Privacy Policy

1. Overview

This Privacy Policy ("Policy") describes how aoewin ("we," "us," "our," or the "Platform") collects, uses, stores, discloses, and protects the personal information of users ("you," "your," or "Data Subject") who access or use the aoewin website and related services.

By registering an account on aoewin, accessing the Platform, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the aoewin Platform.

aoewin acts as the Personal Information Controller (PIC) as defined under the Philippine Data Privacy Act of 2012. We have appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws.

2. Personal Data We Collect

aoewin collects the following categories of personal data from users of the Platform:

We do not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by law (e.g., responsible gaming self-exclusion records).

3. How We Collect Your Data

aoewin collects personal data through the following means:

• Direct interactions: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in promotions, you directly provide us with personal data.
• Automated technologies: As you use the aoewin Platform, we automatically collect technical and usage data through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: We may receive data about you from payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, fraud prevention services, and analytics partners.
• KYC verification: During the Know Your Customer process, we collect copies of government-issued identification documents to verify your identity and age (21+) as required by applicable regulations.

4. Purpose of Processing

aoewin processes your personal data for the following purposes:

• Account management: To create, maintain, and manage your aoewin account, including authentication and security.
• Service delivery: To provide you with access to games, process deposits and withdrawals, and deliver the core features of the aoewin Platform.
• Identity and age verification: To verify that you are at least 21 years of age and to comply with KYC requirements under applicable Philippine regulations.
• Financial transactions: To process deposits, withdrawals, and bonus credits, and to maintain accurate financial records.
• 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 behavior, enforce self-exclusion requests, and provide responsible gaming tools to users who request them.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing and promotions: To send you promotional offers, newsletters, and updates about aoewin, subject to your communication preferences and applicable law.
• Legal compliance: To comply with applicable Philippine laws, regulations, and lawful requests from government authorities.
• Platform improvement: To analyze usage patterns, conduct research, and improve the features and performance of the aoewin Platform.

5. Legal Basis for Processing

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

• Consent: Where you have given explicit consent to the processing of your personal data for one or more specific purposes (e.g., marketing communications).
• Contractual necessity: Where processing is necessary for the performance of the contract between you and aoewin (i.e., the Terms & Conditions governing your use of the Platform).
• Legal obligation: Where processing is necessary for compliance with a legal obligation to which aoewin is subject, including anti-money laundering (AML) regulations and PAGCOR-related compliance requirements.
• Legitimate interests: Where processing is necessary for the legitimate interests of aoewin, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and freedoms.

6. Data Sharing & Disclosure

aoewin does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to process your financial transactions.
• Identity verification providers: Third-party KYC and age verification services used to confirm your identity and eligibility.
• Game software providers: Licensed game studios and software providers whose games are available on the aoewin Platform, to the extent necessary for game operation and fairness auditing.
• IT and security service providers: Cloud hosting, cybersecurity, and fraud detection service providers who assist in operating and securing the Platform.
• Legal and regulatory authorities: Government agencies, law enforcement, courts, and regulatory bodies (including PAGCOR) where disclosure is required by law or in response to a lawful request.
• Professional advisors: Lawyers, auditors, and accountants, subject to professional confidentiality obligations.

7. Data Retention

aoewin retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account data: Retained for the duration of your account and for five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC documents: Retained for five (5) years following account closure or the last transaction, whichever is later.
• Gaming history: Retained for three (3) years from the date of the gaming session.
• Support communications: Retained for two (2) years from the date of the last communication.
• Marketing data: Retained until you withdraw your consent or for two (2) years of inactivity, whichever comes first.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymized in accordance with our data disposal procedures.

8. Data Security

aoewin implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the aoewin Platform.
• Encryption of sensitive data at rest, including financial information and government ID details.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments.
• Two-factor authentication (2FA) available for all user accounts.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, aoewin will notify the National Privacy Commission (NPC) and affected users in accordance with the requirements of the Data Privacy Act and NPC Circular No. 16-03.

9. Your Data Subject Rights

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

• Right to be informed: The right to be informed about how your personal data is collected and processed, as described in this Policy.
• Right of access: The right to request a copy of the personal data we hold about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data, subject to our legal retention obligations.
• Right to object: The right to object to the processing of your personal data, including for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact details in Section 13. We will respond to your request within fifteen (15) business days. We may need to verify your identity before processing your request.

10. Cookies & Tracking Technologies

aoewin uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver relevant content. The types of cookies we use include:

• Strictly necessary cookies: Essential for the operation of the Platform, including session management and security. These cannot be disabled.
• Performance cookies: Used to collect anonymous information about how visitors use the Platform, helping us improve performance and user experience.
• Functional cookies: Used to remember your preferences, such as language settings and login status.
• Analytics cookies: Used to understand user behavior and measure the effectiveness of our Platform features.

You can control non-essential cookies through your browser settings. However, disabling certain cookies may affect the functionality of the aoewin Platform. By continuing to use the Platform after being informed of our cookie use, you consent to our use of cookies as described in this Policy.

11. Minors & Age Restriction

The aoewin Platform is strictly intended for users who are at least 21 years of age. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that we have inadvertently collected personal data from a minor, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has provided personal data to aoewin, please contact our Data Protection Officer immediately using the contact details in Section 13.

12. Changes to This Policy

aoewin reserves the right to update or modify this Privacy Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered users via email or in-platform notification.

Your continued use of the aoewin Platform after any changes to this Policy constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

13. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact the aoewin Data Protection Officer:

Data Protection Officer, aoewin

Email: [email protected]

General Support: [email protected]

We aim to respond to all data subject requests within fifteen (15) business days. For urgent matters, please use the live chat feature available on the aoewin Platform.