Privacy Policy

For the purposes of this Policy, the following definitions apply:

• "Personal Information" — any information, whether recorded in a material form or not, from which the identity of an individual is apparent or can be reasonably and directly ascertained, as defined under the DPA.
• "Sensitive Personal Information" — personal information about an individual's race, ethnic origin, marital status, age, colour, and religious, philosophical or political affiliations; health, education, genetic or sexual life; court proceedings, legal offences, or government-issued identification numbers; as defined in Section 3(l) of the DPA.
• "Processing" — any operation performed upon personal data including, but not limited to, collection, recording, organisation, storage, updating, retrieval, consultation, use, consolidation, blocking, erasure, or destruction of data.
• "Data Controller" — aroonplay, as the entity that determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" — any natural or legal person, public authority, or other body that processes personal data on behalf of aroonplay.
• "DPO" — the Data Protection Officer appointed by aroonplay to oversee compliance with the DPA and to serve as the point of contact for data subject rights enquiries.
• "KYC" — Know Your Customer, the identity verification process required before a Player may withdraw funds from their aroonplay account.

2.1 This Policy applies to all personal data collected and processed by aroonplay in connection with the registration, operation, and support of Player accounts on the aroonplay Platform, including data collected through: (a) the account registration form; (b) the KYC verification process; (c) deposit and withdrawal transactions; (d) customer support interactions; (e) use of games and betting markets on the Platform; and (f) cookies and tracking technologies used on aroonplay.org.

2.2 This Policy applies to all natural persons who interact with the aroonplay Platform, regardless of whether they are registered account holders, and regardless of whether they access the Platform from within the Philippines or from overseas.

2.3 aroonplay is registered as a Personal Information Controller with the National Privacy Commission of the Philippines in accordance with NPC Registration requirements.

3.1 aroonplay collects the following categories of personal data from Players and prospective Players:

3.2 aroonplay does not intentionally collect Sensitive Personal Information beyond what is strictly required for age verification and identity confirmation during KYC processing. Where such data appears incidentally on a submitted government ID, it is not separately recorded or processed beyond what is necessary for verification purposes.

3.3 aroonplay does not collect complete payment card numbers. Where card-based payment options are available, full card numbers are processed exclusively by PCI-DSS-compliant payment processors and are not stored on aroonplay's systems.

4.1 aroonplay processes personal data on the following legal bases under the Data Privacy Act of 2012:

• Consent (Section 12(a) DPA): Where you have provided explicit consent during account registration, including consent to the processing of your personal data as described in this Policy.
• Contractual Necessity (Section 12(b) DPA): Processing necessary for the performance of the contract between you and aroonplay, including operating your gaming account, processing deposits and withdrawals, and delivering gaming services.
• Compliance with a Legal Obligation (Section 12(c) DPA): Processing required to comply with PAGCOR regulations, anti-money laundering obligations under Republic Act No. 9160 (Anti-Money Laundering Act), and tax reporting requirements under the National Internal Revenue Code.
• Legitimate Interests (Section 12(f) DPA): Processing necessary for the legitimate interests pursued by aroonplay, including fraud prevention, platform security, responsible gaming enforcement, and platform improvement, provided such interests are not overridden by your fundamental rights and freedoms.

5.1 aroonplay uses the personal data it collects for the following specific purposes:

1. Account Management: To create, maintain, and administer your aroonplay account, including processing your registration, verifying your identity through KYC, and managing your account settings and preferences.
2. Payment Processing: To process deposits and withdrawals through GCash, Maya, bank transfer, and other approved Philippine payment channels, including verifying that payment accounts are registered in your name.
3. Gaming Services: To provide access to aroonplay's game library, process wagers and winnings, apply bonus entitlements, and maintain your gaming history and account balance.
4. Regulatory Compliance: To fulfil aroonplay's obligations under PAGCOR regulations, including player identity verification, responsible gaming monitoring, transaction reporting, and anti-money laundering due diligence.
5. Customer Support: To respond to enquiries, resolve disputes, process complaints, and communicate with you regarding your aroonplay account.
6. Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, unauthorised account access, bonus abuse, and other misconduct on the Platform.
7. Responsible Gaming: To monitor gaming patterns that may indicate problem gambling behaviour, to apply self-exclusion and deposit limit tools, and to comply with PAGCOR's responsible gaming requirements.
8. Promotional Communications: Where you have consented, to send you personalised promotional offers, bonus notifications, and gaming updates. You may withdraw consent to marketing communications at any time via your account settings.
9. Platform Improvement: To analyse aggregated usage patterns to improve the aroonplay Platform's performance, design, and game offerings — using anonymised or pseudonymised data where possible.

