aceph1 Privacy Policy

01 Introduction & Scope

aceph1 ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all registered players and visitors to the aceph1 website at aceph1.net. This Privacy Policy has been prepared in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations ("IRR"), and the relevant issuances of the National Privacy Commission ("NPC").

This Privacy Policy applies to all personal data collected from you when you visit, register, deposit, play, or otherwise interact with the aceph1 platform — whether accessed from Manila, Cebu, Davao, Quezon City, Makati, or anywhere else across the Philippine archipelago. It covers data collected through the aceph1 website, any mobile applications associated with aceph1, and any customer support interactions conducted via live chat or email.

This Privacy Policy should be read alongside our Terms and Conditions and our Responsible Gaming policy, both of which form part of the agreement between you and aceph1.

02 Personal Data We Collect

aceph1 collects personal data in the following categories. We collect only what is necessary for the purposes described in this policy:

2.1 Registration & Identity Data

When you create an aceph1 account, we collect your legal full name, date of birth, gender, nationality, residential address, email address, and Philippine mobile number. This information is required to create and maintain your account and to verify your identity.

2.2 KYC & Verification Documents

To comply with Philippine AML regulations and our regulatory obligations, we may collect copies of government-issued identification documents (such as a Philippine passport, driver's license, UMID, SSS ID, or PhilSys National ID), proof of address documents, and proof of payment method ownership. These documents are used exclusively for identity verification and fraud prevention purposes.

2.3 Financial & Transaction Data

We collect records of all financial transactions conducted through your aceph1 account, including deposit amounts, withdrawal requests, payment method details (such as your GCash or Maya account name and masked account number), transaction timestamps, and transaction reference numbers. Full payment credentials such as full bank account numbers or card numbers are never stored by aceph1.

2.4 Gaming Activity Data

We collect detailed records of your gaming activity on aceph1, including the games you play, bet amounts, session durations, win and loss records, bonus usage, and wagering history. This data is used for regulatory compliance, responsible gaming monitoring, fraud detection, and platform improvement.

2.5 Technical & Device Data

When you access aceph1, we automatically collect technical data including your IP address, device type and model, operating system, browser type and version, screen resolution, time zone, and referring URL. This data is used for security monitoring, fraud detection, and platform optimization.

2.6 Communications Data

We retain records of all communications between you and aceph1, including live chat transcripts, email correspondence, and any feedback or complaints submitted through the platform. These records are used for quality assurance, dispute resolution, and compliance purposes.

03 How We Collect Your Data

aceph1 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, or participate in promotions.
• Automatically — through cookies, web beacons, server logs, and similar tracking technologies when you browse the aceph1 website or use our platform.
• From third parties — including KYC verification service providers, payment processors (GCash, Maya, BPI, BDO, GrabPay), fraud detection services, and analytics providers, subject to their own privacy policies and data sharing agreements with aceph1.
• From regulatory sources — we may receive information from Philippine regulatory bodies or law enforcement agencies as part of our compliance obligations.

04 How We Use Your Personal Data

aceph1 uses the personal data we collect for the following purposes:

PURPOSE	DESCRIPTION	DATA USED
Account Management	Creating, maintaining, and administering your aceph1 player account	Identity, contact, login data
KYC Verification	Verifying your identity and age (21+) as required by Philippine regulations	Identity documents, selfie verification
Payment Processing	Processing deposits and withdrawals via GCash, Maya, BPI, BDO, and other methods	Financial and transaction data
AML Compliance	Monitoring transactions for suspicious activity and reporting to AMLC as required	Financial, gaming, identity data
Fraud Prevention	Detecting and preventing fraudulent activity, multiple accounts, and platform abuse	Technical, behavioral, gaming data
Responsible Gaming	Monitoring gaming patterns and applying player protection measures	Gaming activity, session data
Customer Support	Responding to your queries, resolving disputes, and managing complaints	Communications, account data
Platform Improvement	Analyzing usage patterns to improve aceph1's features and user experience	Technical, behavioral data (anonymized where possible)
Marketing	Sending promotional offers and bonus communications (with your consent)	Contact data, preferences

