1xbe Privacy Policy

1Introduction

1xbe ("we," "us," or "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the 1xbe platform at 1xbe.one (the "Platform"). This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal data.

This Privacy Policy applies to all users of the 1xbe Platform, including registered Players, visitors who browse the Platform without registering, and individuals who contact 1xbe through any communication channel. It applies to personal data collected through the Platform, our mobile interface, customer support channels, and any other touchpoint between you and 1xbe.

By accessing or using the 1xbe Platform, 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 any part of this Privacy Policy, please discontinue your use of the Platform immediately.

2Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, 1xbe is the Personal Information Controller in respect of the personal data collected through the Platform.

As Personal Information Controller, 1xbe determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable data protection laws, including the Data Privacy Act of 2012 and the regulations issued by the National Privacy Commission (NPC) of the Philippines.

1xbe has registered its data processing activities with the NPC as required under applicable regulations and has appointed a Data Protection Officer (DPO) to oversee compliance with data privacy obligations. Contact details for our DPO are provided in Section 15 of this Privacy Policy.

3Personal Data We Collect

1xbe collects the following categories of personal data, depending on how you interact with the Platform:

1xbe does not collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for regulatory compliance purposes, in which case such collection will be subject to additional safeguards and explicit consent.

4How We Collect Your Data

1xbe collects personal data through the following means:

• Direct Collection: Information you provide when registering an Account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, log files, and similar tracking technologies (see Section 10).
• Third-Party Sources: Identity verification data from KYC service providers; fraud and risk data from anti-fraud service providers; payment data from GCash, PayMaya, and banking partners in connection with transaction processing.
• Regulatory Sources: Data received from PAGCOR or other regulatory authorities in connection with compliance obligations, including self-exclusion registers.

5How We Use Your Personal Data

1xbe uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 1xbe Account, including processing your registration, verifying your identity and age, and managing your Account settings.
• Service Delivery: To provide you with access to the 1xbe Platform, including casino games, sports betting, and all associated features and services.
• Financial Transactions: To process deposits, withdrawals, and bonus credits, and to maintain accurate financial records of all transactions on your Account.
• Legal and Regulatory Compliance: To comply with our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and all other applicable Philippine laws and regulations.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal or prohibited conduct on the Platform.
• Responsible Gaming: To monitor your gaming activity for indicators of problem gambling, to enforce deposit and loss limits you have set, and to administer self-exclusion requests.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Communications: To send you transactional notifications (e.g., deposit confirmations, withdrawal updates, security alerts) and, where you have consented, promotional communications about 1xbe offers and features.
• Platform Improvement: To analyze usage patterns, conduct internal research, and improve the features, performance, and security of the 1xbe Platform.
• Legal Claims: To establish, exercise, or defend legal claims in connection with your use of the Platform.

6Legal Basis for Processing

Under the Data Privacy Act of 2012, 1xbe processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to provide the 1xbe Platform services as described in our Terms & Conditions. This covers Account registration, game access, and transaction processing.
• Legal Obligation: Processing is necessary to comply with our legal and regulatory obligations under PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws.
• Legitimate Interests: Processing is necessary for 1xbe's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, provided that such interests are not overridden by your data protection rights.
• Consent: For certain processing activities — such as sending marketing communications or processing sensitive personal information — 1xbe relies on your explicit, freely given, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7Data Sharing and Disclosure

1xbe does not sell, rent, or trade your personal data. 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:

• KYC and Identity Verification Providers: Third-party service providers who assist with identity verification, age verification, and document authentication as required for regulatory compliance.
• Payment Service Providers: GCash, PayMaya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) for the purpose of processing deposits and withdrawals.
• Fraud Prevention and Risk Management Providers: Third-party providers who assist with detecting and preventing fraudulent activity, money laundering, and other prohibited conduct.
• IT and Platform Service Providers: Cloud hosting, data storage, and technical infrastructure providers who process data on our behalf under strict data processing agreements.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government authorities where disclosure is required by law, court order, or regulatory directive.
• Legal and Professional Advisors: Lawyers, auditors, and other professional advisors engaged by 1xbe in connection with legal proceedings, compliance reviews, or corporate transactions, subject to professional confidentiality obligations.

