aaaji Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how aaaji ("aaaji," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of users ("you," "Player," or "User") who access or use the aaaji online casino platform available at aaaji.app (the "Platform").

aaaji is committed to protecting the privacy and personal data of all Filipino players in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as applicable PAGCOR data governance standards. By registering an account or using the Platform, you consent to the collection and use of your personal information as described in this Policy.

Please read this Policy carefully. If you do not agree with any part of this Policy, you should not use the aaaji Platform. This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, aaaji acts as the Personal Information Controller (PIC) in respect of the personal data you provide when using the Platform. aaaji has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data privacy laws. Contact details for the DPO are provided in Section 15 of this Policy.

3. Data We Collect

aaaji collects the following categories of personal data from registered players and Platform visitors:

aaaji does not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect biometric data, health information, or political affiliations.

4. How We Collect Your Data

aaaji collects personal data through the following means:

• Direct interactions: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, server logs, and session tracking technologies (see Section 8).
• Third-party sources: Identity verification data from government-authorized KYC service providers; fraud screening data from licensed anti-fraud service providers; payment data from GCash, Maya, and banking partners as part of transaction processing.
• Regulatory sources: Information received from PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine regulatory bodies in connection with compliance obligations.

5. How We Use Your Data

aaaji uses your personal data for the following purposes:

• To create, manage, and maintain your aaaji player account;
• To verify your identity and age in compliance with PAGCOR regulations and Philippine law;
• To process deposits and withdrawals via GCash, Maya, and Philippine bank transfers;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities;
• To monitor gaming activity for responsible gaming purposes, including identifying signs of problem gambling;
• To administer bonuses, promotions, and loyalty programs;
• To provide customer support and resolve disputes;
• To send you transactional communications (account notices, security alerts, withdrawal confirmations);
• To send you promotional communications, where you have consented to receive them;
• To improve the Platform's features, performance, and user experience through aggregate analytics;
• To comply with applicable Philippine laws, PAGCOR directives, and AMLC reporting obligations.

aaaji does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review.

6. Legal Basis for Processing

aaaji processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the aaaji Terms & Conditions, including account management and payment processing;
• Legal obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, NPC requirements, and other applicable Philippine laws;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing and Disclosure

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

7.2 aaaji may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements:

• KYC and identity verification providers: Licensed third-party providers engaged to verify your identity and age in compliance with PAGCOR requirements;
• Payment processors: GCash, Maya, and Philippine banking partners, solely for the purpose of processing your deposits and withdrawals;
• Fraud prevention and security providers: Licensed service providers engaged to detect and prevent fraudulent activity on the Platform;
• IT and infrastructure providers: Cloud hosting and technology service providers who process data on aaaji's behalf under strict data processing agreements;
• Regulatory authorities : PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law or regulatory directive;
• Professional advisers: Legal counsel, auditors, and compliance consultants, where necessary for the conduct of aaaji's business and subject to professional confidentiality obligations.

7.3 In the event of a merger, acquisition, or sale of all or substantially all of aaaji's assets, your personal data may be transferred to the successor entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer via the email address registered to your account.

7.4 All third-party service providers engaged by aaaji are contractually required to process your personal data only in accordance with aaaji's instructions and applicable Philippine data privacy law.

8. Cookies and Tracking Technologies

8.1 aaaji uses cookies and similar technologies (such as local storage and session tokens) to operate and improve the Platform. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function, including session authentication, security tokens, and load balancing. These cannot be disabled without impairing Platform functionality.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics cookies: Used to collect aggregate, anonymized data about how players use the Platform, helping aaaji identify areas for improvement. No individual player is identified through analytics data.

8.2 aaaji does not use third-party advertising cookies, cross-site tracking pixels, or behavioral profiling technologies on the Platform.

8.3 You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may prevent you from accessing certain features of the Platform, including your account login.

