FC78 Privacy Policy

1. Who We Are

1.1 FC78 ("FC78," "we," "us," "our") operates the online gaming platform accessible at fc78.app. FC78 is the data controller responsible for the personal information collected through the FC78 platform.

1.2 FC78 operates under applicable Philippine gaming regulations and is subject to the oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). FC78 is also subject to the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and the regulations issued by the National Privacy Commission (NPC).

1.3 For all privacy-related inquiries, you may contact FC78's Data Protection Officer (DPO) at [email protected]. FC78 aims to respond to all privacy inquiries within five (5) business days.

2. Personal Data We Collect

2.1 FC78 collects the following categories of personal data from registered players and platform visitors:

2.2 FC78 does not collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. FC78 does not collect biometric data, health data, or political opinions.

3. How We Collect Your Data

3.1 Directly from you. FC78 collects personal data that you provide directly when you register an account, complete identity verification, make a deposit or withdrawal, contact FC78 support, or participate in a promotion.

3.2 Automatically. When you access the FC78 platform, certain technical data is collected automatically through cookies, log files, and similar tracking technologies. This includes your IP address, device information, and browsing behaviour on the FC78 platform.

3.3 From third parties. FC78 may receive personal data from third-party identity verification providers, payment processors (such as GCash and Maya), and fraud prevention services. FC78 only receives data from third parties where it is necessary for the purposes described in this policy and where the third party is authorised to share that data.

3.4 From public sources. FC78 may supplement your account information with data from publicly available sources, such as government databases, where this is necessary for regulatory compliance or fraud prevention.

4. How We Use Your Personal Data

4.1 FC78 uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your FC78 account, including processing your registration, verifying your identity, and managing your account settings.
• Transaction processing: To process deposits, withdrawals, and bonus payments in Philippine Peso via your chosen payment method.
• Regulatory compliance: To comply with FC78's obligations under Philippine gaming regulations, anti-money laundering laws, and the Data Privacy Act, including conducting Know Your Customer (KYC) checks and filing required reports with PAGCOR and other authorities.
• Platform security and fraud prevention: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the FC78 platform.
• Responsible gaming: To monitor gameplay patterns for signs of problem gambling and to administer responsible gaming tools such as deposit limits, session reminders, and self-exclusion.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform improvement: To analyse usage data and improve the FC78 platform, games, and services.
• Marketing communications: To send you promotional offers, bonuses, and news about FC78, but only where you have given your explicit consent to receive such communications.

4.2 FC78 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise required by law.

5. Legal Basis for Processing

5.1 FC78 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform the contract between you and FC78 — specifically , to operate your FC78 account, process transactions, and deliver gaming services.
• Legal obligation: Processing is necessary for FC78 to comply with its obligations under Philippine law, including anti-money laundering regulations, PAGCOR licensing requirements, and the Data Privacy Act.
• Legitimate interests: Processing is necessary for FC78's legitimate interests in preventing fraud, ensuring platform security, and improving its services, provided those interests are not overridden by your rights and interests.
• Consent: Where FC78 relies on your consent as the legal basis for processing — for example, for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Sharing Your Personal Data

6.1 FC78 does not sell, rent, or trade your personal data to third-party marketers under any circumstances.

6.2 FC78 may share your personal data with the following categories of recipients, strictly on a need-to-know basis and only to the extent necessary for the stated purpose:

• Payment processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification services used to verify your identity and age in compliance with Philippine regulations.
• Fraud prevention services: Third-party fraud detection and prevention providers that help FC78 identify and prevent fraudulent activity on the platform.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where FC78 is legally required to disclose your data.
• Law enforcement: Philippine law enforcement agencies, where FC78 is required by law or court order to disclose your data.
• IT and platform service providers: Third-party technology providers that support the operation of the FC78 platform, including cloud hosting, data analytics, and customer support software providers. These providers are contractually bound to process your data only on FC78's instructions and in accordance with applicable data protection law.

6.3 All third parties with whom FC78 shares personal data are required to maintain appropriate technical and organisational security measures to protect your data and to use it only for the purposes for which it was shared.

6.4 In the event of a merger, acquisition, or sale of all or part of FC78's business, your personal data may be transferred to the acquiring entity. FC78 will notify you of any such transfer and the acquiring entity will be required to honour this Privacy Policy.

7. Cookies and Tracking Technologies

7.1 FC78 uses cookies and similar tracking technologies on the fc78.app platform. Cookies are small text files stored on your device that help FC78 recognise you, remember your preferences, and analyse how the platform is used.

