aaopen Privacy Policy

This Privacy Policy is issued by aaopen ("aaopen," "we," "us," or "our"), the operator of the online gaming platform accessible at https://aaopen.app (the "Platform"). aaopen is the data controller responsible for the personal data of users ("you," "Player," or "User") collected through the Platform.

aaopen is committed to protecting the privacy and personal data of all players in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines (the "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

By registering an account on the aaopen Platform or by continuing to use our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein.

aaopen collects the following categories of personal data from players and visitors to the Platform:

Identity & Contact Data:

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification — players must be 21 years of age or older)
• Residential address in the Philippines
• Email address
• Mobile phone number
• Nationality and citizenship

Identity Verification (KYC) Data:

• Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, UMID, PhilHealth ID, driver's license, or Voter's ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or live photo for identity verification purposes

Financial Data:

• GCash account number or registered mobile number
• PayMaya / Maya account details
• Bank account details (account name, account number, bank name) for withdrawal processing
• Debit card details (card number, expiry date — stored in tokenized form only)
• Transaction history, including deposit amounts, withdrawal amounts, and dates

Gaming & Behavioral Data:

• Game history, including games played, bet amounts, wins, and losses
• Session duration and frequency of play
• Bonus and promotion usage history
• Responsible gaming tool usage (deposit limits, self-exclusion requests)

Technical & Device Data:

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Cookies and similar tracking technologies (see Section 7)
• Login timestamps and session logs

Communications Data:

• Records of your communications with aaopen customer support, including live chat transcripts and email correspondence
• Survey responses and feedback submitted through the Platform

aaopen collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and behavioral data collected automatically when you access and use the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from GCash, PayMaya, and banking partners (limited to what is necessary to process transactions).
• Regulatory sources: Information received from PAGCOR or other Philippine regulatory bodies in connection with our licensing obligations.

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

• Account management: To create, maintain, and manage your aaopen player account, including verifying your identity and age.
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the full range of aaopen Platform services.
• KYC & compliance: To verify your identity in compliance with Philippine anti-money laundering (AML) laws, PAGCOR licensing requirements, and the Data Privacy Act of 2012.
• Fraud prevention & security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the Platform.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible gaming: To monitor gaming behavior for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Marketing & promotions: To send you information about aaopen promotions, bonuses, and new games — but only where you have given your explicit consent to receive such communications. You may withdraw this consent at any time.
• Platform improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the aaopen Platform.
• Legal obligations: To comply with applicable Philippine laws, court orders, and regulatory requirements.

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

• Contractual necessity: Processing required to perform our contract with you — i.e., to provide the aaopen gaming services you have registered for, including account management, game access, and payment processing.
• Legal obligation: Processing required to comply with Philippine law, including AML obligations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate interests: Processing necessary for aaopen's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring — provided these interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

aaopen does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, and banking partners — to process deposits and withdrawals on your behalf.
• KYC & identity verification providers: Third-party services that assist aaopen in verifying player identities and ages in compliance with Philippine law.
• Fraud prevention & AML partners: Services that help aaopen detect and prevent fraudulent activity and money laundering.
• Game software providers: Third-party game developers and live dealer studios whose games are available on the aaopen Platform — limited to the data necessary to deliver the game service.
• IT & hosting providers: Cloud infrastructure and data hosting providers that support the operation of the aaopen Platform.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies — where required by law or regulatory obligation.
• Legal advisors: Where necessary to obtain legal advice or to establish, exercise, or defend legal claims.

All third-party service providers engaged by aaopen are contractually required to process personal data only in accordance with aaopen's instructions and in compliance with the Data Privacy Act of 2012.

aaopen uses cookies and similar tracking technologies to enhance your experience on the Platform, to maintain your session, and to analyze Platform usage. The following categories of cookies are used on the aaopen Platform:

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in during your visit and security cookies that protect against cross-site request forgery. These cookies cannot be disabled.
• Functional cookies: Used to remember your preferences, such as your preferred language, display settings, and responsible gaming tool configurations. Disabling these cookies may affect the functionality of certain Platform features.
• Analytics cookies: Used to collect anonymized data about how players use the Platform — including which pages are visited most frequently and how long players spend on each page. This data helps aaopen improve the Platform experience. Analytics data is aggregated and does not identify individual players.
• Marketing cookies: Used to deliver relevant promotional content to you based on your gaming interests and behavior on the Platform. These cookies are only set with your explicit consent.

