Privacy Policy —
Your Data, Protected

Introduction

This Privacy Policy ("Policy") describes how no1ph ("we", "us", "our", "the Platform") collects, uses, stores, discloses, and otherwise processes personal information about individuals ("you", "Player", "User") who access or use the no1ph online gaming platform available at https://no1ph.net and all associated interfaces and services.

no1ph is committed to protecting your privacy and handling your personal data with the utmost care and transparency. This Policy is drafted in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), the issuances of the National Privacy Commission ("NPC"), and applicable PAGCOR regulatory requirements.

By registering an account on no1ph or by continuing to use the Platform after this Policy has been made available to you, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the no1ph Platform.

Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and all applicable privacy regulations, the personal information controller responsible for the processing of your data in connection with the no1ph Platform is no1ph, operating under a valid PAGCOR license in the Philippines.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact our Data Protection Officer (DPO) at: [email protected]. Please include "Privacy / DPO Request" in your subject line so that your communication is routed to the appropriate team member promptly.

no1ph maintains a Data Privacy Management Program in accordance with NPC Circular No. 16-01 and subsequent NPC issuances. This programme includes regular privacy impact assessments, staff data privacy training, and ongoing review of our data processing activities against our obligations under applicable law.

Personal Data We Collect

no1ph collects personal data from you in the following categories, depending on your interaction with the Platform:

no1ph does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive personal information (as defined under the DPA) is collected, it is processed only to the extent permitted by applicable law and with appropriate safeguards in place.

How We Use Your Personal Data

no1ph processes your personal data for the following specific, legitimate, and declared purposes:

• Account Management — To create, maintain, verify, and administer your no1ph account, including enforcing the one-account-per-person rule and managing account security.
• Identity Verification (KYC) — To verify your identity and age (21+) in compliance with PAGCOR licensing requirements and the Philippine Anti-Money Laundering Act (AMLA) and its amendments.
• Payment Processing — To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other approved channels, and to maintain accurate financial records of all transactions.
• Service Delivery — To provide you with access to casino games, sports betting markets, live dealer games, bingo, slots, and all other services available on the no1ph platform.
• Regulatory Compliance — To fulfil our obligations under applicable Philippine laws and PAGCOR regulations, including anti-money laundering reporting, suspicious transaction reporting, and responding to lawful requests from regulatory authorities.
• Fraud Prevention & Security — To detect, investigate, and prevent fraudulent activity, account compromise, bonus abuse, and other violations of our Terms and Conditions.
• Responsible Gaming — To monitor gaming activity patterns that may indicate problem gambling behaviour, enforce self-exclusion arrangements, and administer responsible gaming tools available to account holders.
• Customer Support — To respond to your enquiries, complaints, and requests through our support channels.
• Platform Improvement — To analyse aggregated and anonymised usage data to improve the performance, design, and content of the no1ph platform.
• Marketing Communications — To send you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may withdraw this consent at any time.

no1ph does not process your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your separate, explicit consent or as otherwise required by applicable law.

Sharing Your Personal Data

no1ph does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. We share your personal data only in the following limited circumstances:

• Payment Service Providers — GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment processors receive the minimum data necessary to facilitate your transactions. These providers operate under their own privacy policies and are bound by applicable Philippine financial regulations.
• Game Software Providers — Third-party game studios and live casino platform providers who supply games available on no1ph may receive anonymised or pseudonymised session data for the purposes of game performance monitoring and RNG certification. They do not receive your full identity data unless required for regulatory compliance.
• Identity Verification Services — Accredited KYC and identity verification service providers assist no1ph in verifying the authenticity of identification documents and cross-referencing against watchlists as required by AMLA.
• Regulatory Authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities may receive your personal data where disclosure is required by law, court order, or regulatory direction.
• Professional Advisers — Legal counsel, auditors, and compliance consultants engaged by no1ph may access your data on a strictly need-to-know basis and are bound by professional confidentiality obligations.
• Business Transfers — In the event of a merger, acquisition, or sale of all or substantially all of no1ph's business assets, your personal data may be transferred as part of that transaction. You will be notified of any such transfer and of any material change to the privacy terms applicable to your data prior to the transfer taking effect.

All third parties with whom no1ph shares personal data are required to process that data in accordance with applicable Philippine data privacy law and under written data processing agreements that impose confidentiality and security obligations no less protective than those applied by no1ph.

Cookies & Tracking Technologies

no1ph uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device by a website server. Cookies do not contain executable code and cannot transmit viruses or malware.

The types of cookies used by no1ph include:

• Strictly Necessary Cookies — Required for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without preventing you from using the Platform.
• Functional Cookies — Remember your preferences such as language settings, preferred game lobby view, and responsible gaming tool configurations.
• Performance & Analytics Cookies — Collect anonymised data about how Players use the Platform, which pages are visited most frequently, and where errors occur. This data is used to improve Platform performance and user experience.
• Session Management Cookies — Maintain your active login session and help enforce session time limits configured through your responsible gaming settings.

You may control cookie preferences through your browser settings. Disabling strictly necessary cookies will impair or prevent your use of the no1ph Platform. Disabling other categories of cookies will not prevent you from using the Platform but may affect personalisation features.

no1ph does not use third-party advertising or behavioural tracking cookies that profile you for the purpose of serving targeted advertisements on other websites.