7.2 FC78 uses the following types of cookies:

• Strictly necessary cookies: These cookies are essential for the FC78 platform to function. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Functional cookies: These cookies remember your preferences and settings, such as your preferred language and display options, to provide a more personalised experience on FC78.
• Analytics cookies: These cookies collect anonymised information about how visitors use the FC78 platform, such as which pages are visited most frequently and how users navigate the site. This data helps FC78 improve the platform.
• Security cookies: These cookies help FC78 detect and prevent fraudulent activity, including bot activity and account takeover attempts.

7.3 You can control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the FC78 platform. Strictly necessary and security cookies cannot be disabled as they are essential to platform operation.

7.4 FC78 does not use cookies to track your activity on third-party websites or to serve targeted advertising on external platforms.

8. Data Retention

8.1 FC78 retains your personal data for as long as your account is active and for such additional period as is necessary to comply with FC78's legal obligations, resolve disputes, and enforce FC78's agreements.

8.2 The following retention periods apply to the main categories of personal data held by FC78:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with Philippine anti-money laundering regulations.
• Financial transaction data: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML law.
• Customer support communications: Retained for three (3) years from the date of the communication.
• Technical and usage data: Retained for up to two (2) years from collection, unless required for longer for fraud investigation or legal proceedings.
• Marketing preference data: Retained until you withdraw your consent or request deletion.

8.3 When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, FC78 will securely delete or anonymise that data.

9. Data Security

9.1 FC78 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the FC78 platform;
• Encryption of sensitive data at rest, including financial data and identity documents;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits and vulnerability assessments of the FC78 platform;
• Two-factor authentication options for player accounts;
• Intrusion detection systems and 24/7 security monitoring.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, FC78 will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, as required by the Data Privacy Act. FC78 will also notify affected players without undue delay where the breach is likely to result in a high risk to their rights.

9.3 While FC78 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for keeping your FC78 login credentials confidential and for notifying FC78 immediately if you suspect unauthorised access to your account.

10. Your Data Privacy Rights

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by FC78:

• Right to be informed: You have the right to be informed about how FC78 collects and uses your personal data. This Privacy Policy fulfils that obligation.
• Right of access: You have the right to request a copy of the personal data FC78 holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data FC78 holds about you.
• 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 FC78's legal retention obligations.
• Right to object: You have the right to object to FC78's processing of your personal data where that processing is based on legitimate interests or for direct marketing purposes.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that FC78 transmit that data to another data controller where technically feasible.
• Right to withdraw consent: Where FC78 processes your data based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe FC78 has violated your data privacy rights.

10.2 To exercise any of the above rights, please contact FC78's Data Protection Officer at [email protected]. FC78 will respond to all data rights requests within fifteen (15) business days of receipt. FC78 may request proof of identity before processing a data rights request.

11. Children's Privacy

11.1 The FC78 platform is strictly intended for persons aged twenty-one (21) years and above. FC78 does not knowingly collect personal data from persons under the age of 21.

11.2 If FC78 becomes aware that it has inadvertently collected personal data from a person under 21 years of age, FC78 will immediately close the associated account, delete the personal data, and return any deposited funds in accordance with FC78's underage account procedures.

11.3 If you believe that FC78 may have collected personal data from a person under 21 years of age, please contact FC78 support immediately at [email protected].

12. Third-Party Links

12.1 The FC78 platform may contain links to third-party websites or services. FC78 is not responsible for the privacy practices of those third-party sites and this Privacy Policy does not apply to them.

12.2 FC78 recommends that you review the privacy policy of any third-party site you visit. FC78 has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services.

13. Changes to This Privacy Policy

13.1 FC78 reserves the right to update or amend this Privacy Policy at any time to reflect changes in FC78's data processing practices, applicable law, or regulatory requirements.

13.2 When material changes are made to this Privacy Policy, FC78 will notify registered players via email or an in-platform notification at least seven (7) days before the changes take effect. The updated effective date will be displayed at the top of this page.

13.3 Your continued use of the FC78 platform after the effective date of any amended Privacy Policy constitutes your acknowledgement of the updated policy. If you do not agree with the amended policy, you must cease using FC78 and may request account closure.

13.4 The most current version of this Privacy Policy is always available at fc78.app/privacy-policy.

14. Contact and Data Protection Officer

14.1 FC78 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy.

14.2 If you have any questions, concerns, or requests relating to this Privacy Policy or FC78's handling of your personal data, please contact the FC78 DPO:

14.3 If you are not satisfied with FC78's response to your privacy inquiry, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC).