1apiso Privacy Policy – How We Handle Your Data

01 Introduction

1apiso ("the Platform," "we," "our," "us") is committed to protecting the privacy and personal information of every player who uses our platform. This Privacy Policy ("Policy") describes how 1apiso collects, processes, stores, shares, and protects personal data in connection with your use of the 1apiso online gaming platform accessible at 1apiso.org.

This Policy is prepared in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as applicable regulations issued by the National Privacy Commission (NPC) of the Philippines and the Philippine Amusement and Gaming Corporation (PAGCOR).

By registering for or using the 1apiso 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. This Policy should be read in conjunction with the 1apiso Terms and Conditions.

02 Data Controller Information

For the purposes of the Data Privacy Act of 2012, the data controller responsible for your personal information is:

1apiso has designated a Data Protection Officer (DPO) as required by the Data Privacy Act of 2012. The DPO is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO directly at the email address above for any data privacy-related concerns.

03 Personal Data We Collect

1apiso collects personal data in the following categories, depending on the nature of your interaction with the platform:

3.1 Identity & Registration Data

• Full legal name as it appears on a government-issued Philippine ID
• Date of birth (used to verify the 21+ age requirement)
• Registered mobile number (Philippine format)
• Email address
• Username and encrypted password
• Nationality and country of residence

3.2 Identity Verification (KYC) Data

• Government-issued ID type and number (PhilSys, UMID, Driver's License, Passport, Voter's ID, SSS ID)
• Scanned or photographed copies of identity documents submitted for KYC verification
• Selfie or facial verification image (where required for enhanced KYC)
• Proof of address documentation where applicable

3.3 Financial & Transaction Data

• GCash account number or Maya account identifier (masked)
• Bank account details for bank transfer transactions (BPI, BDO, Metrobank, etc.)
• Deposit and withdrawal amounts, dates, and reference numbers
• Transaction history and account balance records

3.4 Gameplay & Platform Usage Data

• Games played, bets placed, outcomes, and win/loss records
• Session duration, login timestamps, and session activity logs
• Bonus and promotional offer usage history
• Player preferences, game filter settings, and self-imposed limits

3.5 Technical & Device Data

• IP address and approximate geolocation (province/city level)
• Device type, operating system version, and browser type
• Mobile network operator (Globe, Smart, DITO, etc.)
• Session identifiers and authentication tokens

3.6 Communications Data

• Live chat transcripts and support ticket content
• Emails and SMS messages exchanged with 1apiso support
• Responses to surveys or feedback forms (where voluntarily submitted)

04 How We Collect Your Data

1apiso collects personal data through the following methods:

• Direct submission: Information you provide when registering, completing KYC, depositing funds, or contacting support
• Platform activity: Data generated automatically when you use the 1apiso platform — logins, gameplay, transactions, and navigation behavior
• Technical systems: Server logs, cookies, and session tracking technology that record device and connection information
• Third-party payment processors: Transaction confirmation data shared by GCash, Maya, BPI, BDO, and other payment providers when you initiate a deposit or withdrawal
• Identity verification providers: KYC verification results provided by third-party identity verification services engaged by 1apiso

05 How We Use Your Personal Data

1apiso processes personal data only for specific, legitimate purposes. The table below outlines the primary purposes for which your data is used:

1apiso does not use personal data for automated decision-making that produces legal or similarly significant effects on players without human review. Responsible gaming interventions (such as account restrictions based on gameplay patterns) involve human oversight from our compliance team.

06 Legal Basis for Processing

Under the Data Privacy Act of 2012, 1apiso processes personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill the agreement between you and 1apiso — providing gaming services, processing payments, and managing your account
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, Anti-Money Laundering Act (AMLA) reporting obligations, Bureau of Internal Revenue (BIR) requirements, and other applicable Philippine laws
• Legitimate interest: Processing for fraud prevention, platform security, responsible gaming monitoring, and anonymized analytics — where these interests are not overridden by your data protection rights
• Consent: Processing for optional purposes such as marketing communications and personalized promotions — which you may withdraw at any time through your account settings

07 Data Sharing & Third Parties

1apiso shares personal data only with the following categories of third parties, and only to the extent necessary for the stated purpose:

