Privacy Policy

1 Introduction & Scope

1plush is committed to protecting the privacy and personal data of every individual who interacts with our platform. This Policy applies to all personal data processed in connection with the 1plush online gaming platform, including data collected during account registration, gameplay, deposits and withdrawals, promotional participation, and customer support interactions.

This Policy applies to all users of 1plush regardless of the device or browser used to access the platform. It applies equally to Filipino players accessing the platform from Manila, Cebu, Davao, Quezon City, Makati, and all other parts of the Philippines, as well as any other users permitted to access the platform under applicable law.

By registering a 1plush account or continuing to use the platform after this Policy has been made available to you, you acknowledge that you have read and understood its contents. If you do not agree with any part of this Policy, you should discontinue use of the platform and contact the 1plush support team to close your account.

This Policy should be read alongside the 1plush Terms & Conditions, which together form the complete agreement governing your use of the 1plush platform.

2 Data Controller & Data Protection Officer

For the purposes of the Data Privacy Act of 2012, 1plush is the data controller responsible for the personal data collected through the 1plush platform. As data controller, 1plush determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data privacy law.

1plush has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and with the Data Privacy Act of 2012 and its implementing rules. The DPO serves as the primary point of contact for all data privacy matters, including data subject rights requests, privacy complaints, and regulatory enquiries from the National Privacy Commission (NPC).

3 Personal Data We Collect

1plush collects the following categories of personal data from players and platform visitors. The specific data points collected may vary depending on the stage of your relationship with the platform and the services you use.

1plush does not intentionally collect special categories of sensitive personal data (such as health information, religious beliefs, or political opinions) unless directly relevant to a responsible gaming assessment or a legal obligation. Where such data is collected, explicit consent will be obtained.

4 How We Collect Your Personal Data

1plush collects personal data through the following methods:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, respond to a survey, or participate in a promotion.
• Automatically through platform use — through cookies, web server logs, and similar technologies as you browse and interact with the 1plush website and platform. See Section 8 for more detail on cookies.
• From identity verification providers — when we use third-party KYC and anti-fraud services to verify the identity documents you submit during the KYC process.
• From payment processors — when you transact via GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, InstaPay, or PESONet, limited transaction confirmation data may be shared with us by the payment service provider.
• From regulatory and fraud prevention sources — in certain circumstances, 1plush may receive or verify data from PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine regulatory bodies as required by law.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, 1plush is required to have a lawful basis for each instance of personal data processing. The primary legal bases on which 1plush relies are:

• Performance of a contract — processing your identity, contact, and financial data is necessary to register your account, process transactions, and provide the gaming services described in the 1plush Terms & Conditions.
• Compliance with a legal obligation — processing for KYC, anti-money laundering checks, and regulatory reporting is required by Philippine law, PAGCOR standards, and AMLC regulations.
• Legitimate interests — processing technical and gaming activity data to maintain platform security, prevent fraud, improve services, and conduct analytics. 1plush performs a balancing test to ensure its legitimate interests do not override your rights.
• Consent — processing for marketing communications and optional cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6 How We Use Your Personal Data

1plush uses the personal data it collects for the following purposes:

• To create, verify, and manage your 1plush player account.
• To carry out KYC identity verification as required by PAGCOR and Philippine anti-money laundering regulations.
• To process deposits and withdrawals in Philippine Peso via your chosen payment method.
• To operate and administer games including Slots, Bingo, Dragon and Tiger, Mines Grand, and live dealer titles.
• To detect, investigate, and prevent fraud, cheating, collusion, and other prohibited conduct.
• To comply with legal and regulatory reporting obligations to PAGCOR, the AMLC, and other Philippine authorities.
• To provide customer support and respond to your queries, complaints, and feedback.
• To send you transactional communications (account notices, security alerts, KYC status updates) that are necessary to maintain your account.
• To send you promotional and marketing communications where you have opted in to receive them.
• To administer responsible gaming tools including deposit limits, session reminders, cooling-off periods, and self-exclusion.
• To improve platform performance, game quality, and user experience through analytics and testing.

1plush does not use personal data for automated decision-making that produces legal or similarly significant effects without human review, except where such processing is required by law or by PAGCOR regulatory requirements.

7 Sharing Your Personal Data

1plush does not sell, rent, or trade your personal data to any third party for their own commercial purposes. Your personal data may be shared with the following categories of recipients strictly on a need-to-know basis and only to the extent necessary to deliver the services you use:

• Payment processors — GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, InstaPay, and PESONet operators require limited transactional data to process your deposits and withdrawals.
• KYC and identity verification providers — third-party services engaged by 1plush to verify government-issued identity documents as part of the KYC process. These providers are contractually bound to process data only for KYC purposes.
• Fraud prevention and anti-money laundering services — specialist providers that assist 1plush in screening transactions and player activity for financial crime indicators.
• Technology and infrastructure providers — cloud hosting, platform software, and cybersecurity vendors who process data on 1plush's behalf under data processing agreements that impose strict confidentiality and security obligations.
• Regulatory and law enforcement authorities — PAGCOR, the AMLC, the National Privacy Commission, Philippine law enforcement agencies, and courts, where disclosure is required by law or by a valid legal order.
• Game content providers — where a game title is provided by a licensed third-party studio, limited session and stake data may be shared with that provider for game delivery and integrity purposes.

