Privacy Policy — aoewin2 Casino

1 Introduction and Identity of the Data Controller

aoewin2 Casino is the data controller responsible for the personal information collected through the aoewin2 platform. As a data controller, aoewin2 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC) of the Philippines.

aoewin2 operates under the regulatory oversight of PAGCOR — the Philippine Amusement and Gaming Corporation — and is subject to PAGCOR's data governance requirements in addition to the general requirements of Philippine data privacy law.

This Policy applies to all personal data collected through the aoewin2 website, mobile applications, customer support channels, and any other touchpoints through which you interact with aoewin2. It does not apply to third-party websites or services that may be linked from the aoewin2 platform.

2 Personal Data We Collect

aoewin2 collects the following categories of personal data from registered players and platform visitors:

2.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (for age verification — you must be 21 or older);
• Nationality and country of residence;
• Email address and mobile phone number;
• Residential address (barangay, city/municipality, province, ZIP code).

2.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., PhilSys National ID, passport, driver's licence, SSS/GSIS ID, PRC ID, voter's ID);
• Proof of address documents (e.g., utility bill, bank statement);
• Selfie or live photo for identity verification purposes.

2.3 Financial Data

• GCash or PayMaya account details (mobile number associated with the e-wallet);
• Philippine bank account details for bank transfer transactions (account name, account number, bank name);
• Debit card details (card number masked, expiry date, cardholder name);
• Transaction history including deposits, withdrawals, and wager records.

2.4 Gaming and Behavioural Data

• Game play history, bet amounts, win/loss records;
• Session duration and frequency of play;
• Responsible gaming tool usage (deposit limits, self-exclusion requests);
• Bonus and promotional offer redemption history.

2.5 Technical and Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Cookies and similar tracking technologies (see Section 10);
• Login timestamps and session activity logs.

2.6 Communications Data

• Records of your communications with aoewin2 customer support;
• Feedback, survey responses, and complaint records;
• Marketing communication preferences.

3 How We Collect Your Personal Data

aoewin2 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 data collected automatically when you access the aoewin2 platform, including through cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-money laundering (AML) screening services; payment verification data from payment processors such as GCash and PayMaya;
• Regulatory sources: Information received from PAGCOR or other regulatory authorities in connection with compliance obligations.

4 How We Use Your Personal Data

aoewin2 uses your personal data for the following purposes:

5 Legal Basis for Processing

aoewin2 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you as a registered player, including account management, payment processing, and service delivery;
• Legal obligation: Processing required to comply with PAGCOR regulations, anti-money laundering laws, tax obligations, and other applicable Philippine legal requirements;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where our legitimate interests are not overridden by your rights;
• Consent: Processing for direct marketing communications, where you have provided explicit consent. You may withdraw your consent at any time by updating your communication preferences in your account settings or by contacting our Data Protection Officer.

6 Disclosure and Sharing of Personal Data

aoewin2 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 Policy:

6.1 Service Providers

Third-party service providers who assist aoewin2 in operating the platform, including KYC verification providers, payment processors (GCash, PayMaya, and Philippine banking partners), IT infrastructure providers, and customer support platforms. All service providers are contractually bound to process your data only on aoewin2's instructions and in accordance with applicable data privacy laws.

6.2 Regulatory Authorities

PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities where disclosure is required by law or regulatory mandate.

6.3 Game Providers

Licensed game content providers whose games are available on the aoewin2 platform may receive limited technical data (such as player session identifiers) necessary to deliver game functionality. Game providers do not receive your full identity or financial data.

6.4 Legal and Compliance

Legal advisers, auditors, and law enforcement agencies where disclosure is required to protect aoewin2's legal rights, comply with a court order, or prevent fraud or criminal activity.

7 Data Retention

aoewin2 retains your personal data for the following periods:

Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised. Where data must be retained for longer periods due to ongoing legal proceedings or regulatory investigations, it will be retained until the matter is resolved.

8 Data Security

aoewin2 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• Encryption: All data in transit is protected by 256-bit SSL/TLS encryption. Sensitive data at rest (including payment details and KYC documents) is encrypted using AES-256;
• Access controls: Access to personal data is restricted to authorised aoewin2 personnel on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication;
• Infrastructure security: The aoewin2 platform is hosted on secure, PAGCOR-compliant infrastructure with regular penetration testing and vulnerability assessments;
• Incident response: aoewin2 maintains a documented data breach response plan. In the event of a breach posing a real risk to your rights, we will notify you and the NPC within 72 hours of becoming aware of the breach;
• Staff training: All aoewin2 personnel with access to personal data receive regular data privacy and security training.

9 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by aoewin2. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. aoewin2 will respond to all data subject requests within thirty (30) days of receipt.

9.1 Right to Access

You have the right to request a copy of the personal data aoewin2 holds about you, together with information about how it is being processed. aoewin2 will provide this information free of charge for the first request in any 12-month period.

9.2 Right to Rectification

You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You may update certain account details directly through your aoewin2 account settings. For changes to identity or KYC data, please contact our Data Protection Officer.

9.3 Right to Erasure

You have the right to request deletion of your personal data where: (a) the data is no longer necessary for the purposes for which it was collected; (b) you withdraw consent and there is no other legal basis for processing; or (c) the data has been unlawfully processed. Note that aoewin2 may be required to retain certain data for regulatory compliance purposes even following an erasure request.

9.4 Right to Object

You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, in which case aoewin2 will cease processing unless it can demonstrate compelling legitimate grounds that override your interests.

9.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.

9.6 Right to Lodge a Complaint

If you believe aoewin2 has processed your personal data in violation of the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

10 Cookies and Tracking Technologies

aoewin2 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit the aoewin2 website.

10.1 Types of Cookies We Use

• Strictly necessary cookies: Required for the platform to function, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations.
• Analytics cookies: Collect anonymised data about how players use the platform to help us improve performance and user experience.
• Marketing cookies: Used to deliver relevant promotional content based on your interests, where you have consented to receive marketing communications.

10.2 Managing Cookies

You can control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the aoewin2 platform. Strictly necessary cookies cannot be disabled as they are essential for platform operation.

11 Protection of Minors

aoewin2 employs age verification measures at registration and during KYC review to prevent underage access to the platform. If aoewin2 becomes aware that personal data has been collected from a person under the age of 21, the relevant account will be immediately suspended, all data will be deleted in accordance with applicable law, and any deposited funds will be returned to the originating payment account.

If you are a parent or guardian and believe that a minor has registered on the aoewin2 platform, please contact our Data Protection Officer immediately using the details in Section 14.

12 International Data Transfers

aoewin2 primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines (for example, international game content providers or cloud infrastructure providers), aoewin2 will ensure that such transfers are made in accordance with the Data Privacy Act of 2012 and NPC regulations, including through the use of appropriate contractual safeguards such as standard contractual clauses approved by the NPC.

aoewin2 will not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

13 Changes to This Privacy Policy

aoewin2 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. Where changes are material, aoewin2 will notify registered players via email or an in-platform notification prior to the changes taking effect.

The effective date at the top of this Policy indicates when the current version was last updated. Your continued use of the aoewin2 platform following the effective date of any amended Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically.

14 Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by aoewin2, please contact our designated Data Protection Officer (DPO):

For complaints that cannot be resolved directly with aoewin2, you may contact the National Privacy Commission of the Philippines at privacy.gov.ph (please visit the NPC website directly for current contact details).