fellbet Privacy Policy

1 Introduction

fellbet is committed to protecting the privacy and personal data of every player who uses our platform. We understand that trust is the foundation of any lasting relationship, and that trust includes being transparent about how we handle your personal information — clearly, honestly, and in plain language wherever possible.

This Privacy Policy sets out the types of personal data we collect when you register and use the fellbet platform, the purposes for which that data is processed, the parties with whom it may be shared, the measures we take to keep it secure, and the rights available to you under Philippine law, particularly the Data Privacy Act of 2012 (RA 10173), also known as the DPA.

We process your personal data only as necessary to provide you with a secure, compliant, and enjoyable gaming experience — and never beyond what is strictly required for those purposes. fellbet does not sell your personal data to third parties for their own marketing purposes. Full stop.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, fellbet is the Personal Information Controller (PIC) in respect of personal data collected through the fellbet.org platform and associated services.

As the Personal Information Controller, fellbet determines the purposes for which, and the means by which, personal data is processed. We are registered with and regulated by PAGCOR, and our data processing activities are conducted in compliance with both PAGCOR requirements and the directives of the National Privacy Commission (NPC) of the Philippines.

3 What Personal Data We Collect

fellbet collects personal data in several categories depending on the stage of your interaction with the platform. Below is a comprehensive breakdown of the categories of personal data we process:

• Full legal name as appearing on your government-issued identification document.
• Date of birth (for mandatory age verification — you must be 21 years or older to use the platform).
• Philippine mobile number and/or email address used for account creation and OTP verification.
• Chosen username and account credentials (passwords are stored in encrypted, hashed form only — we never store passwords in plain text).
• Gender and nationality, collected during KYC verification.

• Copies or images of government-issued identification documents (e.g., Philippine passport, driver's license, PhilSys National ID, Voter's ID, SSS/GSIS ID, or PRC license).
• Proof of residential address (e.g., utility bill, bank statement) where required for enhanced due diligence.
• Selfie images or video verification data where biometric verification is requested.
• Source of funds documentation where required by anti-money laundering compliance procedures.

• GCash account identifiers, PayMaya account details, or bank account information linked to your fellbet account for deposit and withdrawal processing.
• Transaction history: deposits, withdrawals, bet placements, game results, bonus credits, and wallet adjustments.
• Payment card details (truncated — we do not store full card numbers; only the last four digits and expiry month/year are retained for reference).

• IP address, device type, browser type and version, and operating system of the device used to access the platform.
• Login timestamps, session durations, and geographical location data derived from IP address.
• Game activity logs: games played, stakes placed, outcomes, and session frequency data.
• Cookie identifiers and similar tracking technologies as described in Section 10 of this policy.

4 How We Collect Your Data

fellbet collects personal data through the following means:

• Direct collection: Data you voluntarily provide during account registration, KYC verification, deposit/withdrawal requests, support interactions, and promotional opt-ins.
• Automated collection: Technical data collected automatically through the use of cookies, server logs, and similar technologies when you access the fellbet platform.
• Third-party sources: Data received from payment processors (GCash, PayMaya, banks) to confirm transaction status; identity verification service providers during KYC; and fraud detection services used to protect account integrity.
• Regulatory sources: Data shared with fellbet by PAGCOR or law enforcement agencies pursuant to a lawful order or regulatory obligation.

5 How We Use Your Personal Data

The following table summarizes the primary purposes for which fellbet processes your personal data:

6 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, all processing of personal data must be grounded in a lawful basis. fellbet's processing activities rely on one or more of the following legal bases:

• Contractual necessity: Processing required to fulfil our agreement with you as a registered player — including account creation, payment processing, game provision, and customer support.
• Legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable Philippine laws.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and abuse detection — provided these interests are not overridden by your rights and interests.
• Consent: Processing for optional purposes such as marketing communications, where your explicit consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Third Parties

fellbet does not sell, rent, or trade your personal data to unaffiliated third parties for their own commercial purposes. However, we do share personal data with certain categories of recipients where necessary to operate the platform and fulfil our legal obligations:

• PAGCOR and regulatory authorities: We are legally required to report certain player data and transaction records to PAGCOR and other Philippine government bodies as part of our licensing obligations.
• Anti-Money Laundering Council (AMLC): Suspicious transactions and required reports are filed with the AMLC in compliance with the Anti-Money Laundering Act.
• Law enforcement: Where required by a lawful court order, subpoena, or legal process, fellbet will disclose personal data to appropriate authorities.