All third-party service providers who process personal data on behalf of 1xbe are required to enter into data processing agreements that obligate them to process such data only in accordance with 1xbe's instructions and applicable data protection laws.

8Data Retention

1xbe retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account Data: Retained for the duration of your Account and for a minimum of five (5) years following Account closure, in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under the Anti-Money Laundering Act and PAGCOR regulations.
• KYC and Identity Documents: Retained for a minimum of five (5) years following Account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required in connection with an ongoing dispute or legal proceeding.
• Technical and Usage Data: Retained for up to two (2) years from collection, unless required for longer periods for security or fraud investigation purposes.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years following withdrawal of consent, to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 1xbe's data disposal procedures.

9Data Security

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

• Encryption: All data in transit is protected using TLS 1.2 or higher. Sensitive data at rest, including financial information and identity documents, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized 1xbe personnel and service providers on a strict need-to-know basis. All access is logged and subject to regular review.
• Multi-Factor Authentication: 1xbe systems require multi-factor authentication for all administrative access to systems containing personal data.
• Regular Security Audits: 1xbe conducts regular penetration testing, vulnerability assessments, and security audits of its Platform and infrastructure.
• Incident Response: 1xbe maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, 1xbe will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act.
• Staff Training: All 1xbe personnel with access to personal data receive regular data privacy and security training.

10Cookies & Tracking Technologies

1xbe uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that maintain your login state and security cookies that protect against cross-site request forgery. These cookies cannot be disabled.
• Functional Cookies: Used to remember your preferences, such as language settings and display preferences, to provide a more personalized experience.
• Analytics Cookies: Used to collect aggregated, anonymized data about how users interact with the Platform, helping us identify areas for improvement. No personally identifiable information is shared with analytics providers.
• Security Cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity verification.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. A full cookie policy is available on request from our DPO.

11Your Data Privacy Rights

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

• Right to Be Informed: The right to be informed about how your personal data is collected, used, and processed — which is the primary purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data 1xbe holds about you, together with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by 1xbe.
• Right to Erasure: 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 1xbe's legal and regulatory retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 1xbe has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, please contact our Data Protection Officer using the contact details in Section 15. 1xbe will respond to all valid data subject requests within fifteen (15) business days of receipt. We may require you to verify your identity before processing your request.

12Children's Privacy

The 1xbe Platform is strictly intended for individuals aged 21 years and above. 1xbe does not knowingly collect personal data from individuals under the age of 21.

If 1xbe becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data and close the associated Account. Any funds deposited by an underage individual will be handled in accordance with applicable regulatory requirements.

If you are a parent or guardian and believe that your child has registered on the 1xbe Platform or provided personal data to 1xbe, please contact our customer support team immediately so that we can take appropriate action.

13Cross-Border Data Transfers

In certain circumstances, 1xbe may transfer your personal data to service providers or partners located outside the Philippines — for example, cloud infrastructure providers or international KYC verification services. Any such cross-border transfer of personal data will be carried out in accordance with the requirements of the Data Privacy Act of 2012, including:

• Ensuring that the recipient country provides an adequate level of data protection, or
• Implementing appropriate safeguards such as contractual clauses approved by the National Privacy Commission, or
• Obtaining your explicit consent to the transfer where required.

1xbe will not transfer your personal data to jurisdictions that do not provide adequate data protection standards without implementing appropriate safeguards as required by applicable law.

14Updates to This Privacy Policy

1xbe 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 most current version of this Privacy Policy will always be published on this page, with the effective date indicated at the top.

Where changes to this Privacy Policy are material — meaning they significantly affect your rights or how we process your personal data — 1xbe will notify you by email or by a prominent notice on the Platform prior to the changes taking effect. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how 1xbe protects your personal data.

15Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 1xbe, please contact us through the following channels:

• Customer Support (Live Chat): Available 24/7 via the live chat widget on the 1xbe Platform — the fastest way to reach us for urgent account-related matters.
• General Privacy Inquiries: [email protected]
• Data Protection Officer: [email protected]

Our Data Protection Officer is responsible for overseeing 1xbe's compliance with the Data Privacy Act of 2012 and will handle all data subject rights requests, privacy complaints, and regulatory inquiries. We aim to respond to all written privacy inquiries within 15 business days.

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