Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 1ph ("we," "us," "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "your," "Player") who access or use the 1ph platform at https://1ph.asia ("Platform").

We are committed to protecting your privacy and handling your personal data in a transparent, lawful, and responsible manner. This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as applicable PAGCOR data governance requirements.

By registering an account on 1ph or otherwise 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 with any part of this Policy, please discontinue use of the Platform.

2. Data Controller

1ph is the data controller responsible for your personal data collected through the Platform. As data controller, we determine the purposes and means of processing your personal data, and we are accountable for ensuring that such processing complies with applicable Philippine data protection law.

We have appointed a Data Protection Officer (DPO) as required under the Data Privacy Act. The DPO is responsible for overseeing our data protection strategy and ensuring compliance with this Policy and applicable law. Contact details for our DPO are provided in Section 14 of this Policy.

3. Data We Collect

1ph collects the following categories of personal data from Players:

4. How We Collect Data

1ph collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including IP address, device identifiers, browser information, and session activity logs.
• Cookies and similar technologies: As described in Section 9 of this Policy, we use cookies and similar tracking technologies to collect data about your interactions with the Platform.
• Third-party sources: We may receive data from identity verification service providers, payment processors, and fraud prevention partners for the purposes of KYC compliance and security.
• Regulatory sources: In certain circumstances, we may receive data from PAGCOR or other regulatory bodies as part of our compliance obligations.

5. Purpose & Legal Basis

We process your personal data only where we have a lawful basis to do so under the Data Privacy Act of 2012. The following table sets out the purposes for which we process your data and the corresponding legal basis:

• Account registration and management: Processing is necessary for the performance of our contract with you as a registered Player on the 1ph platform.
• KYC and identity verification: Processing is required to comply with PAGCOR regulations and the Anti-Money Laundering Act (AMLA). This is a legal obligation we cannot waive.
• Processing deposits and withdrawals: Necessary for the performance of our contract with you and to comply with financial regulations.
• Fraud prevention and security: Processing is in our legitimate interest and yours to protect the integrity of the platform and prevent financial crime.
• Responsible gaming monitoring: Required by PAGCOR regulations and in the legitimate interest of player welfare.
• Customer support: Necessary for the performance of our contract and to respond to your enquiries.
• Marketing communications: Based on your explicit consent. You may withdraw consent at any time by updating your communication preferences in your account settings.
• Platform improvement and analytics: In our legitimate interest to improve the quality and performance of the 1ph platform.

6. Data Sharing

1ph does not sell your personal data. We may share your data with the following categories of recipients only where necessary and under appropriate data protection safeguards:

• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law or regulatory directive.
• Payment processors: GCash, Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing your deposits and withdrawals. These providers process your data under their own privacy policies and applicable regulations.
• Identity verification providers: Third-party KYC service providers engaged to assist with identity verification and document authentication, operating under strict data processing agreements.
• Fraud prevention partners: Service providers that assist in detecting and preventing fraudulent activity, money laundering, and other financial crimes on the platform.
• IT and infrastructure providers: Cloud hosting, data storage, and platform infrastructure providers who process data on our behalf under binding data processing agreements.
• Legal and professional advisors: Lawyers, auditors, and compliance consultants where necessary for legal proceedings, regulatory compliance, or professional advice.

All third parties with whom we share personal data are required to handle it in accordance with applicable Philippine data protection law and our contractual requirements.

7. Data Retention

1ph retains your personal data for the following periods:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required by PAGCOR regulations and AMLA obligations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA record-keeping requirements.
• KYC documents: Retained for a minimum of five (5) years after the end of the business relationship, or longer if required by a regulatory directive or ongoing investigation.
• Gaming history: Retained for a minimum of three (3) years for dispute resolution and responsible gaming monitoring purposes.
• Customer support records: Retained for two (2) years from the date of the last interaction.
• Marketing preference data: Retained until you withdraw consent or close your account, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised, unless retention is required by a specific legal obligation or ongoing regulatory proceeding.

8. Security Measures

1ph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including account credentials and financial information.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While we take all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account login credentials and for notifying 1ph immediately if you suspect any unauthorised access to your account.

9. Cookies & Tracking Technologies

1ph uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential cookies: Required for the Platform to function correctly, including maintaining your login session and remembering your preferences. These cannot be disabled without affecting Platform functionality.
• Analytics cookies: Used to collect aggregated, anonymised data about how Players use the Platform, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats.
• Preference cookies: Used to remember your language, display, and notification preferences across sessions.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may impair your ability to use certain features of the 1ph Platform.

10. Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 1ph:

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 14. We will respond to all verified requests within fifteen (15) business days in accordance with NPC guidelines.

11. Minors

The 1ph Platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine law and PAGCOR regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21, we will immediately close the associated account, delete the data, and return any deposited funds. If you believe a minor has registered on the Platform, please contact us immediately at the details provided in Section 14.

12. Cross-Border Data Transfers

Where personal data is transferred outside the Philippines – for example, to cloud infrastructure providers or international KYC service providers – 1ph ensures that such transfers are conducted in compliance with the Data Privacy Act of 2012 and NPC guidelines on cross-border data transfers.

We implement appropriate safeguards for international transfers, including contractual clauses that require recipient organisations to protect your data to a standard equivalent to Philippine data protection law. We do not transfer your data to jurisdictions that do not provide an adequate level of data protection without implementing such safeguards.

13. Policy Amendments

1ph reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or platform features. Material changes will be communicated to registered Players via the email address associated with their account and via a prominent notice on the Platform.

The effective date at the top of this Policy will be updated whenever changes are made. We encourage you to review this Policy periodically. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

14. Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 1ph, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Response Time: We aim to acknowledge all data rights requests within 3 business days and resolve them within 15 business days.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.