1wen Privacy Policy

This Privacy Policy applies to all personal data collected, processed, stored, and used by 1wen ("we," "us," "the Company") in connection with the operation of the online gaming and sports betting platform accessible at 1wen.vip and any associated subdomains or services ("the Platform").

1wen is the Data Controller in respect of all personal data collected from members, prospective members, and visitors who interact with the Platform. As Data Controller, 1wen determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its Implementing Rules and Regulations.

This Policy should be read alongside the 1wen Terms & Conditions, which form part of the agreement between you and 1wen. By registering a member account or otherwise using the 1wen Platform, you acknowledge that you have read and understood this Privacy Policy.

1wen collects the following categories of personal data. The specific data points collected depend on how you interact with the Platform — not all categories apply to all users at all times.

Special Categories. 1wen does not intentionally collect special categories of personal data as defined under RA 10173 (such as health data, religious beliefs, or political affiliations) unless you voluntarily disclose such information in the context of a support interaction or responsible gaming request.

1wen collects personal data through the following means:

• Direct provision by you: Information you enter during registration, account updates, KYC submission, deposit or withdrawal forms, and communications with our support team.
• Automated technical collection: Data collected automatically when you visit or use the Platform, including IP address, device identifiers, browser fingerprint, and session activity, using server logs, cookies, and similar tracking technologies (see Section 6).
• Payment processors: Transaction confirmation data received from GCash, PayMaya, BDO, BPI, Metrobank, and other integrated payment service providers upon completion of deposit or withdrawal transactions.
• Identity verification services: Where required for KYC compliance, 1wen may use third-party identity verification providers to cross-reference the documents you submit against official records.
• PAGCOR-mandated reporting systems: Certain transaction data is reported to PAGCOR's systems as a condition of our operating license, as required by Philippine gaming regulation.

1wen processes your personal data only for specific, legitimate purposes. The following table sets out our primary processing activities and the legal basis for each under RA 10173:

Marketing Communications. If you have opted in to receive marketing communications from 1wen — including bonus offers, game recommendations, and promotional SMS — you may withdraw that consent at any time via the Preferences section of your account settings or by contacting our support team. Withdrawal of consent does not affect the lawfulness of any processing carried out prior to withdrawal.

5.1 No Sale of Personal Data. 1wen does not sell, rent, trade, or otherwise provide your personal data to third parties for their own marketing or commercial purposes. This is an unconditional commitment.

5.2 Service Providers. 1wen shares personal data with carefully selected third-party service providers who assist in the operation of the Platform, strictly under data processing agreements that prohibit those providers from using your data for their own purposes. These providers include:

• Payment processors: GCash (Mynt), PayMaya (Voyager), BDO, BPI, Metrobank, and card payment processors.
• Identity verification providers engaged to assist with KYC compliance.
• Game software providers (e.g., JILI, Pragmatic Play, PG Soft) to the extent necessary to authenticate your session and record game outcomes.
• Cloud infrastructure and hosting providers that store Platform data in secure server environments.
• Analytics providers, using anonymised or pseudonymised data only, to help 1wen understand platform usage and improve the member experience.

5.3 Regulatory Authorities. 1wen is required by Philippine law to disclose certain data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent regulatory or law enforcement bodies upon lawful request. We will notify you of such disclosures where we are legally permitted to do so.

5.4 Business Transfers. In the event of a merger, acquisition, or sale of all or substantially all of 1wen's assets, your personal data may be transferred to the acquiring entity. We will notify affected members via email or platform notification at least thirty (30) days before any such transfer takes effect, and you will retain all rights under this Policy.

6.1 What Are Cookies. Cookies are small data files placed on your device when you visit the 1wen Platform. They allow us to recognise your device on return visits, maintain your session, remember your preferences, and collect aggregated usage data to improve the Platform.

6.2 Types of Cookies Used. 1wen uses the following categories of cookies:

• Strictly Necessary Cookies: Required for the Platform to function correctly — including maintaining your login session, preventing fraud, and ensuring security. These cannot be disabled without affecting core Platform functionality.
• Functional Cookies: Remember your preferences, language settings, and game lobby configuration to personalise your experience on return visits.
• Analytics Cookies: Collect anonymised information about how members use the Platform (pages visited, session length, feature interaction) to help us identify improvements. Data is aggregated and does not identify individual members.
• Marketing Cookies: Used only with your consent to deliver relevant promotional content within the 1wen Platform. 1wen does not use marketing cookies on third-party sites for cross-site retargeting of its members.

6.3 Managing Cookies. You can manage cookie preferences via your browser settings. Note that disabling strictly necessary cookies will impair or prevent your ability to log in and use the 1wen Platform. For analytics and marketing cookies, you can also manage preferences via the Cookie Settings option available in the Platform footer.

