peso1 Privacy Policy — How We Protect Your Personal Data

1. Scope and Application

This Privacy Policy governs the collection, use, storage, and disclosure of personal data by peso1 (the "Operator," "we," "us," or "our") in connection with all online casino, sports betting, and ancillary services offered through the peso1.cam website and associated mobile applications (collectively, the "Services"). This Policy applies to all Players, registered Account holders, prospective users, and any individual whose personal data we process in the course of operating our Services.

peso1 operates under a valid license issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and is fully subject to the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR). This Policy has been designed to meet or exceed all applicable requirements of the DPA, the National Privacy Commission (NPC) regulations, and PAGCOR's player protection standards.

2. Personal Data We Collect

2.1 Identity and Contact Information

When you register an Account with peso1, we collect personal data necessary to verify your identity and comply with regulatory Know Your Customer (KYC) requirements. This includes your full legal name as it appears on government-issued identification, date of birth, nationality, residential address (including barangay, city, province, and postal code), valid Philippine mobile number, and email address.

2.2 Verification Documents

To fulfill PAGCOR licensing obligations and Anti-Money Laundering Act (AMLA) compliance, peso1 may collect copies of government-issued photo identification such as a Philippine passport, Driver's License, SSS/GSIS card, PhilSys national ID, Voter's ID, or other NPC-recognized primary identification documents. We may also collect proof of address documents such as utility bills, bank statements, or barangay certificates dated within the last three months.

2.3 Financial and Transaction Data

peso1 collects financial information necessary to process deposits, withdrawals, and comply with AMLA reporting requirements. This includes GCash wallet numbers, Maya account details, bank account numbers and account names for BPI, BDO, Metrobank, UnionBank, and other Philippine banks, cryptocurrency wallet addresses, transaction amounts, timestamps, and references. We do not store full credit or debit card numbers, CVV codes, or online banking credentials.

2.4 Gaming Activity Data

We collect comprehensive gaming activity data for operational, regulatory, and responsible gaming purposes. This encompasses game history, wager amounts, win and loss records, session durations, bonus usage and wagering progress, sports betting selections and outcomes, and account balance history. This data is retained for a minimum of five years as required by PAGCOR regulations and AMLA compliance obligations.

2.5 Technical and Device Data

When you access peso1 Services, we automatically collect certain technical data including IP address, geolocation data (country, region, and city level), device type and model, operating system and version, browser type and version, unique device identifiers, mobile network information, and session activity logs. This data is collected for security monitoring, fraud prevention, geolocation compliance, and platform optimization.

2.6 Communications Data

We retain records of all communications between you and peso1, including live chat transcripts, email correspondence, support ticket history, and feedback submissions. These records are maintained for quality assurance, dispute resolution, and regulatory compliance purposes.

3. How We Collect Your Data

peso1 collects personal data through the following means:

• Account Registration: Information provided directly by you when creating or updating your Account profile.
• KYC Verification Process: Documents and information submitted during identity and age verification, including at first withdrawal.
• Financial Transactions: Data provided during deposit, withdrawal, and payment processing activities.
• Gameplay Activity: Automatically generated data as you interact with games and betting features on the platform.
• Cookies and Tracking Technologies: Automated data collection through cookies, web beacons, pixel tags, and similar technologies as described in Section 6.
• Customer Support Interactions: Data shared through live chat, email, and other support channels.
• Third-Party Payment Processors: Transaction confirmation and account verification data received from GCash, Maya, BPI, BDO, and other approved payment providers.
• Anti-Fraud and Monitoring Systems: Data generated by automated fraud detection and responsible gaming monitoring tools.

4. Purposes and Legal Basis for Processing

4.1 Contractual Necessity

peso1 processes personal data that is strictly necessary to fulfill our contractual obligations to you as described in our Terms & Conditions. This includes creating and managing your Account, processing deposits and withdrawals, providing gaming services, handling disputes, and delivering customer support. Without this processing, we cannot provide the Services.

4.2 Legal and Regulatory Compliance

We process personal data to comply with applicable Philippine laws and PAGCOR licensing requirements. Mandatory processing activities include age verification (minimum 21 years under Philippine law), identity verification, anti-money laundering (AML) monitoring and reporting, responsible gaming compliance, tax reporting obligations, and regulatory audit obligations. This processing is mandatory and cannot be opted out of while using peso1 Services.