Data Retention

no1ph retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, as described in this Policy, and to comply with applicable legal and regulatory retention obligations. The following general retention periods apply:

• Account and Identity Data — Retained for the duration of your active account relationship with no1ph, and for a minimum of five (5) years following permanent account closure, as required under AMLA and PAGCOR regulations.
• Financial Transaction Records — Retained for a minimum of five (5) years from the date of the relevant transaction, in compliance with AMLA requirements.
• KYC Verification Documents — Retained for the duration of the account relationship and for a minimum of five (5) years following account closure.
• Customer Support Communications — Retained for three (3) years from the date of the communication, or longer where the communication relates to an unresolved dispute or regulatory investigation.
• Gaming Activity Logs — Retained for three (3) years for responsible gaming monitoring purposes, and for up to five (5) years where required by PAGCOR or AMLA.
• Technical and Log Data — Retained for twelve (12) months for security and fraud prevention purposes, after which it is anonymised or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data disposal procedures. Where data cannot be immediately deleted due to technical constraints, it will be isolated from active processing until deletion is completed.

Security Measures

no1ph implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• Encryption of sensitive data fields at rest within our database infrastructure.
• Multi-factor authentication requirements for privileged access to internal systems handling personal data.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Continuous monitoring of our systems for anomalous activity, intrusion attempts, and data exfiltration patterns.
• Segregated storage of Player funds from operational funds, with payment systems subject to separate security controls.
• Staff data privacy and information security training on an ongoing basis.

Despite these measures, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, no1ph will notify the National Privacy Commission and affected Players in accordance with the timelines and requirements prescribed under the DPA and NPC Circular No. 16-03.

Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by no1ph:

• Right to Be Informed — You have the right to be informed that your personal data is being collected and processed, and of the purposes and basis for that processing. This Privacy Policy fulfils our obligation to inform you.
• Right of Access — You may request a copy of the personal data that no1ph holds about you, along with information about how it is processed.
• Right to Rectification — You may request correction of any inaccurate or incomplete personal data held about you. You may update certain information directly within your account settings.
• Right to Erasure or Blocking — You may request deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent, or where processing is unlawful. This right is subject to no1ph's legal retention obligations under AMLA and PAGCOR regulations.
• Right to Object — You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests where you have grounds relating to your particular situation.
• Right to Data Portability — You may request a structured, machine-readable copy of personal data you have provided to no1ph where processing is carried out by automated means.
• Right to Damages — You have the right to seek compensation for damages sustained as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data.
• Right to File a Complaint — You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Rights Request". We will acknowledge your request within 5 business days and provide a substantive response within 30 calendar days, subject to identity verification requirements.

Minors & Age Policy

The no1ph Platform is strictly intended for adults aged 21 years and above, in accordance with the minimum legal age for casino-style gambling and sports betting under PAGCOR regulations and applicable Philippine law. no1ph does not knowingly collect personal data from individuals below the age of 21.

Age verification is a mandatory component of the no1ph account registration and KYC process. Any account found to belong to a person under 21 years of age will be immediately suspended, all balances will be returned to the source of deposit where technically possible, and the matter will be reported to PAGCOR in accordance with our regulatory obligations.

If you believe that a minor has registered on no1ph, or if you are a parent or guardian who has discovered that a person under 21 in your household has accessed the Platform, please contact us immediately at [email protected] so that we can take prompt action.

International Data Transfers

no1ph's primary data processing infrastructure is located within the Philippines. However, certain third-party service providers engaged by no1ph — including game software suppliers, cloud infrastructure providers, and security monitoring services — may process data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, no1ph ensures that such transfers comply with Section 21 of the Data Privacy Act of 2012 and the NPC's guidelines on cross-border data flows. Specifically, no1ph will only transfer personal data to jurisdictions or recipients that provide a comparable level of data protection, or where appropriate contractual safeguards (such as NPC-approved standard contractual clauses) are in place.

You may request information about the specific countries to which your personal data may be transferred and the safeguards applicable to those transfers by contacting our DPO at [email protected].

Changes to This Privacy Policy

no1ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory guidance. The effective date at the top of this Policy will be updated whenever material changes are made.

Where changes are material — meaning they significantly affect your rights or the way your personal data is processed — no1ph will notify active account holders via the email address registered on their account at least 14 days prior to the changes taking effect. The updated Policy will also be prominently displayed on the Platform upon login.

Your continued use of the no1ph Platform following the effective date of any revised Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with the revised Policy, you must cease using the Platform and may request account closure in accordance with the Terms and Conditions.

Contact & Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise any of your data privacy rights, or wish to raise a data privacy concern, you may contact the no1ph Data Protection Officer at the following:

Email: [email protected] (subject line: "Privacy / DPO Request")

Our DPO will acknowledge receipt of all privacy-related communications within 5 business days. We aim to resolve all requests within 30 calendar days, though complex requests may require additional time, in which case we will notify you of the extended timeline and the reason for it.

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about the NPC's complaint process is available through the NPC's official channels.