9. Data Security

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

• 256-bit SSL/TLS encryption for all data in transit between your device and aaaji's servers;
• AES-256 encryption for sensitive data stored at rest, including financial information and government ID data;
• Multi-factor authentication (MFA) for all aaaji administrative systems;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular penetration testing and vulnerability assessments conducted by independent security specialists;
• 24/7 intrusion detection and security monitoring systems;
• Secure data centers with physical access controls, located within the Philippines where operationally feasible.

9.2 In the event of a personal data breach that is likely to result in harm to affected players, aaaji will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act of 2012 and NPC Circular 16-03.

9.3 While aaaji takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your aaaji login credentials and for notifying aaaji immediately if you suspect unauthorized access to your account.

10. Data Retention

10.1 aaaji retains your personal data for as long as your account remains active and for such additional periods as are required by applicable Philippine law and regulatory obligations, including:

• Account and transaction records: Retained for a minimum of five (5) years following account closure, in compliance with AMLA requirements;
• KYC and identity verification documents: Retained for a minimum of five (5) years following the end of the business relationship, as required by PAGCOR and AMLC regulations;
• Customer support communications: Retained for three (3) years from the date of the interaction, for dispute resolution and quality assurance purposes;
• Technical and usage logs: Retained for twelve (12) months for security and fraud prevention purposes, after which they are anonymized or deleted;
• Marketing consent records: Retained for the duration of your account and for three (3) years following account closure or withdrawal of consent.

10.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with aaaji's data disposal procedures.

11. Your Data Privacy Rights

11.1 Under the Data Privacy Act of 2012 (RA 10173), you have the following rights in respect of your personal data held by aaaji:

• Right to be informed: The right to be notified of how your personal data is collected, used, and processed, as set out in this Policy;
• Right of access: The right to request a copy of the personal data aaaji holds about you, along 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 aaaji;
• 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 aaaji's legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

11.2 To exercise any of the above rights, please contact aaaji's Data Protection Officer using the contact details provided in Section 15. aaaji will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11.3 aaaji may need to verify your identity before processing a data subject request to ensure that personal data is not disclosed to unauthorized parties.

12. Children's and Minors' Privacy

12.1 The aaaji Platform is strictly intended for adults aged twenty-one (21) years and above, in compliance with Philippine gambling regulations. aaaji does not knowingly collect personal data from persons under the age of 21.

12.2 If aaaji becomes aware that personal data has been collected from a person under the age of 21, such data will be deleted immediately and the associated account will be closed. If you believe that a minor has registered an account on aaaji, please contact our support team immediately.

13. Third-Party Links

13.1 The aaaji Platform may contain references to third-party services, such as payment providers (GCash, Maya, Philippine banks). aaaji is not responsible for the privacy practices of these third parties. We encourage you to review the privacy policies of any third-party services you use in connection with your aaaji account.

13.2 aaaji does not embed third-party social media widgets, advertising networks, or external tracking scripts on the Platform.

14. Changes to This Policy

14.1 aaaji reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. The most current version of this Policy will always be available on the Platform, with the effective date clearly indicated at the top of the page.

14.2 Where changes are material, aaaji will notify registered players via the email address on file or through a prominent notice on the Platform at least fourteen (14) days before the changes take effect. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

14.3 If you do not agree to any amended Policy, you must cease using the Platform and may request account closure in accordance with the aaaji Terms & Conditions.

15. Contact Us & Data Protection Officer

15.1 If you have any questions, concerns, or requests regarding this Privacy Policy or aaaji's data practices, please contact our Data Protection Officer (DPO):

• Email: [email protected] (plain text — not a clickable link)
• Support: [email protected] (plain text — not a clickable link)
• Response time: aaaji aims to acknowledge all privacy-related inquiries within two (2) business days and to resolve them within fifteen (15) business days.

15.2 If you are not satisfied with aaaji's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about the NPC and how to file a complaint is available through official Philippine government channels.