1phdream Privacy Policy – Your Data, Your Rights

This Privacy Policy ("Policy") is issued by 1phdream ("we," "us," "our," or "the Platform") and applies to all personal data collected through the 1phdream website at 1phdream.club, our mobile application, and any related services we provide to registered players and visitors in the Philippines. This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as administered by the National Privacy Commission ("NPC") of the Philippines.

1. Introduction & Scope

At 1phdream, we recognize that your personal information is valuable and that you have a right to know how it is handled. This Policy describes our practices regarding the collection, use, storage, sharing, and protection of personal data in connection with your use of the 1phdream platform.

This Policy applies to:

• All registered players with a 1phdream account;
• Visitors who browse the 1phdream website without registering;
• Individuals who contact 1phdream customer support;
• Any person whose personal data is processed by 1phdream in connection with the provision of our services.

By accessing the 1phdream platform or creating an account, 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. If you do not agree with this Policy, please discontinue use of the platform immediately.

2. Data Controller Information

1phdream acts as the Personal Information Controller ("PIC") with respect to the personal data of its users, as defined under the Data Privacy Act of 2012. As PIC, 1phdream determines the purposes and means of processing personal data collected through the platform.

Our designated Data Protection Officer ("DPO") can be reached at [email protected] with the subject line "Privacy Request." The DPO is responsible for ensuring compliance with the DPA and serving as the primary point of contact for data subject inquiries and complaints.

3. Personal Data We Collect

1phdream collects the following categories of personal data in connection with the operation of the platform:

3.1 Identity & Contact Information

• Full legal name as it appears on government-issued identification;
• Date of birth and age verification data;
• Philippine mobile number and email address;
• Residential address within the Philippines;
• Government-issued identification numbers (e.g., PhilSys ID, Passport, Driver's License, UMID).

3.2 Financial & Transaction Data

• GCash or PayMaya account details used for deposits and withdrawals;
• Bank account details for bank transfer transactions (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank);
• Debit card details where applicable;
• Transaction history, including deposit amounts, withdrawal requests, and timestamps;
• Account balance and bonus wallet information.

3.3 Gaming & Behavioral Data

• Game session records, including games played, wagers placed, and outcomes;
• Login timestamps, session durations, and platform activity logs;
• Responsible gaming tool usage, including deposit limits and self-exclusion records;
• Customer support interaction records and complaint history.

3.4 Technical & Device Data

• IP address and approximate geolocation data;
• Device type, operating system, and browser information;
• Cookie identifiers and session tokens;
• Referral source and navigation path data.

We do not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect biometric data, health information, or political affiliations.

4. How We Collect Your Data

1phdream collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, or contacting customer support;
• Automated collection: Technical data collected automatically when you access the platform, including cookies, log files, and device fingerprinting;
• Third-party sources: Identity verification data from KYC service providers; fraud detection signals from payment processors; regulatory data from PAGCOR and the Anti-Money Laundering Council (AMLC) where required by law.

5. Purposes & Legal Basis for Processing

1phdream processes your personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of 2012:

Purpose	Data Used	Legal Basis
Account registration and management	Identity, contact data	Contractual necessity
KYC identity verification	Government ID, date of birth	Legal obligation (PAGCOR, AMLC)
Processing deposits and withdrawals	Financial data, transaction records	Contractual necessity
Fraud prevention and security monitoring	Technical data, transaction data	Legitimate interest / Legal obligation
Regulatory reporting (PAGCOR, AMLC)	Identity, financial, gaming data	Legal obligation
Responsible gaming compliance	Gaming data, self-exclusion records	Legal obligation / Legitimate interest
Customer support and dispute resolution	All relevant data	Contractual necessity
Platform analytics and improvement	Behavioral, technical data	Legitimate interest
Promotional communications (with consent)	Contact data	Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Cookies & Tracking Technologies

The 1phdream platform uses cookies and similar tracking technologies to enhance your experience and ensure the platform functions correctly. The types of cookies we use include:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication tokens and security cookies. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations.
• Analytics Cookies: Collect anonymized data about how users interact with the platform to help us improve performance and user experience.
• Security Cookies: Used for fraud detection, bot prevention, and account security monitoring.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 1phdream platform. We do not use cookies to serve third-party advertising or to track your activity across unrelated websites.

