Fellbet Privacy Policy

1. Introduction

This Privacy Policy applies to all personal data collected and processed by Fellbet in connection with your use of the Fellbet online gaming platform, accessible at fellbet.com and through the Fellbet mobile application (collectively, the "Platform").

Fellbet operates as a data controller in respect of the personal data you provide when registering an account, making deposits, placing wagers, and interacting with the Platform. As data controller, Fellbet determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data protection laws, including the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations.

By registering a Fellbet account or using the Platform, 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 to this Privacy Policy, you must not use the Fellbet Platform.

This Privacy Policy should be read together with Fellbet's Terms & Conditions and Responsible Gaming Policy, both of which are available on the Platform.

2. Personal Data We Collect

Fellbet collects personal data that is necessary to provide the Platform's services, comply with legal obligations, and maintain the security and integrity of the gaming environment. The categories of personal data we collect include:

2.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (for age verification purposes – Fellbet requires all players to be 21 years of age or older);
• Residential address, including barangay, city or municipality, and province;
• Email address;
• Mobile phone number.

2.2 Verification and KYC Data

• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's license, UMID);
• Proof of address documentation;
• Selfie or facial image submitted for identity verification purposes;
• Source of funds documentation where required by anti-money laundering regulations.

2.3 Financial and Transaction Data

• GCash account details, PayMaya account details, or bank account information (BPI, BDO, Metrobank, or other supported institutions) used for deposits and withdrawals;
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references;
• Account balance information.

2.4 Gaming Activity Data

• Wager history, including game titles, bet amounts, outcomes, and timestamps;
• Session duration and frequency of play;
• Bonus and promotion usage history;
• Responsible gaming tool settings, including deposit limits and self-exclusion status.

2.5 Technical and Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser type;
• Mobile network operator (e.g., Smart, Globe, DITO);
• Platform access logs and session identifiers;
• Cookie identifiers and similar tracking data (see Section 7).

2.6 Communications Data

• Records of communications between you and Fellbet's support team, including emails, chat transcripts, and support ticket records;
• Survey responses and feedback submitted voluntarily.

3. How We Collect Your Data

Fellbet collects personal data through the following means:

• Direct submission: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated collection: Technical and device data collected automatically when you access the Platform, including through cookies, log files, and analytics tools;
• Third-party sources: Identity verification data from KYC service providers; fraud detection signals from payment processors; and publicly available information used to verify your identity or assess risk;
• Payment providers: Transaction confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners.

4. How We Use Your Personal Data

Fellbet uses your personal data for the following purposes:

Fellbet does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have provided explicit consent.

5. Legal Basis for Processing

Fellbet processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

• Contractual necessity: Processing required to perform the contract between you and Fellbet, including account management, payment processing, and game provision;
• Legal obligation: Processing required to comply with applicable laws, including anti-money laundering regulations, age verification requirements, and PAGCOR-aligned regulatory obligations;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

Fellbet does not sell your personal data to third parties. We share your data only in the following circumstances and only to the extent necessary for the stated purpose:

• KYC and identity verification providers: Third-party services that assist Fellbet in verifying your identity and age in compliance with regulatory requirements;
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners who process your deposit and withdrawal transactions;
• Game content providers: Licensed game studios and software providers whose games are available on the Fellbet platform, to the extent necessary for game delivery and outcome recording;
• Fraud prevention and security services: Third-party providers that assist Fellbet in detecting and preventing fraudulent activity, money laundering, and platform abuse;
• Regulatory and law enforcement authorities: PAGCOR and other competent Philippine authorities where disclosure is required by law, court order, or regulatory direction;
• Professional advisers: Legal counsel, auditors, and compliance consultants bound by confidentiality obligations, where necessary for Fellbet's legal and business operations;
• Business successors: In the event of a merger, acquisition, or sale of Fellbet's business assets, your data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

All third parties with whom Fellbet shares personal data are required to handle that data in accordance with applicable data protection laws and Fellbet's data processing standards. Fellbet does not permit third-party service providers to use your personal data for their own independent purposes.

7. Cookies and Tracking Technologies

Fellbet uses cookies and similar tracking technologies to operate the Platform, improve user experience, and support security functions. A cookie is a small text file placed on your device when you access the Platform.

