fc78 Privacy Policy

1. Introduction

fc78 is committed to protecting the privacy and security of your personal information. As a PAGCOR-licensed online gaming operator serving Filipino players, we recognize the trust you place in us when sharing your personal data. This Privacy Policy outlines our practices regarding data collection, processing, storage, and protection in full compliance with Philippine data privacy laws and international best practices.

We collect and process personal information solely for legitimate purposes related to providing gaming services, ensuring regulatory compliance, preventing fraud, and enhancing user experience. Your privacy rights are paramount, and we have implemented comprehensive technical and organizational measures to safeguard your data against unauthorized access, disclosure, alteration, or destruction.

This Privacy Policy applies to all users of the fc78 Platform regardless of access method (website, mobile application, or other channels). By continuing to use our services, you confirm your understanding and acceptance of the data practices described in this policy.

2. Data Controller Information

fc78 operates as the data controller responsible for processing your personal information. Our data protection obligations are governed by Philippine law, specifically the Data Privacy Act of 2012 and regulations issued by the National Privacy Commission (NPC). We have appointed a Data Protection Officer (DPO) responsible for overseeing compliance with data protection requirements and serving as the point of contact for privacy-related inquiries.

Data Controller Details:

• Company Name: fc78 Philippines Gaming Corporation
• PAGCOR License Number: PAGCOR-RGL-2020-078
• Principal Office: Metro Manila, Philippines
• Data Protection Officer Email: [email protected]
• Privacy Inquiries: [email protected]

3. Information We Collect

fc78 collects various categories of personal information necessary for account registration, service provision, regulatory compliance, and platform security. The types of information we collect include:

3.1 Registration and Account Information

When you create an fc78 account, we collect identification and contact information including:

• Full legal name as it appears on government-issued identification
• Date of birth and age verification information
• Residential address including street, barangay, city/municipality, and province
• Email address and mobile telephone number
• Government-issued identification number (Philippine passport, driver's license, UMID, national ID)
• Username and encrypted password
• Security questions and answers
• Preferred communication language

3.2 Financial and Transaction Information

To process deposits and withdrawals, we collect financial data including:

• Payment method details (GCash number, Maya account, bank account information, cryptocurrency wallet addresses)
• Transaction history including deposits, withdrawals, and payment processing records
• Source of funds documentation for compliance with anti-money laundering requirements
• Payment processor transaction identifiers and confirmation records
• Betting history, wagering patterns, and gaming activity records
• Bonus redemption and promotional participation records

3.3 Verification and Compliance Information

For regulatory compliance and fraud prevention, we collect:

• Copies of government-issued identification documents
• Proof of address documents (utility bills, bank statements, government correspondence)
• Selfie photographs for identity verification
• Biometric authentication data (if you enable biometric login features)
• Enhanced due diligence documentation for high-value transactions
• Records of customer support interactions and complaints

3.4 Technical and Usage Information

We automatically collect technical data about your use of the fc78 Platform:

• IP address and geographic location data
• Device information (device type, operating system, browser type and version, screen resolution)
• Login timestamps and session duration
• Pages visited, features accessed, and navigation patterns
• Referring website or source of Platform access
• Cookies, web beacons, and similar tracking technologies data
• Error logs, crash reports, and performance data

3.5 Communication Records

We retain records of communications between you and fc78:

• Customer support chat transcripts, emails, and telephone call recordings
• Marketing communication preferences and opt-out requests
• Correspondence related to complaints, disputes, or account issues
• Survey responses and feedback submissions

4. How We Use Your Information

fc78 processes your personal information for specific, explicit, and legitimate purposes. We do not use your data for purposes incompatible with those for which it was originally collected. The primary uses of your information include:

4.1 Service Provision and Account Management

• Creating and maintaining your fc78 account
• Processing deposits, withdrawals, and financial transactions
• Executing bets and gaming activities according to your instructions
• Calculating winnings, settling bets, and managing account balances
• Providing customer support and responding to inquiries
• Sending transactional communications (account confirmations, transaction receipts, important account updates)

4.2 Regulatory Compliance and Legal Obligations

• Verifying your identity and age to comply with PAGCOR licensing requirements
• Conducting anti-money laundering (AML) checks and suspicious transaction monitoring
• Maintaining records as required by Philippine gaming regulations and tax laws
• Reporting to PAGCOR, National Privacy Commission, Anti-Money Laundering Council, and other regulatory authorities as required by law
• Responding to lawful requests from law enforcement and government agencies
• Enforcing our Terms and Conditions and other legal agreements

4.3 Security and Fraud Prevention

• Detecting, investigating, and preventing fraudulent activity, cheating, collusion, and Terms violations
• Monitoring for multiple accounts, bonus abuse, and prohibited gaming patterns
• Protecting against unauthorized access, cyberattacks, and data breaches
• Verifying geographic location to ensure compliance with jurisdiction restrictions
• Conducting security audits and risk assessments

