Privacy Policy

1. Scope and Application

This Privacy Policy applies to all personal data collected, processed, stored, or used by aaaji in connection with the operation of the aaaji online gaming platform accessible at aaaji.club, including all associated subdomains, mobile-optimized pages, and any future applications that reference this policy.

This policy applies to registered players, visitors to the aaaji website who have not yet registered, and former players whose data aaaji retains in accordance with applicable legal and regulatory requirements. By using the aaaji platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2. Data Controller Information

aaaji acts as the data controller in respect of personal data collected through the aaaji platform. As data controller, aaaji determines the purposes and means of processing your personal data, and is responsible for ensuring such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

aaaji has designated a Data Protection Officer (DPO) in accordance with NPC requirements. Inquiries regarding this Privacy Policy or the exercise of your data subject rights may be directed to the aaaji support team at [email protected], marked for the attention of the Data Protection Officer.

3. Personal Data We Collect

aaaji collects the following categories of personal data in connection with account registration, verification, platform use, and regulatory compliance:

• Identity Data: Full legal name, date of birth, gender, nationality, and copies of government-issued Philippine identification documents (UMID, driver's license, passport, PhilSys ID, or equivalent).
• Contact Data: Registered Philippine mobile number, email address, and correspondence address.
• Account Data: Username, account preferences, responsible gaming settings, and communication preferences.
• Financial Data: Deposit and withdrawal transaction records, payment method references (e.g., last four digits of a linked account), and account balance history. Full payment credentials are not stored by aaaji.
• Gaming Activity Data: Game session logs, bet amounts, game outcomes, bonus utilization records, and responsible gaming tool activations.
• Technical Data: IP address, device type, operating system, browser type and version, and session timestamps collected automatically when you access the aaaji platform.
• Communications Data: Records of support chat interactions, email correspondence, and feedback submissions.

4. How We Collect Your Data

aaaji collects your personal data through the following means:

• Direct provision: Data you enter directly into the aaaji platform during registration, KYC verification, deposit and withdrawal requests, support interactions, and account settings updates.
• Automated collection: Technical data collected automatically through cookies, server logs, and similar technologies when you access the aaaji website or platform.
• Third-party sources: Identity verification data received from Philippine payment processors (GCash, PayMaya, BPI, BDO, Metrobank) during transaction processing, and identity data from government-authorized verification services used for KYC compliance.
• Regulatory sources: Information received from PAGCOR or other Philippine regulatory authorities in the context of compliance obligations.

5. Purposes and Legal Basis for Processing

aaaji processes your personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of 2012:

• Account registration and management — necessary for the performance of the contract between you and aaaji.
• Age verification and identity verification (KYC) — required by PAGCOR licensing conditions and Philippine anti-money laundering laws (Republic Act No. 9160, as amended).
• Processing deposits and withdrawals — necessary for the performance of the contract and compliance with financial regulations.
• Providing customer support — necessary for the performance of the contract and aaaji's legitimate interest in maintaining service quality.
• Fraud prevention and platform security — aaaji's legitimate interest in protecting the platform and all players from fraudulent activity.
• Responsible gaming monitoring — PAGCOR compliance requirement and aaaji's legitimate interest in player welfare.
• Regulatory reporting and compliance — legal obligation under PAGCOR licensing conditions and Philippine law.
• Marketing communications — based on your consent, which may be withdrawn at any time without affecting the lawfulness of prior processing.
• Platform improvement and analytics — aaaji's legitimate interest in improving service quality, using aggregated and where possible anonymized data.

6. Sharing Your Personal Data

aaaji does not sell or rent personal data to third parties. aaaji may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment service providers: GCash, PayMaya, BPI, BDO, and Metrobank, solely for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC service providers used to verify your identity and age in compliance with PAGCOR requirements.
• Game content providers: Third-party game studios whose titles are hosted on the aaaji platform, which may receive anonymized session data for game integrity and audit purposes.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies where disclosure is required by law or regulatory obligation.
• IT and hosting service providers: Data processors engaged by aaaji to provide infrastructure, hosting, and cybersecurity services, subject to data processing agreements that require equivalent data protection standards.
• Legal and professional advisors: In connection with legal proceedings, regulatory investigations, or professional advisory services, subject to confidentiality obligations.