05 Legal Basis for Processing

Under the Data Privacy Act of 2012, aceph1 processes your personal data on the following legal bases:

• Contractual Necessity — Processing is necessary to perform our contract with you (the Terms and Conditions), including account management, payment processing, and service delivery.
• Legal Obligation — Processing is required to comply with Philippine law, including the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and regulations issued by the relevant Philippine gaming regulatory authority.
• Legitimate Interests — Processing is necessary for aceph1's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, provided these interests are not overridden by your rights and freedoms.
• Consent — For certain processing activities, such as sending marketing communications or processing sensitive personal information beyond what is required by law, we rely on your explicit, freely given, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out before withdrawal.

06 Data Sharing & Disclosure

aceph1 does not sell, rent, or trade your personal data to third parties for commercial purposes. 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:

6.1 Service Providers

We share data with trusted third-party service providers who assist in the operation of aceph1, including: KYC and identity verification providers; payment processors and e-wallet operators (GCash, Maya, GrabPay, BPI, BDO, InstaPay); cloud hosting and data storage providers; fraud detection and cybersecurity firms; and customer support platform providers. All service providers are bound by data processing agreements requiring them to handle your data in accordance with this Privacy Policy and applicable Philippine law.

6.2 Regulatory & Law Enforcement Authorities

aceph1 is required by Philippine law to disclose personal data to regulatory bodies and law enforcement agencies in certain circumstances, including: the Anti-Money Laundering Council (AMLC) in connection with suspicious transaction reports; the National Privacy Commission (NPC) in the event of a data breach or compliance inquiry; and any other Philippine government authority exercising lawful authority to require disclosure.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of aceph1's assets, your personal data may be transferred to the acquiring entity as part of that transaction, subject to the same protections described in this Privacy Policy. You will be notified of any such transfer and the resulting changes to data processing arrangements via the email address on file.

07 Cookies & Tracking Technologies

aceph1 uses cookies and similar tracking technologies to enhance your experience on our platform, maintain session security, and analyze usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies — Essential for the platform to function. These include session authentication cookies and security tokens. These cannot be disabled without affecting platform functionality.
• Functional Cookies — Used to remember your preferences, such as your preferred language, display settings, and game history. These improve your experience on aceph1.
• Analytics Cookies — Used to collect anonymized data about how players use aceph1, which pages are most visited, and where errors occur. This data helps us improve the platform.
• Security Cookies — Used to detect and prevent fraudulent activity, including multiple account detection and unusual login pattern monitoring.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the aceph1 platform. Strictly necessary and security cookies cannot be opted out of while using the platform.

08 Data Security

aceph1 implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• AES-256 encryption for all personal data stored at rest on aceph1 servers.
• TLS 1.3 encryption for all data transmitted between your device and aceph1 systems.
• Multi-factor authentication options for player accounts to prevent unauthorized login.
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity firms.
• Role-based access controls ensuring that only authorized aceph1 personnel can access player data, limited strictly to what their job function requires.
• Continuous 24/7 security monitoring of aceph1 infrastructure for anomalous activity.
• Regular staff training on data protection and information security best practices.

09 Data Retention

aceph1 retains your personal data for as long as your account is active and for a period thereafter as required by Philippine law and regulatory mandates. Our general data retention periods are as follows:

DATA CATEGORY	RETENTION PERIOD	BASIS
Account & identity data	Duration of account + 5 years post-closure	AMLA compliance requirement
KYC documents	Duration of account + 5 years post-closure	AMLA / regulatory requirement
Financial transaction records	Duration of account + 5 years post-closure	AMLA / tax compliance
Gaming activity logs	Duration of account + 2 years post-closure	Regulatory audit trail
Customer support communications	3 years from date of communication	Dispute resolution / legitimate interest
Technical / device logs	12 months rolling	Security monitoring / fraud prevention
Marketing consent records	Until consent is withdrawn + 1 year	Proof of consent (DPA requirement)

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized so that it can no longer be associated with any individual player.