You may manage your cookie preferences at any time through your browser settings. Please note that disabling certain cookies may limit your ability to use some features of the aaopen Platform. For a full list of cookies used on the Platform, please contact our support team.

aaopen retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account data: Retained for the duration of your account and for a period of five (5) years following account closure, in compliance with Philippine AML regulations and PAGCOR licensing requirements.
• KYC & identity verification documents: Retained for a minimum of five (5) years from the date of collection, as required by the Anti-Money Laundering Act of 2001 (Republic Act No. 9160, as amended).
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Customer support communications: Retained for two (2) years from the date of the last communication, unless a longer retention period is required for dispute resolution or legal proceedings.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of the consent given.
• Technical and device data (logs): Retained for twelve (12) months from the date of collection, unless required for longer periods for security investigations.

Upon expiry of the applicable retention period, aaopen will securely delete or anonymize your personal data in accordance with its data disposal procedures. Where data is anonymized rather than deleted, the anonymized data may be retained indefinitely for statistical and analytical purposes, as it can no longer be used to identify you.

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

• 256-bit SSL/TLS encryption: All data transmitted between your device and the aaopen Platform is encrypted using industry-standard SSL/TLS protocols — the same level of encryption used by major Philippine banks.
• Data encryption at rest: Sensitive personal data stored on aaopen's servers, including financial data and KYC documents, is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data is restricted to aaopen employees and contractors who have a legitimate need to access it for their job functions. All staff with access to personal data are subject to confidentiality obligations.
• Two-factor authentication (2FA): aaopen supports and encourages the use of two-factor authentication for player accounts to provide an additional layer of security.
• Regular security audits: aaopen conducts regular security assessments and penetration testing to identify and address potential vulnerabilities in the Platform.
• Incident response: aaopen maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, aaopen will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

While aaopen 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 account credentials and for notifying aaopen immediately if you suspect any unauthorized access to your account.

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

• Right to be informed: The right to be informed of how your personal data is being collected, processed, and used — which is the primary purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data aaopen 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 aaopen holds 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 aaopen's 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 aaopen's legitimate interests.
• Right to data portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller 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 that aaopen has violated your data privacy rights.

To exercise any of the above rights, please submit a written request to our Data Protection Officer at [email protected]. aaopen will respond to all verified data subject requests within thirty (30) calendar days of receipt. We may request proof of identity before processing your request to ensure the security of your personal data.

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

As part of our registration process, all players are required to confirm that they are at least 21 years of age and to submit government-issued identification for age verification. Any account found to be held by a person under 21 years of age will be immediately closed, all funds returned to the depositing payment method, and all personal data associated with the account deleted in accordance with our data retention procedures.

If you believe that aaopen has inadvertently collected personal data from a person under the age of 21, please contact us immediately at [email protected] so that we can take prompt corrective action.

aaopen primarily stores and processes personal data within the Philippines. However, some of our third-party service providers — including cloud infrastructure providers, KYC verification services, and game software providers — may process personal data in jurisdictions outside the Philippines.

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

• Contractual clauses requiring the recipient to process personal data to the same standard as required under Philippine law.
• Transfers to jurisdictions that have been assessed as providing an adequate level of data protection.
• Binding corporate rules where the recipient is part of the same corporate group as aaopen.

By using the aaopen Platform, you consent to the transfer of your personal data to third-party service providers outside the Philippines, subject to the safeguards described above.

The aaopen Platform may contain references to third-party services, including payment providers such as GCash and PayMaya. When you interact with these third-party services — for example, when making a deposit via GCash — you will be subject to the privacy policy of that third-party provider, not this Privacy Policy.

aaopen is not responsible for the privacy practices of third-party service providers. We encourage you to review the privacy policies of any third-party services you use in connection with your aaopen account. aaopen selects its third-party partners carefully and requires all partners to maintain appropriate data protection standards, but we cannot guarantee the privacy practices of external services.

aaopen reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When material changes are made to this Privacy Policy, aaopen will notify registered players by email to the address on file and/or by posting a prominent notice on the Platform.

The updated Privacy Policy will take effect on the date specified in the notice. Your continued use of the aaopen Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised policy. If you do not agree to the updated Privacy Policy, you must cease using the Platform and may request account closure.

The most current version of this Privacy Policy will always be available at https://aaopen.app/privacy-policy. The "Last Updated" date at the top of this page indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way aaopen processes your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• Subject line: "Data Privacy Request — [Your Full Name]"
• Response time: Within 72 hours for general inquiries; within 30 calendar days for formal data subject requests
• Live Chat: Available 24/7 via the aaopen Platform for general privacy questions

If you are not satisfied with aaopen's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the government body responsible for administering and implementing the Data Privacy Act of 2012.