Where aaaji engages third-party data processors, such processors are bound by contractual data processing agreements that prohibit use of your personal data for any purpose other than providing the specified service to aaaji.

7. Data Retention

aaaji retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention requirements:

• Account and identity data: minimum five (5) years after account closure, as required by PAGCOR licensing conditions and Philippine AML regulations.
• Financial transaction records: minimum five (5) years from the date of the transaction.
• Gaming activity logs: minimum two (2) years from the date of the session.
• Support communications: minimum two (2) years from the date of the interaction.
• Marketing consent records: for the duration of your consent plus two (2) years after withdrawal.

After the applicable retention period expires, aaaji will securely delete or anonymize your personal data in a manner consistent with applicable Philippine data protection requirements.

8. Cookies and Tracking Technologies

aaaji uses cookies and similar tracking technologies to operate the platform, maintain your login session, detect fraud, and analyze platform usage. The following categories of cookies are used:

• Strictly necessary cookies: Required for platform operation, including session authentication and security tokens. These cannot be disabled without impairing platform functionality.
• Functional cookies: Remember your preferences such as language settings and responsible gaming configurations.
• Analytics cookies: Collect aggregated data about how players use the platform to help aaaji improve performance and user experience. Where possible, data is anonymized before analysis.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will affect your ability to use the aaaji platform, including the login function.

9. Your Rights Under the Data Privacy Act

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by aaaji:

To exercise any of these rights, please contact the aaaji Data Protection Officer at [email protected]. aaaji will respond to all data subject requests within thirty (30) days. If you are dissatisfied with aaaji's response, you may lodge a complaint with the National Privacy Commission of the Philippines.

10. Security Measures

aaaji implements the following technical and organizational measures to protect your personal data:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the aaaji platform.
• Encrypted storage for sensitive personal data, including identity verification documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security vulnerability assessments and penetration testing by independent cybersecurity specialists.
• Multi-factor authentication for all aaaji administrative systems that handle personal data.
• Incident response procedures aligned with NPC breach notification requirements under the Data Privacy Act of 2012.

In the event of a personal data breach that poses a real risk of serious harm to affected players, aaaji will notify affected individuals and the National Privacy Commission in accordance with the timelines prescribed by the Data Privacy Act and NPC Circular No. 16-03.

11. Children and Minors

The aaaji platform is strictly restricted to individuals aged 21 years and above as required by PAGCOR. aaaji does not knowingly collect personal data from individuals below the age of 21. If aaaji becomes aware that an account has been registered by or on behalf of a minor, the account will be immediately suspended, all funds returned to the deposit source, and the personal data of the minor deleted in accordance with NPC guidelines.

If you believe a minor has registered on the aaaji platform, please contact support immediately at [email protected].

12. Changes to This Privacy Policy

aaaji reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or platform operations. Material changes will be communicated to registered players via email or in-platform notification at least seven (7) days before taking effect. The "Last Updated" date at the top of this policy will always reflect the most recent revision.

Your continued use of the aaaji platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of and consent to the updated terms. If you do not accept the updated Privacy Policy, you should close your account and cease using the platform.

13. How to Contact Us

For questions, concerns, or requests relating to this Privacy Policy or the exercise of your data subject rights under the Philippine Data Privacy Act of 2012, please contact aaaji using the following channels:

• Email: [email protected] (attention: Data Protection Officer)
• Live Chat: Available 24 hours a day, 7 days a week, via the aaaji platform dashboard

If you are not satisfied with aaaji's response to your data privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines, which oversees enforcement of the Data Privacy Act of 2012.