• Payment processors: GCash, PayMaya, and banking partners receive the minimum data necessary to process deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers process identity documents and biometric data on fellbet's behalf under strict data processing agreements.
• Game providers: Game software providers (e.g., JILI, Evolution, PG Soft) may receive anonymized player session data necessary for game operation. They do not receive personally identifiable information beyond what is technically required.
• Cloud infrastructure providers: Platform data is hosted on secured cloud infrastructure under contractual data protection obligations.
• Fraud detection services: Third-party fraud and risk management services process technical identifiers (IP, device fingerprint) on fellbet's behalf to protect platform integrity.

All third-party service providers engaged by fellbet are bound by contractual data processing agreements that restrict their use of your data to the specific purposes for which it was shared. They are not permitted to use your data for their own purposes.

8 Data Retention

fellbet retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The general retention principles are as follows:

• Active account data: Retained for the full duration of your active account and for a minimum of five (5) years following account closure, as required for AML compliance and regulatory audit purposes under Philippine law.
• KYC documents: Retained for a minimum of five (5) years after the end of the business relationship, in compliance with the Anti-Money Laundering Act of the Philippines.
• Financial transaction records: Retained for a minimum of ten (10) years as required by relevant Philippine financial record-keeping regulations.
• Customer support communications: Retained for two (2) years from the date of the last communication, unless the matter relates to an ongoing dispute or legal proceeding.
• Technical and log data: Access and server logs retained for twelve (12) months for security investigation purposes, then deleted or anonymized.
• Marketing consent records: Retained for the period of the marketing relationship plus three (3) years, to demonstrate lawful consent.

At the end of each applicable retention period, personal data is securely deleted or irreversibly anonymized in accordance with data destruction standards.

9 Data Security

Protecting your personal data against unauthorized access, loss, alteration, or disclosure is a technical and operational priority at fellbet. We implement a comprehensive set of security measures commensurate with the sensitivity of the data we hold:

• 256-bit SSL/TLS encryption: All data transmitted between your device and the fellbet platform is encrypted using industry-standard 256-bit SSL/TLS protocols — the same standard used by Philippine banks including BPI and BDO.
• Password hashing: Account passwords are stored exclusively as irreversible cryptographic hashes using strong hashing algorithms. fellbet staff cannot see your password in any readable form.
• Two-factor authentication (2FA): Players are encouraged and supported in enabling 2FA on their accounts. Certain account actions may require 2FA regardless of user preference.
• Access controls: Access to personal data within fellbet's internal systems is restricted to staff with a documented need-to-know for legitimate operational purposes. All access is logged and audited.
• Data minimization: fellbet collects only the personal data strictly necessary for the stated purposes. We do not collect or retain excessive data.
• Incident response: In the event of a personal data breach that is likely to prejudice your rights and interests, fellbet will notify the National Privacy Commission (NPC) and affected players within the timeframes required by the DPA and its implementing rules.

10 Cookies & Tracking Technologies

fellbet uses cookies and similar tracking technologies to improve platform performance, maintain your login session, prevent fraud, and analyze platform usage. The categories of cookies we use are as follows:

• Strictly necessary cookies: Required for the platform to function. These include session cookies that maintain your logged-in state while navigating the site. They cannot be disabled without causing the platform to malfunction.
• Security cookies: Used to detect fraudulent activity, protect against CSRF attacks, and verify the authenticity of requests made to the platform.
• Performance cookies: Collect anonymized, aggregated data about how players use the platform (page views, error rates, load times) to help us improve platform performance. Individual users are not identified.
• Preference cookies: Store your platform preferences such as language and display settings between visits.