7. Data Sharing & Disclosure

1phdream does not sell, rent, or trade your personal data to third parties for commercial or marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

7.1 Service Providers

We engage third-party service providers to assist in operating the 1phdream platform, including KYC verification providers, payment processors (GCash, PayMaya, and banking partners), cloud hosting providers, and customer support platforms. These providers are contractually bound to process your data only as instructed by 1phdream and in compliance with the DPA.

7.2 Regulatory Authorities

We are required by law to disclose certain personal and financial data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities upon lawful request or as mandated by applicable regulations.

7.3 Legal & Security Purposes

We may disclose personal data where necessary to enforce our Terms and Conditions, prevent fraud, investigate suspected illegal activity, or protect the rights, property, or safety of 1phdream, our players, or the public.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 1phdream's assets, personal data held by the platform may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

8. International Data Transfers

The 1phdream platform is operated primarily within the Philippines. Where personal data is transferred to service providers located outside the Philippines, 1phdream ensures that such transfers are conducted in compliance with Section 21 of the Data Privacy Act of 2012 and the NPC's guidelines on cross-border data transfers. We require all international recipients to maintain data protection standards equivalent to those required under Philippine law.

9. Data Retention

1phdream retains personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Specific retention periods include:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction;
• Customer support records: Retained for three (3) years from the date of the interaction;
• Gaming session logs: Retained for two (2) years from the date of the session;
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year thereafter.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with NPC-approved data disposal procedures.

10. Security Measures

1phdream implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption in transit: All data transmitted between your device and the 1phdream platform is protected using TLS 1.2 or higher encryption;
• Encryption at rest: Sensitive personal and financial data stored on our servers is encrypted using AES-256 or equivalent standards;
• Access controls: Access to personal data is restricted to authorized personnel on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication;
• Intrusion detection: Our infrastructure is monitored 24/7 for suspicious activity, unauthorized access attempts, and anomalous behavior;
• Regular security audits: We conduct periodic vulnerability assessments and penetration testing to identify and remediate security weaknesses;
• Staff training: All 1phdream personnel with access to personal data receive regular data privacy and security training;
• Incident response: We maintain a documented data breach response plan and will notify affected data subjects and the NPC within 72 hours of discovering a breach that poses a real risk of serious harm, as required by the DPA.

While we take every reasonable precaution to protect your data, no system is completely immune to security risks. We encourage you to use a strong, unique password for your 1phdream account and to enable two-factor authentication where available.

11. Your Data Subject Rights

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

• Right to be Informed: You have the right to know what personal data we collect, how it is used, and with whom it is shared — which is the purpose of this Privacy Policy;
• Right to Access: You may request a copy of the personal data we hold about you, along with information about how it is being processed;
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you;
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to Object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interest;
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: You have the right to file a complaint with the National Privacy Commission (NPC) if you believe 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 Subject Rights Request." We will respond to all verified requests within fifteen (15) business days of receipt. We may require proof of identity before processing your request to protect against unauthorized access to your data.

12. Children's Privacy

The 1phdream platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine law and PAGCOR regulations governing online gaming. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and return any deposited funds to the original payment source. If you believe a minor has registered on the 1phdream platform, please notify us immediately at [email protected].

13. Changes to This Policy

1phdream reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will:

• Post the updated Policy on the 1phdream website with a revised effective date;
• Send a notification to your registered email address where the changes are significant;
• Display a prominent notice on the platform for a period of at least thirty (30) days following the update.

Your continued use of the 1phdream platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

14. Contact & DPO Details

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 1phdream, please contact us through the following channel:

• Email: [email protected]
• Subject Line: "Privacy Request" or "Data Subject Rights Request"
• Response Time: Within fifteen (15) business days for data subject rights requests; within one (1) business day for general privacy inquiries
• Support Hours: 24 hours a day, 7 days a week

For unresolved complaints, you may also contact the National Privacy Commission (NPC) of the Philippines through official NPC channels. The NPC is the independent government body responsible for administering and implementing the Data Privacy Act of 2012.