10 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by aceph1. You may exercise any of these rights by contacting our Data Protection Officer as described in Section 15.

• Right to Be Informed — You have the right to know whether aceph1 holds personal data about you, and to receive clear information about how that data is processed.
• Right of Access — You have the right to request a copy of the personal data aceph1 holds about you, along with information about how it is processed, in a commonly used and machine-readable format where applicable.
• Right to Rectification — If personal data we hold about you is inaccurate or incomplete, you have the right to request correction without undue delay.
• Right to Erasure — You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where processing is unlawful — subject to overriding legal obligations such as AMLA retention requirements.
• Right to Object — You have the right to object to the processing of your personal data for direct marketing purposes, or where processing is based on aceph1's legitimate interests and you believe your rights override those interests.
• Right to Data Portability — Where processing is based on your consent or a contract, you may request that aceph1 provide your personal data in a structured, commonly used, and machine-readable format for transfer to another controller.
• Right to Lodge a Complaint — If you believe aceph1 has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11 Children's Privacy

aceph1 is strictly an adult gaming platform intended solely for players who are at least 21 years of age, in compliance with Philippine gambling regulations. We do not knowingly collect personal data from any person under the age of 21. If you are under 21, you are not permitted to use aceph1 and must not attempt to register or access the platform.

If aceph1 discovers or is notified that personal data has been collected from a person under 21 years of age, the associated account will be immediately closed, all personal data collected will be deleted or anonymized, and any funds in the account will be handled in accordance with applicable regulatory requirements.

Parents and guardians who believe their child may have accessed aceph1 are encouraged to contact us immediately at [email protected] so that we can take swift action.

12 International Data Transfers

aceph1 primarily stores and processes player data within data centers located in or serving the Asia-Pacific region. In certain circumstances, personal data may be transferred to and processed in countries outside the Philippines — for example, where a third-party service provider operates servers in another jurisdiction.

Where such international transfers occur, aceph1 ensures that adequate safeguards are in place in accordance with NPC requirements, including:

• Transferring data only to countries that provide an adequate level of data protection as recognized by the NPC, or
• Entering into binding data processing agreements incorporating standard contractual clauses approved under the DPA framework, or
• Obtaining your explicit consent to the transfer where required.

aceph1 will never transfer your personal data internationally in a manner that reduces the protections you are entitled to under the Data Privacy Act of 2012.

13 Third-Party Services & Game Providers

The aceph1 platform integrates games and services provided by licensed third-party game studios and technology providers. When you play games powered by these providers, limited technical and gaming activity data may be shared with them for the purpose of game delivery, fairness auditing, and technical support.

All third-party game and technology providers integrated into aceph1 are contractually required to process player data only for the purposes of service delivery, to maintain appropriate security standards, and not to use aceph1 player data for their own independent purposes without prior written approval from aceph1.

aceph1 is not responsible for the independent privacy practices of any external websites that may be referenced from our platform. This Privacy Policy applies only to the aceph1 platform at aceph1.net and does not extend to any third-party websites or services.

14 Updates to This Privacy Policy

aceph1 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. The effective date at the top of this policy will be updated whenever a new version is published.

For material changes that significantly affect how we process your personal data, aceph1 will notify registered players via the email address on file no fewer than fourteen (14) days before the changes take effect. For minor changes — such as corrections to typos or clarifications that do not alter the substance of our processing activities — notification may be provided solely through an updated policy on the aceph1 website.

Your continued use of the aceph1 platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of and, where required, consent to the revised terms. If you do not agree with any changes, you should cease using the platform and may request account closure and data deletion as described in Section 10.

15 Contact & Data Protection Officer

aceph1 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, you may contact the aceph1 DPO through the following channels:

• Email: [email protected] — use the subject line "Privacy / DPO Inquiry" for fastest routing.
• Live Chat: Available 24/7 directly on the aceph1 platform — staffed by Filipino support agents who can escalate data privacy matters to the DPO team.