11 Your Rights Under the Data Privacy Act (RA 10173)

As a data subject under Philippine law, you have the following rights with respect to your personal data held by fellbet. To exercise any of these rights, please contact us at [email protected] with the subject "Data Privacy Request" along with your full name, registered username, and a clear description of your request.

• Right to be Informed: You have the right to be informed about how your personal data is collected, processed, and used — which is the purpose of this Privacy Policy.
• Right to Access: You may request a copy of the personal data fellbet holds about you, along with information about how it is being processed.
• Right to Rectification (Correction): If your personal data held by fellbet is inaccurate or incomplete, you have the right to request correction. Account profile details can often be updated directly in your account settings.
• Right to Erasure (Right to be Forgotten): You may request the deletion of your personal data where there is no longer a lawful basis for its retention. Note that data subject to legal hold periods (e.g., AML records) cannot be deleted until the mandatory retention period has elapsed.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests. Objections to marketing can be actioned immediately by contacting support.
• Right to Data Portability: You have the right to receive a copy of personal data you have provided to fellbet in a structured, commonly used, machine-readable format, where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing emails), you may withdraw consent at any time without affecting the lawfulness of prior processing.

fellbet will respond to all data subject requests within thirty (30) days of receipt. 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. We will not charge a fee for reasonable requests. Manifestly unfounded or excessive requests may be declined or subject to a reasonable administrative fee.

12 Minors & Age Policy

If fellbet discovers, at any point, that personal data has been collected from an individual under the age of 21, the account will be immediately suspended and the personal data will be permanently deleted without processing any pending transactions. Proof of age misrepresentation will be reported to relevant regulatory authorities.

Parents and guardians who believe their minor child may have registered an account on the fellbet platform should contact our Data Protection Officer immediately at [email protected] for urgent account closure and data deletion.

13 Cross-Border Data Transfers

Some of fellbet's service providers and infrastructure partners operate outside the Philippines. Where personal data is transferred to servers or entities located in countries that may not provide the same level of data protection as Philippine law, fellbet ensures that adequate safeguards are in place. These safeguards include:

• Contractual data processing agreements that impose obligations on overseas recipients equivalent to those under the Philippine Data Privacy Act.
• Use of service providers who hold internationally recognized data security certifications (e.g., ISO 27001).
• Transfer only to jurisdictions recognized by the National Privacy Commission as providing adequate data protection where applicable.

We transfer only the minimum data necessary for the specific service purpose and ensure all such transfers are covered by appropriate contractual protections.

14 Third-Party Services & Links

The fellbet platform incorporates third-party software and services — including game engines from licensed providers, payment processing integrations, and fraud detection tools — that may process certain technical data as part of their service delivery.

This Privacy Policy does not apply to the privacy practices of any third-party service provider, game developer, or payment processor. Each of these parties operates under their own privacy policies. We encourage you to review the privacy policies of any third party whose services you access through or in connection with the fellbet platform.

fellbet is not responsible for the privacy practices or content of third-party websites or services, including any links that may appear on the platform. Accessing such third-party content is at your own discretion and risk.

15 Changes to This Privacy Policy

fellbet reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or the nature of the services we provide. Significant changes will be communicated to registered players via their registered mobile number or email address, or through a prominent notice on the platform prior to the changes taking effect.

The date of the most recent revision is indicated at the top of this policy ("Last Updated"). Your continued use of the fellbet platform following the posting of any revised Privacy Policy constitutes your acceptance of those changes. If you do not agree to any changes, you must cease using the platform. The version currently published on this page is the operative, binding version.

16 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact fellbet's designated Data Protection Officer (DPO). The DPO is responsible for overseeing compliance with data privacy obligations and is your primary point of contact for all privacy-related matters.

If you believe your data privacy rights have been violated and your concern has not been adequately addressed by fellbet, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph. fellbet is committed to cooperating fully with any NPC investigation.