4.3 Legitimate Interests

peso1 processes certain data on the basis of legitimate interests, balanced against your rights and expectations. These interests include fraud prevention and security monitoring, improvement of platform performance and user experience, responsible gaming pattern detection, customer service quality assurance, and resolution of disputes. Where we rely on legitimate interests, we have assessed that our interests do not override your fundamental privacy rights.

4.4 Consent-Based Processing

For processing activities not covered by the above bases — such as marketing communications, optional surveys, and personalized game recommendations — peso1 relies on your explicit, freely given, informed, and specific consent. You may withdraw consent at any time through your Account preferences or by contacting our Data Privacy Officer. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

5. Data Sharing and Disclosure

5.1 Service Providers and Processors

peso1 shares personal data with trusted third-party service providers who assist in operating our Services, subject to strict data processing agreements ensuring they handle data only as instructed and in compliance with the DPA. Categories of processors include identity verification providers, payment processors and e-wallet operators, game technology providers and studios, cloud infrastructure and hosting providers, cybersecurity and fraud prevention services, and customer support technology platforms.

5.2 Regulatory and Law Enforcement Authorities

peso1 is required by Philippine law to disclose personal data to regulatory authorities including PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), the National Privacy Commission (NPC), and law enforcement agencies when lawfully requested. Such disclosures are made in strict compliance with applicable legal requirements and only to the extent necessary to fulfill our obligations.

5.3 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of substantially all of peso1's assets, your personal data may be transferred to the relevant third party as part of that transaction, subject to continued compliance with this Privacy Policy and Philippine data protection laws. You will be notified of any such change via email or prominent notice on the Website prior to the transfer.

5.4 No Sale of Personal Data

peso1 does not sell, rent, or lease your personal data to third parties for their independent marketing or commercial purposes. Any sharing of data is conducted strictly for operational, legal, or regulatory purposes as described in this Policy.

6. Cookies and Tracking Technologies

6.1 Types of Cookies Used

peso1 uses the following categories of cookies and similar tracking technologies on our Website and applications:

• Strictly Necessary Cookies: Essential for platform operation, user authentication, security, and fraud prevention. These cannot be disabled.
• Performance Cookies: Collect anonymized data on how Players use the platform to help us improve loading speed, navigation, and game performance.
• Functional Cookies: Remember your preferences such as language settings, default view options, and recently played games.
• Analytics Cookies: Help us understand overall usage patterns, traffic sources, and Player engagement through aggregated, anonymized reporting.
• Responsible Gaming Cookies: Track session duration and activity to support responsible gaming features like reality check notifications and session limit enforcement.

6.2 Managing Cookies

You may manage non-essential cookie preferences through your browser settings or our cookie preference center accessible via the Website. However, disabling strictly necessary cookies will impair the functionality of peso1 Services and may prevent you from accessing your Account.

7. Data Retention and Deletion

peso1 retains personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. Our standard retention periods are:

• Account and Identity Data: Duration of Account activity plus five (5) years after Account closure, as required by PAGCOR and AMLA regulations.
• Financial Transaction Records: Ten (10) years from transaction date as required by Philippine tax and anti-money laundering laws.
• Gaming Activity Logs: Five (5) years from date of activity as required by PAGCOR licensing conditions.
• Customer Support Records: Three (3) years from date of last interaction, or longer if related to an unresolved dispute or legal proceeding.
• Marketing Consent Records: Until you withdraw consent plus one (1) year for audit purposes.
• Technical and Device Logs: Twelve (12) months from collection, or longer if flagged in connection with a security investigation.

Upon expiry of applicable retention periods, peso1 securely destroys or anonymizes personal data such that it can no longer be attributed to any individual. Anonymized data may be retained indefinitely for statistical and research purposes without constituting personal data processing under the DPA.

