aaajj Casino Privacy Policy

1 Introduction and Scope

1.1 aaajj is committed to protecting the privacy and personal data of every player who uses our platform. We recognise that trust is the foundation of any lasting player relationship, and that trust begins with transparent, responsible data practices.

1.2 This Policy applies to all personal information collected through the aaajj website, mobile platform, customer support channels, and any other touchpoint through which you interact with aaajj. It applies to registered players, prospective players who browse the platform without registering, and individuals who contact our support team.

1.3 This Policy should be read alongside aaajj's Terms & Conditions, which govern your use of the platform as a whole. Capitalised terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

1.4 aaajj acts as the Data Controller with respect to the personal data it processes. Our Data Protection Officer (DPO) can be contacted using the details set out in Section 13 of this Policy.

2 Personal Data We Collect

2.1 aaajj collects personal data through several channels. The categories of data we collect and the circumstances in which we collect them are set out below.

2.1 Data You Provide Directly

• Registration data: Full legal name, date of birth, email address, Philippine mobile number, username, and password;
• KYC / identity verification documents: Government-issued photo ID (e.g., PhilSys National ID, passport, UMID, SSS ID, driver's license, PRC ID), proof of address (utility bill, bank statement, barangay certificate), and selfie verification images;
• Payment information: GCash mobile number, PayMaya account details, bank account number and name (BPI, BDO, Metrobank, UnionBank), and other payment method details necessary to process deposits and withdrawals;
• Communication data: Messages sent to aaajj via live chat, email, or any other support channel, including their content and metadata.

2.2 Data Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and language settings;
• Usage and behavioural data: Pages visited, games played, bet amounts and frequencies, session duration, clickstream data, and feature interactions;
• Transaction data: Complete records of all deposits, withdrawals, bets placed, game outcomes, and bonus transactions;
• Cookies and tracking data: As described in Section 6 of this Policy.

2.3 Data from Third Parties

• KYC and AML screening providers: Identity verification results, politically exposed person (PEP) checks, and sanctions screening outcomes;
• Payment processors: Transaction confirmation, fraud flags, and chargeback notifications;
• Game providers: Game session data, RNG audit logs, and jackpot records relevant to your account activity.

3 How We Use Your Personal Data

3.1 aaajj uses the personal data it collects for the following purposes:

3.2 aaajj will not use your personal data for any purpose incompatible with the purposes listed above without first obtaining your explicit consent or establishing another lawful basis for such processing.

3.3 You may opt out of marketing communications at any time by clicking the "unsubscribe" link in any promotional email or by contacting our support team. Opting out of marketing does not affect the processing of your data for account management, payment, or compliance purposes.

4 Legal Basis for Processing

4.1 aaajj processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012 (RA 10173):

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and provision of gaming services;
• Legal obligation: Processing necessary to comply with applicable Philippine laws and regulations, including AML obligations, tax reporting, and PAGCOR-related regulatory requirements;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and platform analytics, where such interests are not overridden by your privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, which you may withdraw at any time.

4.2 Where aaajj relies on your consent as the legal basis for processing, 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

5.1 aaajj does not sell, rent, or trade your personal information to any third party for their own commercial purposes. We share your data only in the following circumstances:

5.1 Service Providers (Data Processors)

We share data with trusted third-party service providers who process data on our behalf under strict contractual data processing agreements. These include:

• KYC and identity verification providers;
• Payment gateway and e-wallet operators (GCash, PayMaya, BPI, BDO, Metrobank, UnionBank);
• AML screening and fraud detection services;
• Game software providers (data limited to what is necessary for game delivery and audit);
• Cloud hosting and IT infrastructure providers;
• Customer support software providers.

5.2 Regulatory and Law Enforcement Authorities

aaajj will disclose personal data to government and regulatory authorities — including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies — where required or permitted by Philippine law. Such disclosures are made only to the extent required and with appropriate safeguards where possible.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of aaajj's assets, your personal data may be transferred to the acquiring entity. We will notify you via email and/or a prominent notice on the platform before your data is transferred and becomes subject to a different privacy policy.

6 Cookies and Tracking Technologies

6.1 aaajj uses cookies and similar technologies (including web beacons, pixel tags, and local storage) to operate and improve the platform. The types of cookies we use are:

• Strictly necessary cookies: Required for the platform to function. These include session cookies that keep you logged in and security cookies that prevent cross-site request forgery. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, currency display, and game lobby filters. Disabling these may affect your experience.
• Analytics cookies: Collect anonymised data about how players use the platform to help us improve features and performance. We use privacy-respecting analytics tools and do not share raw analytics data with third parties.
• Security and fraud prevention cookies: Used to detect unusual activity, multiple account attempts, and bot behaviour. These are essential for platform integrity.