7.1 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting Platform functionality;
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations;
• Analytics cookies: Collect aggregated, anonymised data about how players use the Platform, helping Fellbet identify areas for improvement;
• Marketing cookies: Used to deliver relevant promotional content to you based on your gaming preferences, where you have provided consent.

7.2 Managing Cookies

You can manage your cookie preferences through the cookie settings panel available on the Platform. You may also configure your browser to block or delete cookies; however, disabling strictly necessary cookies may impair your ability to use the Platform. Note that withdrawing consent for marketing cookies does not affect the delivery of your gaming services.

8. Data Retention

Fellbet retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements;
• Transaction and gaming activity data: Retained for a minimum of five (5) years from the date of each transaction, as required by applicable financial regulations;
• KYC documentation: Retained for a minimum of five (5) years following the completion of the verification process or account closure, whichever is later;
• Communications data: Retained for a period of three (3) years from the date of the communication, unless a longer period is required for dispute resolution or legal proceedings;
• Technical and device data: Retained for up to twelve (12) months from collection, unless required for longer periods for security investigations;
• Marketing consent records: Retained for the duration of your account and for one (1) year following withdrawal of consent.

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

9. Data Security

Fellbet implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the Fellbet Platform;
• Encryption of sensitive data at rest, including financial account details and identity documents;
• Access controls limiting personal data access to authorised Fellbet personnel and service providers on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform infrastructure;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, Fellbet will notify the National Privacy Commission of the Philippines and, where required, affected individuals, in accordance with the Data Privacy Act of 2012 and its implementing rules.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in respect of your personal data held by Fellbet:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed, as set out in this Privacy Policy;
• Right of access: You have the right to request a copy of the personal data Fellbet holds about you and information about how it is processed;
• Right to rectification: You have the right to request correction of inaccurate or incomplete personal data. You may update certain account details directly through your account settings;
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to Fellbet's legal retention obligations;
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to Fellbet's overriding legal or operational requirements;
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format where processing is based on consent or contractual necessity;
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact Fellbet's support team. Fellbet will respond to all data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, with prior notification to you.

Please note that certain rights are subject to limitations where Fellbet is required to retain or process data to comply with legal obligations, including anti-money laundering regulations and PAGCOR-aligned regulatory requirements.

11. Children's Privacy and Age Restrictions

Fellbet conducts mandatory age verification as part of the account registration and KYC process. Any account found to belong to a person under 21 years of age will be immediately suspended, and any funds held in that account will be handled in accordance with applicable regulations.

If you believe that Fellbet has inadvertently collected personal data from a person under the age of 21, please contact our support team immediately. Fellbet will take prompt action to delete such data and close the associated account.

Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gaming platforms. Fellbet supports responsible gaming initiatives and the protection of vulnerable individuals, including minors.

12. International Data Transfers

Fellbet's primary operations and data storage are based in the Philippines. However, some of Fellbet's third-party service providers, including KYC verification providers, game content providers, and cloud infrastructure partners, may process personal data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, Fellbet ensures that appropriate safeguards are in place to protect your data, including:

• Contractual clauses requiring recipient organisations to apply data protection standards equivalent to those required under Philippine law;
• Transfers only to jurisdictions that the National Privacy Commission has determined provide an adequate level of data protection;
• Binding corporate rules or equivalent mechanisms where data is transferred within a corporate group.

By using the Fellbet Platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside the Philippines, subject to the safeguards described above.

13. Changes to This Privacy Policy

Fellbet reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. The date of the most recent revision is displayed at the top of this page.

Where changes are material, Fellbet will notify registered account holders via email or platform notification prior to the changes taking effect. Your continued use of the Fellbet Platform following the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how Fellbet protects your personal data. If you have concerns about any changes, please contact our support team before continuing to use the Platform.

14. Contact and Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or Fellbet's handling of your personal data, please contact our Data Privacy Officer. Our team is available to assist players across the Philippines, including those in Manila, Cebu, Davao, Quezon City, and Makati.

If you are not satisfied with Fellbet's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Details of the NPC's complaint process are available on the NPC's official website.

For responsible gaming concerns, including self-exclusion requests and deposit limit adjustments, please visit the Responsible Gaming section of the Fellbet Platform.