1wen retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. Key retention periods are as follows:

• Identity and KYC Data: Retained for a minimum of five (5) years following account closure, in compliance with PAGCOR requirements and the Anti-Money Laundering Act (RA 9160).
• Transaction and Financial Records: Retained for a minimum of five (5) years following the date of each transaction, per AML and PAGCOR regulatory requirements.
• Account and Profile Data: Retained for the duration of active membership, and for two (2) years following account closure, after which it is securely deleted or anonymised.
• Support Communications: Retained for two (2) years following the resolution of a support case, unless a longer retention period is required for an ongoing dispute or legal proceeding.
• Technical and Usage Data: Anonymised after thirteen (13) months and retained in aggregated form for platform analytics purposes.
• Marketing Preferences and Consent Records: Retained for the duration of your opt-in and for three (3) years following opt-out, as evidence of consent management.

Following the expiry of the applicable retention period, personal data is either permanently deleted from 1wen's systems or irreversibly anonymised so that it can no longer be linked to an identifiable individual.

8.1 Technical Safeguards. 1wen implements the following technical security measures to protect your personal data:

• 256-bit Transport Layer Security (TLS) encryption for all data in transit between your device and 1wen's servers.
• AES-256 encryption for sensitive data at rest, including financial and identity records.
• Firewalls, intrusion detection systems, and continuous security monitoring of Platform infrastructure.
• Role-based access controls that limit employee access to personal data strictly to those with a legitimate business need.
• Regular third-party security penetration testing and vulnerability assessments.

8.2 Organisational Safeguards. All 1wen personnel with access to personal data are subject to strict confidentiality obligations and undergo mandatory data protection training. Access to production systems containing member data is logged and audited.

8.3 Data Breach Response. In the event of a personal data breach that poses a risk to your rights and freedoms, 1wen will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, in accordance with RA 10173. Affected members will be notified directly via their registered email address as soon as practicable.

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 1wen. To exercise any of these rights, contact us at [email protected]. We will acknowledge all requests within five (5) business days and respond substantively within thirty (30) days.

The 1wen Platform is strictly restricted to individuals aged twenty-one (21) years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. 1wen does not knowingly collect, process, or store personal data belonging to individuals under the age of 21.

If 1wen discovers or is notified that personal data belonging to an individual under 21 has been collected — whether as a result of misrepresentation during registration or any other cause — 1wen will immediately:

• Suspend and permanently close the relevant account;
• Return any real-money deposits to the original payment method, less applicable administrative fees; and
• Delete all personal data associated with the account from 1wen's systems, subject only to any retention obligations required by law.

Parents and guardians who believe their child may have registered on or accessed the 1wen Platform should contact our support team immediately at [email protected].

In the course of providing the 1wen Platform, certain personal data may be processed by service providers whose servers are located outside the Philippines, including game software providers and cloud infrastructure partners with data centres in Asia (e.g., Singapore, Hong Kong) and other regions.

Where personal data is transferred outside the Philippines, 1wen ensures that such transfers are made only to jurisdictions or recipients that provide an adequate level of data protection, or are subject to appropriate contractual safeguards (such as data processing agreements containing standard contractual clauses) that ensure your personal data receives protection equivalent to that afforded under RA 10173.

You may request details of the specific safeguards in place for any international transfer by contacting our Data Protection Officer at the address set out in Section 14.

The 1wen Platform may contain references to or integrations with third-party services, including payment processors and game providers. This Privacy Policy applies only to personal data processed by 1wen and does not cover the privacy practices of third parties.

Payment service providers such as GCash and PayMaya operate under their own privacy policies, which govern how they handle your financial data. 1wen recommends that you review the privacy policies of any third-party service you use in connection with the 1wen Platform.

1wen is not responsible for the privacy practices or content of any third-party services accessed in connection with the Platform.

1wen reserves the right to amend this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or Platform functionality. The effective date of the most recent version is displayed at the top of this page.

Where amendments are material — meaning they affect your rights, the categories of data we collect, or the purposes for which we use it — 1wen will provide advance notice to affected members via email or a prominent in-Platform notification at least fourteen (14) days before the changes take effect.

Continued use of the 1wen Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with any changes, you should discontinue use of the Platform and may request account closure in accordance with the 1wen Terms & Conditions.

1wen has designated a Data Protection Officer (DPO) responsible for overseeing compliance with RA 10173 and this Privacy Policy. If you have any questions, concerns, or requests relating to this Policy or the handling of your personal data, please contact us through the following:

All data privacy requests are handled by the 1wen DPO team and are treated with strict confidentiality. We will acknowledge your request within five (5) business days and provide a substantive response within thirty (30) days. For complex requests, we may extend this period by an additional thirty (30) days, with notification to you of the extension and the reasons for it.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.