Privacy Policy — no1 Casino

Who We Are

no1 is the operator of the online casino platform accessible at no1.today and all associated subdomains and mobile browser interfaces (collectively, the "Platform"). In this Privacy Policy, references to "no1," "we," "us," or "our" refer to the operator of the Platform.

no1 acts as the Personal Information Controller (PIC) in respect of the personal data it collects from players and visitors, as defined under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, hereinafter "DPA") and its Implementing Rules and Regulations ("IRR").

Our designated Data Protection Officer (DPO) is responsible for overseeing compliance with the DPA and this Privacy Policy. You may contact our DPO by sending a written inquiry to the email address listed in the footer of this page, with the subject line: "Attention: Data Protection Officer."

Personal Data We Collect

no1 collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected and processed. The categories of personal data we collect include:

A. Registration & Identity Data

• Full legal name as it appears on your government-issued ID.
• Date of birth (used to verify that you are 21 years of age or older).
• Gender (optional, for personalization purposes).
• Nationality and country of residence.
• Email address and mobile number.
• Username and encrypted password.

B. Identity Verification (KYC) Data

• Scanned or photographed copies of government-issued photo ID (e.g., Philippine passport, SSS ID, UMID, driver's license, PhilSys National ID).
• Proof of address (e.g., utility bill, bank statement dated within 90 days).
• Selfie or liveness check image for biometric verification, where required.
• Proof of payment method (e.g., screenshot of GCash or PayMaya account showing your registered name).

C. Financial & Transaction Data

• Deposit and withdrawal amounts, dates, and payment method references.
• GCash or PayMaya account reference numbers (we do not store full wallet credentials).
• Bank account name and last four digits of account number for BPI, BDO, and Metrobank transfers.
• Transaction history and wallet balance records.

D. Gameplay & Behavioral Data

• Game session logs, including games played, wager amounts, win/loss outcomes, and session duration.
• Bonus and promotion usage history.
• Responsible gaming tool settings (deposit limits, self-exclusion status, cooling-off periods).
• Customer support interaction records, including chat transcripts and email correspondence.

E. Technical & Device Data

• IP address and approximate geolocation derived from IP.
• Device type, operating system, and browser type and version.
• Unique device identifiers.
• Session timestamps and page interaction logs.
• Cookie identifiers and similar tracking technology data (see Section 10).

How We Collect Your Data

no1 collects personal data through the following channels:

• Directly from you: When you register for an Account, complete KYC verification, make a deposit or withdrawal, contact customer support, respond to a survey, or participate in a promotion.
• Automatically: When you visit or interact with the Platform, our servers and analytics tools automatically collect technical and behavioral data, including IP address, device information, and session activity.
• From third-party identity verification providers: When you submit KYC documents, we may use a third-party verification service to authenticate your identity. These providers return a verification result and risk score to no1.
• From payment processors: GCash, PayMaya, BPI, BDO, and Metrobank may share transaction confirmation data with no1 to reconcile deposits and withdrawals.
• From fraud prevention and AML screening services: We may receive data from third-party services that screen for politically exposed persons (PEPs), sanctions lists, and adverse media in compliance with our Anti-Money Laundering Act (AMLA) obligations.

How We Use Your Personal Data

no1 uses the personal data it collects for the following purposes:

• Account creation and management: To register your Account, verify your identity, maintain your Wallet, and provide you with access to the Platform's games and features.
• Transaction processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, and to maintain accurate financial records.
• KYC and regulatory compliance: To verify that you meet the 21+ age requirement, confirm your identity, and comply with our obligations under the Anti-Money Laundering Act (AMLA), PAGCOR regulations, and the DPA.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, and unauthorized access to Accounts.
• Customer support: To respond to your inquiries, resolve disputes, and improve our support processes.
• Responsible gaming: To monitor gameplay patterns for signs of problem gambling, enforce deposit limits and self-exclusion orders, and provide you with responsible gaming tools.
• Platform improvement: To analyze usage patterns, conduct A/B testing, and improve the design, performance, and game selection of the Platform.
• Marketing communications (with consent): To send you promotional emails, SMS notifications, and in-platform messages about bonuses, new games, and special offers — but only if you have opted in to receive such communications. You may opt out at any time.
• Legal obligations: To comply with court orders, regulatory directives, and lawful requests from PAGCOR, AMLC, the NPC, and other competent Philippine authorities.

Legal Basis for Processing

Under the Philippine Data Privacy Act, no1 processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to perform the contract between you and no1 — specifically, to create and manage your Account, process transactions, and provide access to the Platform's services. This is the primary legal basis for most of our data processing activities.
• Legal obligation: Processing is required for no1 to comply with applicable Philippine law, including the DPA, AMLA, and PAGCOR regulatory requirements. This includes KYC verification, AML screening, and the retention of financial records.
• Legitimate interests: Processing is necessary for no1's legitimate interests in fraud prevention, platform security, and business analytics, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and optional analytics cookies, no1 relies on your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Sharing Your Personal Data

