Privacy Policy

01Introduction

peso1 ("peso1," "we," "us," or "our") takes the privacy of its users seriously. This Privacy Policy is a formal declaration of how peso1 handles personal data belonging to individuals who access peso1.app, register an account, make deposits, place wagers, or otherwise interact with the peso1 Platform (the "Platform").

The Philippines' Data Privacy Act of 2012 (RA 10173) — overseen by the National Privacy Commission (NPC) — is the primary legal framework governing peso1's data processing activities. peso1 processes personal data only for lawful purposes, in accordance with the principles of transparency, legitimate purpose, and proportionality as defined under RA 10173.

This Policy applies to all personal data collected through the Platform, through customer support interactions, through marketing communications where applicable, and through any verification processes required under PAGCOR regulations and Philippine anti-money laundering law.

02Data Controller

For the purposes of the Data Privacy Act of 2012, peso1 is the Personal Information Controller (PIC) with respect to all personal data collected through the Platform. peso1 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with RA 10173 and its Implementing Rules.

peso1 has designated a Data Protection Officer (DPO) in accordance with Section 21 of the Implementing Rules and Regulations of RA 10173. The DPO is responsible for overseeing compliance with this Policy and applicable data protection law. Contact details for the DPO are provided in Section 14 of this Policy.

03Data We Collect

3.1 Data You Provide Directly

When you register, verify your identity, make a deposit, request a withdrawal, or contact support, peso1 collects personal data including:

• Identity data: full legal name, date of birth, nationality;
• Contact data: registered Philippine mobile number, email address;
• Identity verification documents: government-issued ID (e.g., Philippine passport, driver's license, Unified Multi-Purpose ID), selfie photographs, proof of address;
• Financial data: GCash or PayMaya account number, bank account details, transaction history on the Platform;
• Account credentials: username and hashed password (never stored in plaintext).

3.2 Data Collected Automatically

When you access the Platform, peso1's systems automatically record:

• Device and technical data: device type, operating system, browser type and version, screen resolution;
• Network data: IP address, approximate geolocation derived from IP;
• Usage data: pages visited, games played, session duration, click paths, login timestamps;
• Cookie and tracking data: as described in Section 9 of this Policy.

3.3 Data from Third Parties

peso1 may receive personal data from third-party identity verification providers, payment processors (including GCash and PayMaya), fraud detection services, and PAGCOR where required by regulation. Such data is processed solely for the purposes described in Section 4.

04Purpose of Processing

peso1 processes personal data only for the following lawful and specific purposes:

Purpose	Data Used
Account registration and authentication	Identity data, contact data, credentials
Identity verification (KYC) and age confirmation	Identity documents, selfie, date of birth
Processing deposits and withdrawals	Financial data, identity data
Anti-money laundering (AML) compliance	Identity data, transaction history
PAGCOR regulatory reporting	As required by regulation
Fraud detection and prevention	Device data, network data, usage data
Customer support and dispute resolution	Contact data, transaction data, communication records
Responsible gaming enforcement	Usage data, account data, self-exclusion status
Platform analytics and improvement	Usage data, device data (aggregated/anonymised)
Marketing communications (where consent given)	Contact data, gameplay preferences

peso1 does not use personal data for any purpose not listed above without first obtaining additional consent or establishing a separate lawful basis under RA 10173.

05Legal Basis for Processing

Under RA 10173, peso1 processes personal data on the following legal bases:

• Consent: For marketing communications and cookie-based tracking beyond strictly necessary functions. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Contractual necessity: For processing required to fulfill peso1's obligations to you under the Terms & Conditions — including account management, payment processing, and game delivery.
• Legal obligation: For processing required to comply with PAGCOR regulations, Philippine AML law (Republic Act No. 9160 as amended), NPC requirements, and any other applicable Philippine law.
• Legitimate interests: For fraud prevention, platform security, and internal analytics — where these interests are not overridden by your privacy rights.

06Sharing Your Data

6.1 Authorized Third-Party Processors

peso1 engages third-party service providers ("Personal Information Processors" under RA 10173) who process data on peso1's behalf under written data processing agreements. These include: payment processors (GCash operator Mynt, PayMaya/Maya Bank), identity verification providers, cloud hosting infrastructure providers, game platform providers, and fraud detection technology vendors.

All third-party processors are contractually required to process personal data only as instructed by peso1, to implement appropriate security measures, and to comply with applicable Philippine data protection law.

