Privacy Policy

1. Introduction

aaaji ("aaaji," "we," "us," or "our") operates the online gaming platform accessible at aaaji.net (the "Platform"). We are committed to protecting the privacy and personal data of every player who registers and uses our services. This Privacy Policy ("Policy") describes how aaaji collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform.

This Policy applies to all registered players, visitors to the aaaji website, and any individual whose personal data is processed by aaaji in connection with the Platform. By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

aaaji's data practices are governed by Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations. We are committed to full compliance with the DPA and to upholding the privacy rights of all Filipino players on our platform.

2. Personal Data We Collect

aaaji collects personal data that is necessary to operate the Platform, verify player identity, process financial transactions, and comply with applicable Philippine regulatory requirements. The categories of personal data we collect include the following:

2.1 Registration and Identity Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify the 21+ age requirement);
• Residential address, including city (e.g., Manila, Cebu, Davao, Quezon City, Makati);
• Email address and mobile number;
• Username and encrypted password;
• Government-issued identification documents submitted for KYC verification.

2.2 Financial and Transaction Data

• Deposit and withdrawal transaction records;
• Payment method details, including GCash account reference, PayMaya account reference, or bank account details for BPI, BDO, or Metrobank;
• Transaction amounts in Philippine Peso (₱ / PHP);
• Bonus and promotional activity records.

2.3 Gaming Activity Data

• Game session history, including games played, wagers placed, and outcomes;
• Betting patterns and platform usage statistics;
• Responsible gaming tool usage, including deposit limits and self-exclusion requests.

2.4 Technical and Device Data

• IP address and approximate geographic location;
• Device type, operating system, and browser information;
• Session timestamps and platform interaction logs;
• Cookie identifiers and similar tracking data.

2.5 Communications Data

• Records of communications between you and aaaji customer support;
• Feedback, complaints, and dispute records;
• Marketing communication preferences.

3. How We Collect Your Data

aaaji collects personal data through the following means:

3.1 Directly From You

The majority of personal data aaaji holds is provided directly by you when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion. You are responsible for ensuring that the information you provide to aaaji is accurate and up to date.

3.2 Automatically Through Platform Use

When you access and use the aaaji Platform, we automatically collect certain technical data, including your IP address, device information, browser type, and session activity. This data is collected through server logs, cookies, and similar tracking technologies as described in Section 8 of this Policy.

3.3 From Third-Party Payment Providers

When you make a deposit or withdrawal using GCash, PayMaya, BPI, BDO, Metrobank, or another supported payment method, aaaji receives transaction confirmation data from the relevant payment provider. aaaji does not store full payment credentials — only the reference information necessary to process and reconcile transactions.

3.4 From Identity Verification Services

aaaji may use third-party identity verification services to assist with KYC compliance. These services may cross-reference the identity documents you submit against authoritative data sources to confirm your identity. Any data shared with such services is governed by appropriate data processing agreements.

4. How We Use Your Personal Data

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

aaaji will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to fulfil our obligations to you under the aaaji Terms and Conditions, including account management, payment processing, and provision of gaming services;
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering obligations, KYC requirements, and regulatory reporting;
• Legitimate interests: Processing necessary for aaaji's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your privacy rights;
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of marketing communications. You may withdraw your consent at any time by updating your communication preferences in your account settings or by contacting our support team.

6. Sharing Your Personal Data

aaaji does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

6.1 Payment Service Providers

We share transaction data with payment service providers such as GCash, PayMaya, and partner banks (BPI, BDO, Metrobank) to process your deposits and withdrawals. These providers act as independent data controllers for their own services and are subject to their own privacy policies.

6.2 Identity Verification and Compliance Partners

aaaji may share identity documents and related data with third-party KYC and anti-money laundering compliance service providers. All such providers are bound by data processing agreements that require them to handle your data in accordance with applicable privacy laws.

6.3 Technology and Infrastructure Providers

aaaji uses third-party technology providers for hosting, platform infrastructure, and game content delivery. These providers process data on aaaji's behalf and are contractually prohibited from using your data for their own purposes.

6.4 Regulatory and Law Enforcement Authorities

aaaji may disclose personal data to Philippine regulatory authorities, law enforcement agencies, or other government bodies where required by law, court order, or regulatory direction. This includes disclosures required under Philippine anti-money laundering legislation.

6.5 Business Transfers

In the event of a merger, acquisition, or sale of all or part of aaaji's business, your personal data may be transferred to the relevant successor entity. You will be notified of any such transfer and your rights under this Policy will continue to apply.

7. Data Retention

aaaji retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve any disputes or enforce our agreements. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine anti-money laundering record-keeping requirements;
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction;
• Gaming activity data: Retained for the duration of your account and for three (3) years following account closure;
• Customer support communications: Retained for three (3) years from the date of the communication;
• Marketing preferences: Retained until you withdraw your consent or close your account.

Upon expiry of the applicable retention period, aaaji will securely delete or anonymise your personal data in accordance with our data disposal procedures.

8. Cookies and Tracking Technologies

aaaji uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyse usage patterns, and deliver a personalised experience. The following categories of cookies are used on the aaaji Platform:

• Essential cookies: Required for the Platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled without affecting Platform functionality;
• Performance cookies: Used to collect anonymised data about how players use the Platform, helping us identify areas for improvement. No personally identifiable information is collected through performance cookies;
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalised experience;
• Analytics cookies: Used to understand aggregate player behaviour and Platform usage trends. Data collected through analytics cookies is processed in anonymised or pseudonymised form.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the aaaji Platform. For more information on managing cookies, refer to your browser's help documentation.

9. Your Data Rights

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

• Right to be informed: You have the right to be informed about how aaaji collects and uses your personal data, as set out in this Policy;
• Right of access: You have the right to request a copy of the personal data aaaji holds about you;
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you;
• Right to erasure: You have 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: You have the right to object to the processing of your personal data for direct marketing purposes at any time;
• Right to data portability: You have the right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, please contact the aaaji support team. We will respond to all data rights requests within thirty (30) days of receipt. We may require you to verify your identity before processing your request.

10. Data Security

aaaji implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the aaaji Platform;
• Encryption of sensitive data at rest, including identity documents and financial information;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of Platform infrastructure;
• Multi-factor authentication options for player accounts;
• Continuous monitoring for suspicious activity and potential security incidents.

While aaaji takes all reasonable steps to protect your personal data, no online 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, aaaji will notify you and the National Privacy Commission of the Philippines in accordance with the requirements of the Data Privacy Act of 2012.

11. Children and Minors

The aaaji Platform is strictly intended for individuals who are at least twenty-one (21) years of age. aaaji does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you believe that a minor has registered an account on aaaji or that we have inadvertently collected personal data from a minor, please contact our support team immediately so that we can investigate and take appropriate action.

12. Changes to This Privacy Policy

aaaji reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. Where changes are material, we will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is indicated at the top of this page. We encourage you to review this Policy periodically to stay informed about how aaaji protects your personal data. Your continued use of the Platform following any update to this Policy constitutes your acceptance of the revised terms.

13. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or aaaji's handling of your personal data, please contact our Data Privacy team. We are committed to addressing all privacy-related enquiries promptly and transparently.

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you are not satisfied with aaaji's response to your privacy concern. For more information on your rights under the Data Privacy Act of 2012, you may visit the National Privacy Commission's official resources.