8 Cookies & Tracking Technologies

The 1plush platform uses cookies and similar technologies (including web beacons and local storage) to operate core platform functions and to improve your experience. The following categories of cookies are used:

• Strictly necessary cookies — essential for the platform to function. These include session management cookies that keep you logged in during your visit and security cookies that protect against cross-site request forgery. These cannot be disabled without breaking core platform functionality.
• Performance and analytics cookies — collect aggregated, anonymised data about how players navigate and use the platform. This data helps 1plush identify and fix technical issues, understand popular game categories, and prioritise product improvements.
• Functional cookies — remember your preferences such as language settings, display preferences, and responsible gaming tool configurations so you do not need to reset them on every visit.
• Marketing cookies — used only where you have consented, to measure the effectiveness of 1plush promotional campaigns and to avoid showing you the same promotional content repeatedly.

You may manage your cookie preferences through your browser settings at any time. Note that disabling strictly necessary cookies will impair your ability to use the 1plush platform. Disabling other categories of cookies will not prevent you from using core platform features but may affect certain personalisation and convenience functions.

9 Data Retention

1plush retains personal data only for as long as necessary to fulfil the purposes for which it was collected, and in accordance with applicable Philippine legal and regulatory retention requirements. The following general retention periods apply:

• Account and KYC data — retained for the duration of your active account relationship with 1plush, and for a minimum of five (5) years following account closure, in accordance with PAGCOR requirements and anti-money laundering record-keeping obligations under the AMLA.
• Transaction and financial records — retained for a minimum of five (5) years from the date of the transaction, consistent with Philippine financial record-keeping requirements.
• Gaming activity logs — retained for three (3) years from the date of the activity, or longer if required by an ongoing regulatory investigation or legal proceeding.
• Customer support communications — retained for two (2) years from the close of the support case, to enable review of escalated complaints and dispute resolution.
• Marketing preference records — retained for the duration of your account, and for one (1) year following account closure to demonstrate compliance with opt-out requests.

On expiry of the applicable retention period, 1plush will securely delete or anonymise your personal data so that it can no longer be associated with you as an identifiable individual.

10 Data Security

1plush 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:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 1plush platform.
• Encryption of sensitive personal data (including identity documents and financial account details) at rest using industry-standard algorithms.
• Role-based access controls restricting access to personal data to authorised personnel on a strict need-to-know basis.
• Multi-factor authentication requirements for staff accessing systems that process personal data.
• Regular security audits, vulnerability assessments, and penetration testing of platform infrastructure.
• Formal incident response procedures enabling 1plush to detect, contain, and notify affected parties in the event of a personal data breach.

In the event of a personal data breach that is likely to result in risk to your rights, 1plush will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with NPC Circular 16-03 and applicable data breach notification requirements.

11 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 1plush. These rights may be exercised at any time by contacting the 1plush DPO at [email protected]:

• Right to be informed — you have the right to be told clearly how your personal data is being collected and used. This Policy fulfils that obligation.
• Right of access — you have the right to request a copy of the personal data 1plush holds about you, and information about how it is being processed.
• Right to rectification — you have the right to have inaccurate or incomplete personal data corrected. You may update most account information directly through your 1plush account settings.
• Right to erasure — you have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected and no overriding legal obligation requires its continued retention.
• Right to object — you have the right to object to processing of your personal data where 1plush relies on legitimate interests as the legal basis, and where processing for direct marketing purposes.
• Right to data portability — you have the right to receive a copy of personal data you have provided to 1plush in a structured, commonly used, machine-readable format where processing is based on consent or contract.
• Right to withdraw consent — where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint — if you believe 1plush has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

1plush will respond to all data subject rights requests within thirty (30) calendar days of receipt. Where a request is complex or involves a large volume of data, the response period may be extended by a further thirty (30) days with notice to you.

12 Children & Minors

If 1plush becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be immediately suspended, all associated data will be reviewed and deleted to the extent permissible by law, and the matter will be escalated to the 1plush compliance team.

If you are a parent or guardian and believe that a minor in your care has registered a 1plush account or submitted personal data to the platform, please contact 1plush immediately at [email protected] so that appropriate action can be taken without delay.

13 Cross-Border Data Transfers

1plush primarily processes and stores personal data within the Philippines. In certain limited circumstances — such as where a third-party technology provider or game content studio operates infrastructure outside the Philippines — personal data may be transferred to and processed in another jurisdiction.

Where cross-border transfers occur, 1plush ensures that such transfers comply with the requirements of the Data Privacy Act of 2012 and NPC regulations on cross-border data transfers. Specifically, 1plush will only transfer personal data to a recipient in another country where:

• The receiving country has been determined to provide an adequate level of data protection; or
• Appropriate contractual safeguards — including standard contractual clauses approved by the NPC — are in place between 1plush and the data importer; or
• The transfer is necessary for the performance of your contract with 1plush (for example, processing a payment through an international card network); or
• You have given your explicit consent to the specific transfer after being informed of the risks.

You may request details of any cross-border transfers affecting your personal data, and the safeguards in place, by contacting the 1plush DPO.

14 Changes to This Privacy Policy

1plush reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, our data processing practices, or our platform services. The effective date at the top of this Policy indicates when the current version came into force.

Where changes are material — meaning they significantly affect how we process your personal data or the rights available to you — 1plush will notify registered players via email or an in-platform notification prior to the changes taking effect. For minor clarifications or non-material updates, the updated Policy will be published on this page with a revised effective date.

Your continued use of the 1plush platform after the effective date of any amendment constitutes your acceptance of the updated Policy. We encourage you to review this Policy periodically to stay informed of how 1plush protects your personal data.

15 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or have a concern about how 1plush has handled your personal data, please contact our Data Protection Officer:

Email: [email protected]
Subject line: Data Privacy Enquiry
Response time: Within 3 business days for initial acknowledgement; within 30 calendar days for substantive response

If you are not satisfied with the response you receive from 1plush, or if you believe that 1plush has violated your rights under the Data Privacy Act of 2012, you have the right to file a complaint with the National Privacy Commission of the Philippines.