6.1 aroonplay uses cookies and similar tracking technologies on aroonplay.org to operate the Platform, enhance user experience, and collect the technical data described in Section 3. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without impairing core Platform functionality.
• Functional Cookies: Used to remember your preferences, including language settings, game lobby view preferences, and login session persistence on trusted devices.
• Analytics Cookies: Used to collect anonymised or pseudonymised data about how Players use the aroonplay Platform, enabling improvements to navigation, game discovery, and overall performance. aroonplay uses privacy-compliant analytics tools.
• Security Cookies: Used to detect and prevent fraudulent login attempts, identify unusual session behaviour, and support aroonplay's account security systems.

6.2 You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to log in to and use the aroonplay Platform. aroonplay does not use third-party advertising cookies or behavioural advertising tracking technologies.

7.1 aroonplay does not sell, rent, or commercially transfer your personal data to third parties. aroonplay discloses personal data only in the following limited circumstances:

• Payment Processors: Your financial data is shared with aroonplay's approved Philippine payment partners (including GCash, Maya, and banking partners) solely to the extent necessary to process your transactions. These processors are contractually bound to process data only for the purpose of transaction completion.
• KYC and Identity Verification Providers: Your identity documents may be processed by aroonplay's contracted KYC verification service provider for identity authentication purposes. Such providers operate under data processing agreements consistent with the DPA.
• Regulatory Authorities: aroonplay is required to disclose player data to PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other Philippine government agencies as required by law, regulation, or court order.
• Fraud Prevention Services: Anonymised or pseudonymised transaction data may be shared with industry-standard fraud prevention networks to protect aroonplay and its Players from fraud, money laundering, and financial crime.
• Game Providers: Technical session data (but not identity data) may be shared with aroonplay's licensed game providers for the purpose of game operation, dispute resolution, and jackpot processing.
• Professional Advisers: aroonplay may share personal data with its legal advisers, auditors, and compliance consultants where strictly necessary and subject to professional confidentiality obligations.

7.2 All third parties with whom aroonplay shares personal data are required to maintain the security and confidentiality of that data and to process it only for the specific authorised purposes. aroonplay does not permit third-party processors to use Player data for their own marketing or commercial purposes.

8.1 aroonplay retains personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your aroonplay account and for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• KYC Documents: Retained for a minimum of five (5) years from the date of account closure or from the date of the last transaction on the account, whichever is later.
• Financial Transaction Records: Retained for a minimum of ten (10) years in accordance with Philippine tax law and AMLC record-keeping requirements.
• Gaming Activity Data: Retained for a minimum of five (5) years for responsible gaming monitoring, regulatory reporting, and dispute resolution purposes.
• Support Communications: Retained for three (3) years following the closure of the relevant support interaction for quality assurance and dispute resolution purposes.
• Technical and Log Data: Retained for up to twelve (12) months for security monitoring and platform performance purposes.

8.2 Upon expiry of the applicable retention period, aroonplay will securely delete or anonymise personal data in a manner that prevents reconstruction of the original data.

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and aroonplay's servers;
• Encryption of stored personal data and KYC documents using industry-standard encryption protocols;
• Role-based access controls limiting access to personal data to authorised personnel with a legitimate operational need;
• Regular security audits, penetration testing, and vulnerability assessments of the aroonplay Platform;
• Two-factor authentication for Player accounts and for aroonplay's internal administrative systems;
• Physical and logical access controls on aroonplay's server infrastructure;
• Data processing agreements with all third-party processors specifying security obligations.

9.2 Data Breach Notification. In the event of a personal data breach that is likely to result in harm to affected Data Subjects, aroonplay will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected Players without undue delay, in accordance with NPC Circular 16-03 and the DPA's breach notification requirements.

