Privacy Policy of fxreplay

This Privacy Policy ("Policy") describes how fxreplay ("fxreplay," "we," "us," or "our"), the operator of the online gaming platform at fxreplay.vip (the "Platform"), collects, uses, stores, discloses, and protects the personal data of individuals ("Players," "Users," or "you") who access or use the Platform.

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC") of the Philippines. It applies to all personal data collected through the Platform, our mobile applications, customer support channels, and any other touchpoints between you and fxreplay.

This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, which together form the complete agreement governing your use of fxreplay.

For the purposes of the Data Privacy Act of 2012, fxreplay acts as the Personal Information Controller in respect of the personal data it collects and processes through the Platform. This means fxreplay determines the purposes and means of processing your personal data.

Where fxreplay engages third-party service providers to process personal data on its behalf (for example, payment processors or identity verification providers), those parties act as Personal Information Processors and are contractually bound to process your data only on fxreplay's instructions and in accordance with applicable Philippine data privacy law.

Our designated Data Protection Officer ("DPO") can be contacted at: [email protected]

fxreplay collects the following categories of personal data:

fxreplay collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity and fraud-check data received from KYC verification providers, payment processors (such as GCash, PayMaya, BPI, BDO, Metrobank), and fraud prevention services.
• Publicly available sources: Information from public registries or databases where permitted by law and necessary for compliance purposes.

fxreplay uses your personal data for the following purposes:

• To create, verify, and manage your fxreplay player account.
• To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment channels.
• To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under Philippine law.
• To verify that you meet the minimum age requirement of 21 years as required under Philippine gaming regulations.
• To deliver bonuses, promotions, and personalised offers where you have opted in to receive marketing communications.
• To monitor gameplay for responsible gaming purposes, including detecting signs of problem gambling and enforcing self-exclusion requests.
• To detect, investigate, and prevent fraud, cheating, money laundering, and other prohibited activities.
• To improve the Platform's features, performance, and user experience through analytics.
• To respond to your customer support enquiries and resolve disputes.
• To comply with applicable laws, regulations, and requests from regulatory authorities including PAGCOR and the NPC.

Under the Data Privacy Act of 2012, fxreplay processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you (i.e., operating your player account, processing transactions).
• Legal obligation: Processing required to comply with Philippine laws and regulations, including AML, KYC, and gaming regulatory requirements.
• Legitimate interests: Processing for fraud prevention, platform security, 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.

fxreplay does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment service providers, for the purpose of processing your financial transactions.
• KYC and identity verification providers: Third-party services engaged to verify your identity and age in compliance with regulatory requirements.
• Fraud prevention and security services: Providers that help fxreplay detect and prevent fraudulent activity on the Platform.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities, where disclosure is required by law or court order.
• IT and cloud service providers: Providers of hosting, data storage, and technical infrastructure services, who process data solely on fxreplay's instructions.
• Professional advisers: Lawyers, auditors, and accountants, where necessary for legal or compliance purposes, subject to professional confidentiality obligations.

fxreplay uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, and analyse how the Platform is used.

Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function, including session management and security. These cannot be disabled.
• Functional cookies: Remember your preferences (such as language settings) to provide a more personalised experience.
• Analytics cookies: Help us understand how players use the Platform so we can improve its performance and features. Used only with your consent.
• Marketing cookies: Used to deliver relevant promotional content. Used only with your explicit consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the fxreplay Platform.

fxreplay retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. In general:

• Account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AML and gaming regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years as required by the Anti-Money Laundering Act and PAGCOR regulations.
• KYC documents: Retained for the period required by applicable law, typically five (5) years from the end of the business relationship.
• Customer support records: Retained for up to three (3) years from the date of the interaction.
• Marketing data: Retained until you withdraw consent or request deletion, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with fxreplay's data disposal procedures.

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the fxreplay Platform.
• Encryption of sensitive data at rest, including financial information and government ID data.
• Role-based access controls ensuring that only authorised fxreplay personnel can access personal data on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform.
• Multi-factor authentication options for player accounts.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by fxreplay:

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days in accordance with NPC guidelines. You also have the right to lodge a complaint with the National Privacy Commission if you believe your data rights have been violated.

The fxreplay Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. fxreplay does not knowingly collect personal data from individuals under the age of 21.

If fxreplay becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the associated personal data, and, where applicable, return any deposited funds. If you believe a minor has registered on the fxreplay Platform, please notify us immediately at [email protected].

fxreplay's primary operations and data storage are based in the Philippines. In certain circumstances, your personal data may be transferred to, stored in, or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international fraud prevention services.

Where such transfers occur, fxreplay ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that impose data protection obligations equivalent to those under the Data Privacy Act of 2012. fxreplay will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without implementing appropriate safeguards.

fxreplay reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically to stay informed about how fxreplay protects your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by fxreplay, please contact our Data Protection Officer:

Data Protection Officer: fxreplay Privacy Team
Email: [email protected]
General Support: [email protected]
Response Time: Within 15 business days of receiving a verified request.

You also have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. For more information, visit the NPC's official website or contact them directly through official government channels.