4.4 Platform Improvement and Analytics

• Analyzing user behavior and gaming patterns to improve Platform functionality
• Conducting research and statistical analysis to enhance user experience
• Testing new features, games, and services
• Optimizing Platform performance, speed, and reliability
• Identifying and fixing technical issues and bugs

4.5 Marketing and Communications (With Consent)

• Sending promotional offers, bonuses, and special event notifications
• Providing personalized gaming recommendations based on your preferences
• Conducting surveys and gathering feedback about fc78 services
• Informing you about new games, features, and Platform updates

Note on Marketing: You may opt out of marketing communications at any time by clicking the unsubscribe link in promotional emails or adjusting your communication preferences in account settings. Opting out of marketing does not affect transactional communications necessary for service provision.

5. Information Sharing and Disclosure

fc78 does not sell, rent, or trade your personal information to third parties for their marketing purposes. We share your information only in the following limited circumstances:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers who assist in Platform operation:

• Payment processors: GCash, Maya, banks, and cryptocurrency payment gateways that process your transactions
• Game providers: Software developers (Pragmatic Play, Evolution Gaming, etc.) whose games you play
• Identity verification services: Third-party verification providers that confirm your identity and age
• Cloud infrastructure providers: Data hosting and storage service providers
• Customer support tools: Live chat, email, and communication platform providers
• Analytics providers: Services that help us understand Platform usage patterns

All service providers are contractually bound to maintain confidentiality and use your data only for specified purposes. We conduct due diligence to ensure service providers implement adequate security measures.

5.2 Regulatory and Legal Disclosures

We disclose personal information when required by Philippine law or regulatory obligations:

• To PAGCOR for licensing compliance and regulatory reporting
• To the Anti-Money Laundering Council (AMLC) for suspicious transaction reports
• To the National Privacy Commission in response to data privacy inquiries
• To law enforcement agencies pursuant to valid legal process (subpoenas, court orders, warrants)
• To tax authorities for compliance with Philippine tax laws

5.3 Business Transfers

In the event fc78 undergoes a merger, acquisition, corporate restructuring, or sale of assets, your personal information may be transferred to the successor entity. You will be notified of any such transfer, and the acquiring entity will be bound by the commitments in this Privacy Policy.

5.4 Consent-Based Sharing

With your explicit consent, we may share information with third parties for purposes not otherwise described in this Privacy Policy. You retain the right to withdraw consent at any time.

6. Data Security Measures

fc78 implements industry-standard security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

6.1 Technical Security Controls

• Encryption: All data transmissions use 256-bit SSL/TLS encryption. Sensitive data stored in databases is encrypted at rest using AES-256 encryption.
• Access Controls: Strict role-based access controls limit employee access to personal data based on job function necessity. Multi-factor authentication required for administrative access.
• Network Security: Firewalls, intrusion detection systems, and regular security audits protect against cyberattacks.
• Secure Development: Code review processes, vulnerability scanning, and penetration testing conducted regularly.
• Data Segregation: Player funds held in segregated accounts separate from operational accounts.

6.2 Organizational Security Measures

• Employee Training: All fc78 employees receive data privacy and security training as part of onboarding and ongoing education.
• Confidentiality Agreements: Employees and contractors sign strict confidentiality agreements prohibiting unauthorized data disclosure.
• Data Protection Impact Assessments: Regular assessments conducted for new processing activities that may affect privacy.
• Incident Response: Comprehensive data breach response plan in place to detect, respond to, and mitigate security incidents.

6.3 Third-Party Security

All third-party service providers undergo security assessments before engagement. Contracts require providers to maintain security standards equivalent to or exceeding fc78's own measures.

User Responsibility: While fc78 implements robust security measures, you also play a critical role in protecting your account. Keep your password confidential, enable two-factor authentication if available, avoid using public Wi-Fi for sensitive transactions, and immediately report any suspected unauthorized access.

7. Data Retention

fc78 retains personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce agreements.

7.1 Active Account Data

While your account remains active, we retain all account and transactional data necessary for service provision, including your registration information, transaction history, gaming activity, and communication records.

7.2 Closed Account Data

Following voluntary account closure, we retain certain data for legal and regulatory compliance:

• PAGCOR Requirements: Transaction records, identity verification documents, and gaming activity logs retained for minimum of five (5) years per PAGCOR regulations.
• Anti-Money Laundering: Financial transaction records retained for five (5) years per AMLA requirements.
• Tax Compliance: Records retained as required by Bureau of Internal Revenue regulations.
• Legal Claims: Data related to disputes, complaints, or legal matters retained until resolution plus applicable statute of limitations period.