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

1. Right to be Informed: You have the right to be informed of the manner in which your personal data is being processed by aroonplay, including the purposes of processing, the recipients of the data, and your rights as a data subject — as described in this Policy.
2. Right of Access: You have the right to request a copy of the personal data that aroonplay holds about you, together with information about how that data is processed.
3. Right to Correction: You have the right to request correction of any inaccurate or incomplete personal data that aroonplay holds about you.
4. Right to Erasure / Blocking: You have the right to request the deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, or where processing was based on consent that you have since withdrawn, subject to aroonplay's legal retention obligations.
5. Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes, or to processing based on legitimate interests where your interests, rights, or freedoms override those interests.
6. Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format, and to transmit it to another controller where technically feasible.
7. Right to File a Complaint: You have the right to file a complaint with the National Privacy Commission of the Philippines if you believe aroonplay has violated your rights under the Data Privacy Act of 2012.
8. Right to Damages: You have the right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of personal data, subject to applicable law.

10.2 To exercise any of the rights described in this Section, please contact aroonplay's Data Protection Officer at the contact details set out in Section 15. aroonplay will respond to all data subject rights requests within fifteen (15) calendar days of receipt, unless the complexity of the request requires a longer period, in which case aroonplay will notify you of the extended timeline.

11.1 The aroonplay Platform is strictly for use by adults aged 21 years and above in compliance with PAGCOR regulations. aroonplay does not knowingly collect personal data from individuals under the age of 21.

11.2 All new aroonplay accounts are subject to KYC verification that confirms the account holder's date of birth. Any account found to belong to a person under 21 years of age will be closed immediately, the account balance returned, and any personal data collected will be deleted except to the extent required for incident reporting purposes.

11.3 Parents or guardians who become aware that a minor has accessed the aroonplay Platform using their account or has independently registered an account at aroonplay must contact aroonplay support immediately at [email protected].

12.1 Where aroonplay transfers personal data to data processors or service providers located outside the Philippines — including, for example, internationally operated game studio providers or cloud infrastructure services — aroonplay ensures that such transfers comply with Section 21 of the Data Privacy Act of 2012 and the NPC's applicable circulars on cross-border data transfers.

12.2 aroonplay requires all overseas data processors to maintain data protection standards equivalent to those required under the Philippine DPA, and to process transferred data only for the specific authorised purposes described in their data processing agreements with aroonplay.

13.1 The aroonplay Platform integrates with third-party services including payment gateways (GCash, Maya, BPI, BDO, Metrobank, and others), game providers, and identity verification services. These third parties operate under their own privacy policies, and aroonplay is not responsible for the data practices of third-party service providers except to the extent governed by aroonplay's data processing agreements with them.

13.2 aroonplay recommends that Players review the privacy policies of any third-party payment service they use in connection with their aroonplay account, including GCash (operated by G-Xchange, Inc.) and Maya (operated by PayMaya Philippines, Inc.), as aroonplay's Privacy Policy does not extend to those third-party platforms.

14.1 aroonplay reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in applicable law, changes in aroonplay's data processing practices, or changes in PAGCOR regulatory requirements.

14.2 Material amendments to this Policy will be communicated to registered aroonplay Players via the mobile number or email address associated with their account, with at least fourteen (14) days' notice prior to the effective date of the amendment, except where a shorter notice period is required by applicable law or regulatory authority.

14.3 The date of the most recent revision to this Policy is displayed at the top of this page. Continued use of the aroonplay Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

15.1 aroonplay has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with this Privacy Policy and the Data Privacy Act of 2012. The DPO serves as the primary point of contact for data subject rights requests and privacy-related enquiries.

15.2 To exercise your data subject rights, to submit a privacy complaint, or to raise any concern about how aroonplay processes your personal data, please contact our Data Protection Officer using the following details:

Data Protection Officer, aroonplay
Email: [email protected] (plain text — not a clickable link)
Subject Line: "Data Privacy Request — [Your Name]"
Response Time: Within 15 calendar days of receipt

15.3 aroonplay's general customer support team is also available 24 hours a day, 7 days a week via live chat on aroonplay.org for account-related privacy queries that do not require a formal data subject rights request.