Privacy Policy — aecph

aecph ("aecph," "we," "us," or "our") is committed to protecting the privacy and personal data of all users of the aecph platform ("Platform"). This Privacy Policy describes how we collect, use, disclose, store, and protect your personal information when you access or use our website, mobile platform, and associated services.

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC") of the Philippines. It should be read together with our Terms & Conditions.

By registering an account with aecph or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Privacy Policy, please discontinue use of the Platform.

aecph collects personal data in the following categories:

2.1 Data You Provide Directly

• Registration data: Full legal name, date of birth, gender, nationality, residential address, email address, and mobile number.
• Identity verification (KYC) data: Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's licence), proof of address, and selfie photographs for identity verification purposes.
• Financial data: Payment method details including GCash account numbers, PayMaya account numbers, bank account details (BPI, BDO, Metrobank), and card information (Visa, Mastercard) as required to process deposits and withdrawals.
• Communications data: Records of your correspondence with our customer support team, including chat logs, emails, and call recordings where applicable.
• Responsible gaming data: Information you provide when setting deposit limits, requesting self-exclusion, or accessing responsible gaming tools.

2.2 Data Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage data: Pages visited, games played, betting history, session duration , timestamps, deposit and withdrawal amounts, and bonus activity.
• Location data: General geographic location derived from your IP address, used to verify jurisdictional eligibility and comply with regulatory requirements.
• Cookie and tracking data: Information collected through cookies, web beacons, and similar technologies as described in Section 6 of this Policy.

aecph processes your personal data for the following purposes:

• Account creation and management: To register your aecph account, verify your identity, and maintain your account in good standing.
• Service delivery: To provide access to games, process bets and wagers, credit winnings, and deliver the full range of aecph platform features.
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, and to verify that payment methods are registered in your name.
• KYC and regulatory compliance: To verify your age (21+), identity, and residential address in compliance with PAGCOR regulations and Philippine anti-money laundering laws.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform.
• Responsible gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools including deposit limits, cooling-off periods, and self-exclusion.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, subject to your communication preferences and applicable opt-out rights.
• Platform improvement: To analyse usage patterns, conduct research, and improve the functionality, content, and user experience of the aecph platform.
• Legal obligations: To comply with applicable Philippine laws, regulatory directives from PAGCOR, and orders from competent courts or government authorities.

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

• Contractual necessity: Processing required to perform our obligations under the aecph Terms & Conditions, including account management, game delivery, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR licensing conditions, the Anti-Money Laundering Act (Republic Act No. 9160, as amended), and the Data Privacy Act of 2012.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and business analytics, where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where we have obtained your prior consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

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

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and identity verification service providers engaged to assist with age and identity verification in compliance with PAGCOR requirements.
• Game content providers: Licensed game studios and software providers whose games are available on the aecph platform, to the extent necessary to deliver game services.
• Fraud prevention and security providers: Third-party fraud detection and cybersecurity service providers engaged to protect the integrity of the Platform.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory directive.
• Professional advisers: Legal counsel, auditors, and other professional advisers engaged by aecph, subject to confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of all or substantially all of aecph's assets, your personal data may be transferred to the successor entity, subject to equivalent privacy protections.

aecph uses cookies and similar tracking technologies to enhance your experience on the Platform. A cookie is a small text file placed on your device when you visit our website. We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session authentication cookies and security tokens. These cookies cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to personalise your experience on aecph.
• Analytics cookies: Used to collect anonymised data about how users interact with the Platform, including pages visited, session duration, and navigation paths. This data helps us improve the Platform.
• Marketing cookies: Used to deliver relevant promotional content and track the effectiveness of our marketing campaigns. These cookies are only placed with your consent.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the aecph Platform. For detailed information on the specific cookies we use, please contact us at [email protected].

aecph retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, in compliance with PAGCOR licensing conditions and the Anti-Money Laundering Act.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine financial regulations.
• Customer support records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications, after which it is deleted or anonymised within 30 days.
• Technical and usage data: Retained for up to twelve (12) months, after which it is anonymised or deleted.

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

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the aecph Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls limiting access to personal data to authorised personnel with a legitimate business need.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and responding to personal data breaches in accordance with NPC notification requirements.

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

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by aecph:

• Right to be informed: The right to be informed of how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data aecph holds about you, together with information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• 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 our legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• 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) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please submit a written request to our Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will respond to your request within fifteen (15) business days in accordance with NPC guidelines.

The aecph Platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations and Philippine law governing online gambling. aecph does not knowingly collect personal data from individuals under the age of 21.

If aecph discovers or is notified that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the associated personal data, and report the matter to the appropriate regulatory authorities where required.

If you are a parent or guardian and believe that a minor in your care has registered an account with aecph or provided personal data to us, please contact our support team immediately at [email protected].

aecph primarily stores and processes personal data within the Philippines. In certain circumstances, your personal data may be transferred to, or accessed by, service providers or partners located outside the Philippines — for example, where we use internationally hosted cloud infrastructure or engage overseas technology providers.

Where personal data is transferred outside the Philippines, aecph ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act of 2012 and NPC guidelines. Such safeguards may include:

• Contractual data processing agreements incorporating NPC-approved standard contractual clauses.
• Transfers to countries or organisations that the NPC has determined provide an adequate level of data protection.
• Other legally recognised transfer mechanisms as approved by the NPC from time to time.

You may request further information about the safeguards applicable to international transfers of your personal data by contacting our Data Protection Officer at [email protected].

aecph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered users by email or by posting a prominent notice on the Platform at least seven (7) days before the changes take effect.

The most current version of this Privacy Policy will always be available on this page, with the "Last Updated" date reflecting the date of the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how aecph protects your personal data.

Your continued use of the aecph Platform after the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with the changes, you may request account closure as described in our Terms & Conditions.

aecph 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, please contact our DPO:

Data Protection Officer — aecph
Email: [email protected]
Subject line: "Data Privacy Request"

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. For more information about your rights as an aecph player, please also review our Terms & Conditions and Responsible Gaming pages.