6.2 aaajj does not use third-party advertising cookies or allow external advertising networks to place cookies on our platform.

6.3 You can manage or disable non-essential cookies through your browser settings. Note that disabling functional or analytics cookies may limit certain platform features. Instructions for managing cookies in popular browsers are available through the browser's help documentation.

7 Data Security

7.1 aaajj implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction.

7.2 Our security measures include, but are not limited to:

• SSL/TLS encryption for all data in transit between your device and our servers;
• AES-256 encryption for sensitive data stored at rest, including identity documents and payment details;
• Multi-factor authentication options for player accounts;
• Regular penetration testing and vulnerability assessments conducted by independent security professionals;
• Strict role-based access controls limiting staff access to player data on a need-to-know basis;
• Comprehensive audit logging of all access to personal data systems;
• Staff training on data protection and information security.

7.3 Despite these measures, no internet-based platform can guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, aaajj will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach and will inform affected players without undue delay.

8 Data Retention

8.1 aaajj retains your personal data only for as long as is necessary to fulfil the purposes described in this Policy or as required by applicable Philippine laws and regulations.

8.2 The following general retention periods apply:

• Active account data: Retained for the duration of the account relationship plus five (5) years following account closure, to satisfy AML, tax, and regulatory compliance obligations;
• Transaction records: Minimum five (5) years from the date of each transaction, as required under Philippine AML regulations;
• KYC and identity documents: Minimum five (5) years following the termination of the business relationship;
• Customer support communications: Two (2) years from the date of the last interaction, or longer if the matter is subject to a dispute or legal proceeding;
• Marketing consent records: Until consent is withdrawn, plus one (1) year thereafter as evidence of the consent history;
• Website log and analytics data: Up to thirteen (13) months on a rolling basis.

8.3 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be associated with any individual. Where complete deletion is not technically feasible, aaajj will implement appropriate isolation measures to prevent further processing.

9 Your Data Rights Under Philippine Law

9.1 As a data subject under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by aaajj:

9.2 To exercise any of the above rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Rights Request." We will acknowledge your request within five (5) business days and respond substantively within thirty (30) calendar days. We may require identity verification before processing certain requests.

9.3 If you believe that aaajj has not adequately addressed your data privacy concerns, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through their official channels.

10 Children's Privacy and Age Restriction

10.1 The aaajj platform is strictly intended for individuals who are 21 years of age or older, consistent with the minimum age requirements for online casino-style gambling under applicable Philippine regulations.

10.2 aaajj does not knowingly collect personal data from individuals under the age of 21. All registration attempts are subject to age verification during the KYC process. If aaajj discovers that personal data has been collected from a person under 21, all associated account data will be permanently deleted and the matter will be escalated to the relevant regulatory authority where required.

10.3 Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gambling platforms. aaajj supports industry-wide efforts to prevent underage gambling and cooperates with PAGCOR and other relevant Philippine bodies on this issue.

11 International Data Transfers

11.1 aaajj's primary operations and data storage are based in the Philippines. However, some of our third-party service providers — including certain KYC verification partners, cloud infrastructure providers, and game software suppliers — may process data outside the Philippines.

11.2 Where personal data is transferred outside the Philippines, aaajj ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under Philippine law. Such safeguards include contractual data processing agreements incorporating standard data protection clauses, and transfers only to jurisdictions with adequate data protection frameworks recognised by the NPC.

11.3 By using the aaajj platform, you acknowledge and consent to the transfer of your personal data outside the Philippines where necessary for the provision of our services, subject to the safeguards described in this section.

12 Updates to This Privacy Policy

12.1 aaajj reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform functionality. The revised Policy will be published on this page with an updated "Last Updated" date.

12.2 Where changes are material — meaning they significantly affect your rights or how we use your data — aaajj will provide advance notice via email to your registered address or via a prominent notice on the platform. Where required by law, we will seek renewed consent for any materially changed data processing activities.

12.3 Your continued use of the aaajj platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the revised Policy. We encourage you to review this page periodically to stay informed about our data practices.

13 Contact Us and Data Protection Officer

13.1 aaajj has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Philippine Data Privacy Act. The DPO can be contacted through the following channels:

• Email: [email protected] — subject line: "Data Privacy / DPO"
• Live Chat: 24/7 via the aaajj platform
• Response time: We aim to acknowledge all data privacy enquiries within 5 business days and resolve them within 30 calendar days.

13.2 If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC). The NPC is the Philippine government authority responsible for enforcing the Data Privacy Act. Contact information for the NPC is available through official Philippine government channels.