no1 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the following circumstances and only to the extent necessary:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank receive transaction data necessary to process your deposits and withdrawals. Each processor operates under its own privacy policy and applicable Philippine financial regulations.
• Identity verification providers: Third-party KYC service providers receive your identity documents and biometric data solely for the purpose of verifying your identity. These providers are contractually bound to process your data only for this purpose.
• Game providers: The game studios whose titles are available on the Platform may receive anonymized session data (e.g., game ID, wager amount, outcome) for game integrity and RTP auditing purposes. They do not receive your name, contact details, or financial information.
• Fraud prevention and AML screening services: We share relevant data with third-party screening services to fulfill our AMLA obligations, including PEP and sanctions list screening.
• Regulatory and law enforcement authorities: no1 will disclose personal data to PAGCOR, AMLC, the NPC, the National Bureau of Investigation (NBI), or other competent authorities when required by law, court order, or regulatory directive.
• Professional advisors: Our lawyers, auditors, and accountants may access personal data to the extent necessary to provide their professional services, subject to strict confidentiality obligations.

Data Retention

no1 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account and KYC data: Retained for the duration of your Account and for a minimum of 5 years after Account closure, in compliance with AMLA record-keeping requirements.
• Financial transaction records: Retained for a minimum of 5 years from the date of the transaction, as required by AMLA and applicable tax regulations.
• Customer support records: Retained for 3 years from the date of the last interaction, or longer if the interaction relates to an ongoing dispute or investigation.
• Marketing consent records: Retained for the duration of your consent and for 1 year after withdrawal of consent, to demonstrate compliance.
• Technical and device logs: Retained for 12 months from the date of collection, unless required for an ongoing security investigation.

When personal data is no longer required, no1 will securely delete or anonymize it in accordance with our data disposal procedures. Anonymized data (which can no longer identify you) may be retained indefinitely for statistical and analytical purposes.

Security Measures

no1 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption in transit: All data transmitted between your device and the no1 Platform is encrypted using TLS 1.2 or higher.
• Encryption at rest: Sensitive personal data stored on our servers — including KYC documents and financial records — is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to no1 staff and contractors who have a legitimate need to access it for their job functions. All access is logged and audited.
• Two-factor authentication (2FA): no1 offers 2FA for player Accounts and requires it for all internal staff accessing production systems.
• Regular security audits: no1 conducts periodic penetration tests and vulnerability assessments of its Platform and infrastructure.
• Incident response: no1 maintains a documented data breach response plan. In the event of a personal data breach that poses a real risk to your rights and freedoms, we will notify the NPC within 72 hours and affected players without undue delay, as required by the DPA.

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 no1:

• Right to be Informed: You have the right to know what personal data no1 collects about you, why it is collected, and how it is used. This Privacy Policy fulfills that obligation.
• Right of Access: You may request a copy of the personal data no1 holds about you, including information on how it has been processed.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You can update most Account details directly through your Account settings.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal obligations to retain certain records (see Section 7).
• Right to Data Portability: You may request that no1 provide your personal data in a structured, commonly used, and machine-readable format so that you can transfer it to another service provider.
• 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, subject to no1's overriding legitimate grounds.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: If you believe no1 has violated your data privacy rights, you may file a complaint with the National Privacy Commission (NPC) at privacy.gov.ph.

To exercise any of the above rights, please contact our Data Protection Officer at the email address listed in the footer of this page. We will respond to all verified data subject requests within 15 business days of receipt, as required by the DPA IRR.

Cookies & Tracking Technologies

no1 uses cookies and similar tracking technologies (such as web beacons and local storage) on the Platform. A cookie is a small text file placed on your device when you visit a website. Cookies help us recognize you, remember your preferences, and analyze how the Platform is used.

We use the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They maintain your login session, protect against cross-site request forgery (CSRF), and ensure the security of your Account. These cookies cannot be disabled without breaking core Platform functionality.
• Functional Cookies: These cookies remember your preferences, such as your preferred language, display settings, and responsible gaming tool configurations. They improve your experience but are not strictly required for the Platform to operate.
• Analytics Cookies: With your consent, we use analytics cookies to understand how players interact with the Platform — which pages are visited most, where players drop off, and how features are used. This data is aggregated and anonymized where possible.
• Marketing Cookies: With your consent, we may use cookies to deliver personalized promotional content within the Platform based on your gameplay history and preferences.

You can manage your cookie preferences through the cookie settings panel available on the Platform. You can also control cookies through your browser settings, though disabling strictly necessary cookies may impair your ability to use the Platform.

Minors

The no1 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with the minimum legal age for casino-style gambling in the Philippines. no1 does not knowingly collect, process, or store personal data from individuals under the age of 21.

All players are required to confirm their age during registration and to provide valid proof of age during KYC verification. If no1 discovers or has reasonable grounds to believe that a registered player is under 21 years of age, no1 will:

• Immediately suspend the Account and block access to the Platform.
• Delete all personal data associated with the Account as soon as practicable, subject to any legal obligations to retain records of the incident.
• Return any real-money deposits to the originating payment method after investigation.
• Forfeit all Bonus Funds and any winnings derived from Bonus Funds.

Changes to This Privacy Policy

no1 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 material changes are made, we will notify registered players via email or a prominent notice on the Platform at least 7 days before the changes take effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how no1 protects your data.

Your continued use of the Platform after the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with the revised policy, you must stop using the Platform and may request Account closure in accordance with our Terms & Conditions.