• Payment processors: GCash, Maya, BPI, BDO, and other payment providers receive transaction data necessary to process deposits and withdrawals
• Identity verification providers: Third-party KYC service providers process identity document data on our behalf under strict data processing agreements
• Game providers: Pragmatic Play, PG Soft, Evolution Gaming, and other licensed game developers receive anonymized session tokens — not personally identifiable information — to deliver game content
• Regulatory authorities: PAGCOR, the AMLC (Anti-Money Laundering Council), NPC, and other Philippine government agencies where required by law or court order
• IT service providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under binding contractual data protection obligations

All third parties engaged by 1apiso to process personal data are required to maintain confidentiality and to process data only in accordance with 1apiso's instructions and applicable data protection law.

08 Data Retention

1apiso retains personal data for the minimum period necessary to fulfill the purposes for which it was collected, in accordance with applicable legal obligations:

• Account and identity data: Retained for the duration of account activity plus 5 years following account closure, as required by PAGCOR licensing conditions and AMLA obligations
• KYC documents: Retained for 5 years from the date of verification or account closure, whichever is later
• Transaction records: Retained for 5 years in compliance with AMLA record-keeping requirements
• Gameplay logs: Retained for 2 years for responsible gaming monitoring and dispute resolution purposes
• Communications (support transcripts, emails): Retained for 2 years from the date of the communication
• Marketing preferences and consent records: Retained until withdrawn plus 1 year as proof of consent

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. Players may request early deletion of data that is not subject to a mandatory retention obligation under Philippine law.

09 Cookies & Tracking Technologies

The 1apiso platform uses cookies and similar technologies to deliver core functionality and improve the player experience. The categories of cookies used include:

• Strictly necessary cookies: Required for login session management, security (CSRF protection), and core platform functionality. These cannot be disabled.
• Functional cookies: Store your preferences such as language settings, game filters, and last-visited sections to personalize your experience.
• Analytics cookies: Collect anonymized data about how players navigate and use the platform, used to identify technical issues and improve usability. No personally identifiable information is captured in analytics data.

1apiso does not use third-party advertising or retargeting cookies. Cookies set by 1apiso are first-party cookies stored on your device. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will prevent the platform from functioning correctly.

10 Data Security Measures

1apiso implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Key security measures include:

• TLS 1.3 encryption for all data transmitted between your device and 1apiso servers
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records
• Multi-factor authentication (OTP) for all player login sessions
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular independent security audits and penetration testing of platform infrastructure
• Automated threat detection and anomalous activity monitoring

In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 1apiso will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay in accordance with NPC Circular No. 16-03.

11 Your Data Rights

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

• Right to be informed: The right to know what personal data we collect, why we collect it, and how it is processed — as provided in this Policy
• Right of access: The right to request a copy of the personal data we hold about you
• Right to rectification: The right to request correction of inaccurate or incomplete personal data
• Right to erasure: The right to request deletion of your personal data, subject to legal retention obligations
• Right to data portability: The right to receive your data in a structured, commonly used format for transfer to another service
• Right to object: The right to object to processing based on legitimate interest, including processing for direct marketing purposes
• Right to withdraw consent: The right to withdraw consent for any processing based on consent, at any time, without affecting the lawfulness of prior processing
• Right to complain: The right to file a complaint with the National Privacy Commission if you believe your data rights have been violated

To exercise any of these rights, contact the 1apiso Data Protection Officer at [email protected] with "Data Privacy Request" in the subject line. 1apiso will respond within 15 business days. Identity verification may be required before processing your request.

12 Children's Privacy & Age Restriction

Parents or guardians who believe that a minor has registered on the 1apiso platform should contact us immediately at [email protected]. We will investigate and close any such accounts promptly.

13 Changes to This Privacy Policy

1apiso may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or platform features. When material changes are made, we will notify registered players through one or more of the following channels: a notification displayed on the 1apiso platform upon login, an email to your registered address, or an SMS to your registered mobile number.

The effective date of the current version of this Policy is displayed at the top of this document. Continued use of the 1apiso platform after any revised Policy has been posted constitutes your acknowledgment of the changes. We encourage you to review this Policy periodically.

14 Contact & Data Protection Officer

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

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the regulatory authority for data protection matters under the Data Privacy Act of 2012.