6.2 Regulatory Disclosure

peso1 may be required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, Philippine law enforcement authorities, or courts of competent jurisdiction, where such disclosure is required by law or valid legal process.

6.3 No Sale of Personal Data

peso1 does not sell, rent, or trade your personal data to any third party for their own marketing purposes. Personal data is shared only as described in this Section and only to the extent necessary for the stated purpose.

07Data Retention Periods

peso1 retains personal data only for as long as necessary for the purposes described in this Policy, or as required by applicable law. Key retention periods are:

• Account data: For the duration of your active account, plus a minimum of five (5) years after account closure, as required under Philippine AML regulations;
• KYC and identity verification documents: Minimum five (5) years from the date of collection or from last transaction, whichever is later;
• Transaction records: Minimum five (5) years from the date of each transaction;
• Customer support records: Three (3) years from the date of the interaction, or longer if related to an unresolved dispute;
• Marketing consent records: Until consent is withdrawn, plus a reasonable period thereafter to evidence the withdrawal;
• Technical/log data: Up to twelve (12) months from collection, unless required for longer by active fraud investigation or legal proceedings.

08Security Measures

peso1 implements technical and organisational security measures designed to protect personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data in transit between your device and peso1's servers;
• AES-256 encryption for sensitive data at rest in peso1's databases;
• One-way cryptographic hashing (bcrypt) for password storage — no plaintext passwords are ever stored;
• Role-based access controls limiting internal staff access to personal data on a need-to-know basis;
• Multi-factor authentication required for all internal administrative access;
• Regular penetration testing and security audits by independent third parties;
• Comprehensive incident response procedures, including NPC breach notification within 72 hours where required.

Notwithstanding the foregoing, no electronic transmission or storage system can be guaranteed to be 100% secure. You are responsible for maintaining the security of your own account credentials.

09Cookies & Tracking Technologies

peso1 uses cookies and similar technologies (collectively, "cookies") to operate the Platform, remember your preferences, maintain your session, detect fraud, and analyze Platform usage. Cookies are small text files stored on your device by your browser.

Types of Cookies Used

• Strictly necessary cookies: Required for core Platform functions including authentication, session management, and security. These cannot be disabled without disrupting Platform functionality.
• Functional cookies: Remember your language and display preferences to personalize your experience.
• Analytics cookies: Collect aggregated, anonymized data about how users interact with the Platform to help peso1 improve performance and usability.
• Fraud prevention cookies: Help identify and prevent suspicious activity by tracking device and behavioral signals.

You can configure your browser to refuse or delete cookies, though doing so may affect the functionality of the peso1 Platform. Analytics cookies require your consent and can be declined without affecting core Platform features.

10Minors

11Your Rights Under RA 10173

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by peso1:

To exercise any of the above rights, contact peso1's Data Protection Officer using the details in Section 14. peso1 will respond to verified data subject requests within thirty (30) calendar days of receipt, or within such extended period as permitted under RA 10173 where the request is complex or numerous.

12International Data Transfers

Some of peso1's third-party service providers — including cloud infrastructure and game platform vendors — may be located outside the Philippines. Where personal data is transferred internationally, peso1 ensures that such transfers are subject to appropriate safeguards, including contractual data transfer agreements that impose data protection obligations equivalent to those under RA 10173. peso1 does not transfer personal data to jurisdictions without adequate data protection frameworks without implementing these contractual safeguards.

13Changes to This Privacy Policy

peso1 reserves the right to update this Privacy Policy at any time to reflect changes in law, regulatory guidance, or peso1's data processing practices. Material changes will be communicated to registered users via notification to your registered mobile number or through a prominent notice on the Platform. The updated Policy will be effective from the date stated in the Meta section at the top of this document.

Your continued use of the peso1 Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree to the updated Policy, you must stop using the Platform and may request account closure in accordance with peso1's Terms & Conditions.

14Contact & NPC Complaints

For any privacy-related queries, to exercise your data subject rights, or to contact peso1's Data Protection Officer, please reach out via:

• Email (DPO): [email protected]
• Live Chat: Available 24/7 via the Platform for registered users
• Platform: peso1.app

peso1 aims to resolve all privacy concerns promptly and in good faith. If you believe your concern has not been adequately addressed, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which has supervisory authority over the Data Privacy Act of 2012.

This Privacy Policy was last reviewed and updated on 1 January 2026. All prior versions are superseded by this document.