7.3 Marketing Data

If you opt out of marketing communications, we retain minimal information (email address, opt-out preference) to honor your request and prevent future unwanted communications.

7.4 Data Deletion

After retention periods expire and no legal obligation requires continued storage, personal information is securely deleted or anonymized. Deletion methods include secure overwriting of digital data and physical destruction of paper records.

8. Your Privacy Rights

Under the Philippine Data Privacy Act, you have the following rights regarding your personal information:

8.1 Right to Information

You have the right to be informed about the collection and processing of your personal data. This Privacy Policy and related notices fulfill this obligation.

8.2 Right to Access

You may request access to your personal information held by fc78. We will provide a copy of your data in a commonly used electronic format within thirty (30) days of verified request.

8.3 Right to Rectification

You may request correction of inaccurate or incomplete personal information. You can update most account information directly through your fc78 account settings. For changes requiring verification (name, date of birth), contact Customer Support with supporting documentation.

8.4 Right to Erasure

You may request deletion of your personal information when: (a) data is no longer necessary for the purposes collected; (b) you withdraw consent and no other legal ground exists for processing; (c) data was unlawfully processed. This right is subject to legal retention obligations described in Section 7.

8.5 Right to Object

You may object to processing of your personal information for direct marketing purposes (opt-out rights) or processing based on legitimate interests. Upon objection, we will cease processing unless compelling legitimate grounds override your interests.

8.6 Right to Data Portability

You may request transfer of your personal data to another service provider in a structured, commonly used, machine-readable format, where technically feasible.

8.7 Right to Withdraw Consent

Where processing is based on consent, you may withdraw consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.

8.8 Exercising Your Rights

To exercise privacy rights, contact our Data Protection Officer at [email protected] or submit a request through the privacy settings in your fc78 account. We will verify your identity before processing requests and respond within fifteen (15) days for simple requests or thirty (30) days for complex requests.

9. Cookies and Tracking Technologies

fc78 uses cookies, web beacons, and similar technologies to enhance Platform functionality, analyze usage patterns, and personalize user experience.

9.1 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Enable core Platform functionality, login authentication, and security features. These cannot be disabled.	Session / 1 year
Performance Cookies	Collect anonymous usage data to improve Platform performance and identify technical issues.	1-2 years
Functional Cookies	Remember your preferences (language, display settings) to personalize your experience.	1 year
Analytics Cookies	Track visitor behavior to understand how users interact with the Platform and optimize accordingly.	1-2 years
Marketing Cookies	Deliver relevant promotional content and measure marketing campaign effectiveness.	90 days - 1 year

9.2 Managing Cookies

You can control cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. However, disabling essential cookies may prevent access to certain Platform features. Consult your browser's help documentation for cookie management instructions.

10. International Data Transfers

fc78 primarily stores and processes data within the Philippines. However, some service providers may process data in other jurisdictions. When transferring data internationally, we ensure adequate protection through:

• Contractual clauses requiring equivalent data protection standards
• Verification that destination jurisdictions provide adequate legal protections
• Use of recognized international data transfer mechanisms

Data transferred outside the Philippines remains subject to Philippine Data Privacy Act protections, and we retain responsibility for ensuring proper handling by international processors.

11. Children's Privacy

The fc78 Platform is strictly intended for adults aged 21 years and older. We do not knowingly collect personal information from individuals under 21 years of age. Our age verification processes are designed to prevent underage access.

If we discover that personal information of an individual under 21 has been collected, we will immediately delete such information, terminate the associated account, forfeit any account balance, and report the matter to PAGCOR and relevant authorities as required.

Parents or guardians who believe their minor child has provided information to fc78 should immediately contact [email protected] so we can take appropriate action.

12. Changes to Privacy Policy

fc78 reserves the right to modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated through:

• Prominent notice on the fc78 Platform homepage
• Email notification to your registered email address
• In-Platform notification upon login
• Updated "Last Updated" date at the top of this policy

Continued use of the Platform following Privacy Policy changes constitutes acceptance of updated terms. If you do not agree with modifications, your sole remedy is to discontinue use and close your account.

13. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or your personal information, please contact:

• Data Protection Officer: [email protected]
• Privacy Inquiries: [email protected]
• Customer Support: [email protected] (24/7 availability)
• Live Chat: Available through fc78 website and mobile app

Regulatory Contact: If you have unresolved concerns about our data practices, you may lodge a complaint with the National Privacy Commission:

• National Privacy Commission
• 5th Floor, Philippine International Convention Center, Vicente Sotto Street, Pasay City, Metro Manila, Philippines
• Email: [email protected]
• Website: www.privacy.gov.ph
• Hotline: (+632) 8234-2228

This Privacy Policy was last updated on January 15, 2025.