8. Data Security Measures

peso1 employs a comprehensive, layered security framework to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Encryption: All data in transit is protected by 256-bit SSL/TLS encryption. Sensitive data at rest, including financial credentials and identity documents, is encrypted using AES-256 encryption standards.
• Access Controls: Personal data is accessible only to peso1 employees and contractors who require it for legitimate business purposes, governed by role-based access control (RBAC) policies and enforced through multi-factor authentication (MFA).
• Infrastructure Security: Our servers are hosted in certified data centers with physical access controls, 24/7 monitoring, redundant power systems, and regular security audits.
• Penetration Testing: We conduct regular third-party penetration tests and vulnerability assessments to identify and remediate potential security weaknesses before they can be exploited.
• Incident Response: A formal data breach response plan is in place. In the event of a breach, we will notify the National Privacy Commission within 72 hours and affected individuals within a reasonable time as required by NPC Circular 16-03.
• Employee Training: All peso1 employees with access to personal data receive mandatory data privacy training and are bound by confidentiality agreements.

9. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you hold the following rights with respect to your personal data processed by peso1:

• Right to Be Informed: The right to know that your personal data is being collected and processed, the purposes of processing, and your rights as a data subject — which is the purpose of this Policy.
• Right to Access: The right to request a copy of your personal data held by peso1 and information about how it is being processed, within 15 business days of your request.
• Right to Correction: The right to request correction of inaccurate, incomplete, or outdated personal data in your Account. Minor corrections can be made directly through Account settings; others require verification.
• Right to Erasure or Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations. Note that data subject to PAGCOR, AMLA, or BIR retention requirements cannot be deleted until mandatory periods expire.
• Right to Object: The right to object to processing of your personal data for direct marketing, automated profiling, or purposes not covered by legitimate interest or contractual necessity.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission if you believe peso1 has violated your data privacy rights.
• Right to Damages: The right to claim compensation for damages suffered as a result of inaccurate, incomplete, false, unlawfully obtained, or improperly used personal data.

To exercise any of the above rights, submit a written request to our Data Privacy Officer at [email protected]. We will acknowledge receipt within 48 hours and respond substantively within fifteen (15) business days.

10. Children's Privacy

peso1 Services are strictly intended for individuals who are at least twenty-one (21) years of age, as required by PAGCOR regulations and Philippine gaming law. We do not knowingly collect personal data from individuals below this age. Our registration process requires age verification and collection of government-issued identification to enforce this requirement.

If we become aware that personal data has been collected from an individual below twenty-one (21) years of age, we will immediately suspend the relevant Account, securely delete all associated data, and void any transactions conducted. If you believe a minor has registered with peso1, please notify us immediately at [email protected] so we can take prompt action.

11. Cross-Border Data Transfers

In the course of providing Services, peso1 may transfer personal data to service providers and technology partners located outside the Republic of the Philippines, including game studios, cloud infrastructure providers, and cybersecurity firms based in other countries.

Any such cross-border transfer is conducted only where: (a) the receiving country provides an adequate level of data protection as determined by the NPC; (b) appropriate safeguards are in place through standard contractual clauses or binding corporate rules; or (c) the transfer is necessary for the performance of a contract to which you are a party. peso1 maintains a register of all cross-border data flows and subjects all international processors to equivalent data protection standards.

12. Amendments to This Policy

peso1 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, technological developments, legal requirements, or PAGCOR regulatory guidance. The "Effective Date" at the top of this Policy will be updated to reflect the date of the most recent revision.

When we make material changes to this Policy, we will notify you via email to your registered address and post a prominent notice on the Website. Your continued use of peso1 Services following notification constitutes your acceptance of the revised Policy. If you do not agree to the updated terms, you must discontinue use of the Services.

13. Contact Our Data Privacy Officer

For any questions, concerns, complaints, or requests related to this Privacy Policy or your personal data rights, please contact the peso1 Data Privacy Officer (DPO):

• Email: [email protected] (subject line: "Data Privacy Request")
• Live Chat: Available 24/7 on the peso1.cam Website
• Response Time: Acknowledgment within 48 hours; substantive response within 15 business days

You also have the right to file a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

Acknowledgment: By using peso1 Services, you confirm that you have read, understood, and freely consented to the collection and processing of your personal data as described in this Privacy Policy. This Policy is read together with and forms part of the peso1 Terms & Conditions.