we1we Privacy
Policy

1 Introduction

we1we is committed to protecting the privacy and personal data of all players who use our platform. This Policy has been prepared in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC).

This Policy applies to all personal data collected through the we1we website at we1we.app, our mobile-optimized platform, customer support channels, and any other touchpoints through which we interact with you. It covers data collected from players based in Manila, Cebu, Davao, Quezon City, Makati, and across the Philippines, as well as from any other jurisdiction where access to the platform is permitted.

Please read this Policy carefully. If you do not agree with the practices described herein, you should not use the we1we platform. For questions about this Policy, please contact our Data Protection Officer using the details provided in Section 13.

2 Personal Data We Collect

we1we collects personal data through several channels, including account registration, identity verification, payment processing, platform usage, and customer support interactions. The categories of personal data we collect are described below.

2.1 Data You Provide Directly

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification document details (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license).
• Contact Data: Email address, mobile number, and residential address (including city, province, and postal code).
• Financial Data: GCash account number, PayMaya account details, bank account information (BDO, BPI, Metrobank, UnionBank), and transaction history on the we1we platform.
• Account Credentials: Username and encrypted password. we1we does not store passwords in plain text.
• Support Communications: Records of your interactions with we1we customer support, including live chat transcripts and email correspondence.

2.2 Data Collected Automatically

• Technical Data: IP address, device type, operating system, browser type and version, and screen resolution.
• Usage Data: Pages visited, games played, session duration, betting history, deposit and withdrawal activity, and feature interactions.
• Location Data: General geographic location derived from your IP address, used for regulatory compliance and fraud prevention purposes.
• Cookie Data: Information collected through cookies and similar tracking technologies, as described in Section 6.

2.3 Data from Third Parties

we1we may receive personal data about you from third-party sources, including identity verification service providers, payment processors, fraud detection agencies, and publicly available sources, where permitted by applicable law. Such data is used solely to supplement our own records for the purposes described in this Policy.

3 How We Use Your Personal Data

we1we uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your we1we player account, including processing your registration and verifying your identity.
• Transaction Processing: To process deposits via GCash, PayMaya, BDO, BPI, and other supported payment methods, and to facilitate withdrawals in Philippine Peso (PHP).
• Regulatory Compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML) requirements, Know Your Customer (KYC) obligations, and applicable gaming regulations.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the platform and its users.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our support channels.
• Platform Improvement: To analyze usage patterns, identify technical issues, and improve the features, performance, and user experience of the we1we platform.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion, in accordance with our Responsible Gaming Policy.
• Communications: To send you account-related notifications, security alerts, and, where you have opted in, promotional communications about we1we offers and updates.

4 Legal Basis for Processing

we1we processes your personal data on the following legal bases, as recognized under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your we1we account, process your transactions, and deliver the gaming services you have requested.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and gaming regulatory requirements.
• Legitimate Interests: Processing is necessary for we1we's legitimate interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your data protection rights.
• Consent: Where we rely on your consent as the legal basis for processing — for example, for marketing communications or non-essential cookies — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5 Data Sharing and Disclosure

we1we does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

5.1 Service Providers

we1we engages trusted third-party service providers to assist in operating the platform. These include identity verification providers, payment processors (including GCash and PayMaya integrations), cloud hosting providers, fraud detection services, and customer support technology providers. All service providers are contractually required to process your data only on our instructions and to maintain appropriate security measures.

5.2 Regulatory and Law Enforcement Authorities

we1we may disclose your personal data to government agencies, regulatory bodies, law enforcement authorities, or courts where required to do so by applicable Philippine law, court order, or regulatory directive. This includes disclosures required under AML legislation and gaming regulations.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of we1we's business, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and the privacy practices of the successor entity prior to your data being transferred.

5.4 With Your Consent

we1we may share your personal data with other third parties where you have given your explicit consent to such sharing. You may withdraw this consent at any time by contacting our support team.

6 Cookies and Tracking Technologies

we1we uses cookies and similar technologies (such as web beacons and local storage) to operate and improve the platform. The types of cookies we use are described below:

• Strictly Necessary Cookies: These cookies are essential for the platform to function. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Performance Cookies: These cookies collect anonymized information about how players use the platform — for example, which pages are visited most frequently and whether error messages are received. This data helps us improve platform performance.
• Functionality Cookies: These cookies remember your preferences, such as your preferred language and display settings, to provide a more personalized experience.
• Security Cookies: These cookies help us detect and prevent fraudulent activity and unauthorized access to your account.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the we1we platform. we1we does not use cookies to serve third-party advertising or to build behavioral advertising profiles.

7 Data Security

we1we 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:

• SSL/TLS encryption for all data transmitted between your device and the we1we platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Two-factor authentication (2FA) options for player accounts.
• Role-based access controls limiting internal access to personal data to authorized personnel only.
• Regular security audits and vulnerability assessments of the platform infrastructure.
• Secure data centers with physical access controls and environmental safeguards.
• Staff training on data protection obligations and security best practices.

While we1we takes all reasonable steps to protect your personal data, 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, we1we will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012.

8 Data Retention

we1we retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with we1we, and for a period of five (5) years following account closure, in accordance with AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC Documents: Retained for five (5) years following the end of the business relationship, or longer if required by a specific regulatory directive.
• Support Communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution purposes.
• Technical and Usage Data: Retained for up to twelve (12) months, after which it is anonymized or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with we1we's data disposal procedures.

9 Your Data Protection Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by we1we:

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed, as set out in this Policy.
• Right of Access: You have the right to request a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• 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, subject to our legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data where we rely on legitimate interests as the legal basis, or where your data is used for direct marketing purposes.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13. we1we will respond to all verified data rights requests within thirty (30) days of receipt, in accordance with the requirements of the Data Privacy Act of 2012.

10 Children's Privacy

The we1we platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations and Philippine law governing casino-style gambling. we1we does 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 the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account on the we1we platform, please contact our support team immediately.

11 Third-Party Links

The we1we platform may contain references to third-party services, such as payment providers including GCash and PayMaya. When you interact with these third-party services, you are subject to their own privacy policies and terms of use. we1we is not responsible for the privacy practices or content of any third-party services.

we1we encourages you to review the privacy policies of any third-party services you use in connection with your we1we account, particularly those of your chosen payment provider, before submitting personal or financial information to them.

12 Updates to This Policy

we1we 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. The date of the most recent revision is displayed at the top of this page.

When material changes are made to this Policy, we1we will notify registered players via email or through a prominent notice on the platform prior to the changes taking effect. Your continued use of the we1we platform following the effective date of any update constitutes your acceptance of the revised Policy.

If you do not agree with the updated Policy, you should cease using the platform and may request account closure by contacting our support team.

13 Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way we1we handles your personal data, please contact our Data Protection Officer (DPO). Our DPO is responsible for overseeing compliance with the Data Privacy Act of 2012 and this Policy.

You may reach the we1we Data Protection Officer via the live chat feature available on the platform, or by email at the address below:

[email protected]

Please include your full name, registered account username, and a clear description of your query or request. we1we aims to acknowledge all privacy-related inquiries within 5 business days and to provide a full response within 30 days.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.