RBAC) principles. Employees can only access the minimum data necessary for their specific job function;
• Multi-Factor Authentication: Administrative access to systems containing personal data requires multi-factor authentication;
• Audit Logging: All access to and modifications of personal data within filslot's systems are logged with timestamps and staff identifiers for accountability purposes;
• Penetration Testing: filslot's platform infrastructure undergoes regular independent security testing and vulnerability assessments.

10.2 Organisational Safeguards

• Staff who handle personal data receive mandatory data privacy training on joining filslot and annually thereafter;
• Third-party service providers are assessed for data security compliance before engagement and are contractually bound to maintain appropriate security standards;
• filslot maintains an incident response plan that defines procedures for detecting, containing, and reporting data security incidents.

Your Rights as a Data Subject Under the DPA

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by filslot. These rights are not absolute — they are subject to exceptions where filslot's legal obligations or overriding legitimate interests apply — but filslot is committed to honouring your rights wherever lawfully possible.

To exercise any of the rights listed above, please contact filslot's Data Protection Officer using the contact details in Section 16. filslot will acknowledge your request within 72 hours and provide a substantive response within 30 days, or such shorter period as required by NPC regulations. Where a request is complex or voluminous, the response period may be extended by a further 30 days, with notification provided within the initial 30-day window.

Children and Minors

If filslot becomes aware that personal data of a person under the age of 21 has been collected in connection with a filslot Account, the following actions will be taken immediately:

• The Account will be suspended pending investigation;
• All personal data associated with the Account will be reviewed and permanently deleted where no legal retention obligation applies;
• Any funds deposited will be refunded to the originating payment method following identity verification of the account holder;
• The matter will be reported to PAGCOR in accordance with our licensing obligations.

If you are a parent or guardian who believes that a minor has created a filslot Account or provided personal data through our platform, please contact filslot's support team immediately via live chat or the email address provided in Section 16.

International Data Transfers

In the course of providing its services, filslot may transfer your personal data to service providers or game providers whose servers or operations are located outside of the Philippines. Such transfers may occur in connection with cloud hosting, game delivery infrastructure, or international payment processing.

Where personal data is transferred outside the Philippines, filslot ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections afforded under the Data Privacy Act. These safeguards may include:

• Binding contractual clauses in data processing agreements that impose DPA-equivalent data protection obligations on overseas recipients;
• Transfers to countries or organisations that the NPC has determined provide an adequate level of protection for personal data;
• In circumstances where neither adequacy nor contractual safeguards apply, transfers based on your explicit consent or on a legal obligation affecting filslot.

Players who wish to obtain further information about the specific safeguards applicable to international data transfers affecting their personal data may contact the filslot Data Protection Officer at the address in Section 16.

Data Breach Notification

Despite filslot's implementation of comprehensive security measures, no digital platform can guarantee absolute immunity from data security incidents. In the event of a personal data breach that is likely to result in a real risk of serious harm to affected data subjects, filslot will comply with the following obligations:

• NPC Notification: filslot will notify the National Privacy Commission of a qualifying breach within 72 hours of becoming aware of the incident, in accordance with the NPC's Personal Data Breach Management Circular;
• Player Notification: Where a breach is likely to result in high risk to the rights and freedoms of individual data subjects, filslot will notify affected players as soon as practicable using their registered contact details. The notification will include: a description of the nature of the breach; the categories and approximate number of records affected; the likely consequences of the breach; and the measures filslot has taken or proposes to take in response;
• Internal Response: filslot's incident response plan will be activated upon detection of a breach, including containment, forensic investigation, remediation, and post-incident review.

Changes to This Privacy Policy

filslot reserves the right to update or revise this Privacy Policy at any time to reflect changes in our processing activities, applicable Philippine law, NPC guidance, or PAGCOR requirements. The following process governs amendments to this Policy:

• The revised Privacy Policy will be published on this page with an updated "Last Updated" date at the top of the document;
• Where changes are material — such as those involving new categories of data collected, new third-party recipients, or changes to your rights — filslot will notify registered Account holders via their registered email address or an in-platform notification before the changes take effect;
• Minor amendments — including clarifications, typographical corrections, or updates to reflect changes in NPC terminology — may be made without advance notice;
• Continued use of the filslot platform following publication of an updated Privacy Policy constitutes acknowledgement of the changes. Where the changes require your consent (for example, consent to a new processing purpose), filslot will seek that consent separately before commencing the new processing.

We encourage all filslot Account holders to review this Privacy Policy periodically. The current version is always available at filslot.club/privacy-policy.

Contact Us and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by filslot, you may contact us through the following channels. The same channels are used for exercising your data subject rights under Section 11.

filslot will acknowledge all DPA-related requests within 72 hours of receipt and will provide a substantive response within 30 days. If your query relates to a potential personal data breach or unauthorised account access, please use live chat for the fastest possible response — our security team is available around the clock on Philippine Standard Time.

If you are not satisfied with filslot's response to your data subject request or privacy concern, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines. The NPC is the supervisory authority for data protection matters in the Philippines.