Privacy Policy

1. Scope and Application of This Policy

This Privacy Policy applies to all personal data processed by aajljl in connection with the operation of aajljl.cam, any associated mobile applications, and all related services, promotions, and customer support interactions. It applies to registered Members, prospective Members who have initiated but not completed registration, and any visitor who accesses the platform.

By registering an account, depositing funds, playing any game, or otherwise using the aajljl platform, you acknowledge that you have read and understood this Privacy Policy. Where consent is the legal basis for processing, your continued use of the platform constitutes that consent. This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy.

2. Personal Data We Collect

aajljl collects only the personal data that is necessary and proportionate to the specific purposes described in Section 4. The categories of personal data we may collect include, but are not limited to, the following:

We do not knowingly collect sensitive personal information — such as racial or ethnic origin, religious beliefs, or health data — unless directly relevant to a responsible gaming assessment or legally required by PAGCOR for licensing compliance.

3. How We Collect Your Data

aajljl collects personal data through the following channels:

• Direct Submission: Information you actively provide during registration, identity verification (KYC), deposit or withdrawal requests, customer support inquiries, bonus claim forms, and account settings updates.
• Automated Technologies: Technical and usage data collected automatically when you access the platform, including data gathered via cookies, pixel tags, server logs, and similar tracking technologies (see Section 5).
• Payment Processors: Transaction references and confirmation data provided by GCash, Maya, BPI, BDO, UnionBank, Metrobank, and cryptocurrency processing partners when you make deposits or request withdrawals.
• Identity Verification Partners: Document authenticity checks and biometric liveness verification performed by third-party KYC service providers in compliance with PAGCOR Anti-Money Laundering (AML) requirements.
• Fraud Prevention & Security Services: Risk scores, device fingerprints, and behavioural signals shared by fraud-detection partners to protect the integrity of the aajljl platform.

4. Purposes and Legal Bases for Processing

aajljl processes personal data only where a lawful basis under the Data Privacy Act of 2012 exists. The primary purposes and their corresponding legal bases are as follows:

• Account Registration and Service Delivery — Processing is necessary for the performance of a contract between you and aajljl. We cannot create your account or provide gaming services without your identity and contact data.
• Identity Verification and KYC Compliance — Processing is required by PAGCOR licensing conditions and the Anti-Money Laundering Act (Republic Act No. 9160, as amended). Age verification to confirm players are at least 21 years old is a legal obligation and also protects minors from access.
• Payment Processing and Financial Record-Keeping — Necessary for the performance of our contract with you and required by Philippine tax and financial reporting regulations.
• Responsible Gaming and Player Protection — Based on our legitimate interest in preventing problem gambling and on compliance with PAGCOR's responsible gaming frameworks. This includes processing responsible gaming data to administer self-exclusion and deposit limits.
• Fraud Prevention and Platform Security — Based on our legitimate interest in protecting the integrity of the aajljl platform and all Members against fraud, collusion, and money laundering.
• Customer Support — Necessary for the performance of our contract and our legitimate interest in resolving disputes and improving our services.
• Marketing Communications — Based on your explicit consent, which you may withdraw at any time by updating your communication preferences in account settings or by contacting support.
• Platform Analytics and Improvement — Based on our legitimate interest in understanding how Members use the platform so we can optimise game offerings, interface design, and technical performance.

5. Cookies and Similar Technologies

5.1 What We Use

The aajljl platform uses cookies, web beacons, local storage, and similar technologies to ensure the platform functions correctly, to remember your preferences, and to analyse how you interact with our services.

5.2 Types of Cookies

• Strictly Necessary Cookies: Required for the platform to operate — session authentication, security tokens, and load-balancing. These cannot be disabled without breaking core functionality.
• Functional Cookies: Store your language preference, display settings, and responsible gaming configurations so you don't need to re-enter them each session.
• Analytics Cookies: Help us understand aggregate usage patterns — which games are most popular, where navigation drop-offs occur, and platform performance metrics. Data is anonymised before analysis where possible.
• Fraud-Prevention Cookies: Device fingerprinting tokens used by our security systems to detect unauthorised access, account takeover attempts, and collusive behaviour.

5.3 Managing Cookies

You may configure your browser to reject non-essential cookies; however, doing so may impair certain aajljl platform features. You can manage cookie preferences through the Cookie Settings panel accessible at the bottom of any page. Note that strictly necessary cookies cannot be disabled.

6. Data Sharing and Third-Party Disclosure

aajljl does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your data with the following categories of recipients only to the extent necessary:

• PAGCOR and Regulatory Authorities: We are legally obligated to disclose member data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and Philippine law enforcement agencies upon valid legal request or as required by our operating licence.
• Payment Service Providers: GCash, Maya, BPI, BDO, UnionBank, Metrobank, and cryptocurrency processors receive only the transaction data necessary to execute and verify payments.
• KYC and Identity Verification Partners: Third-party KYC providers process government-issued ID images and biometric liveness checks under strict data-processing agreements and solely for identity verification purposes.
• Game Content Providers: Providers such as Evolution Gaming, Pragmatic Play, and Microgaming receive anonymised session data necessary to deliver their games; they do not receive personally identifiable information beyond what is technically required.
• Cloud Infrastructure and Security Providers: Hosting, content delivery, and cybersecurity partners who process data on our behalf under binding data-processing agreements compliant with Philippine privacy law.

7. Cross-Border Data Transfers

Some of the third-party service providers engaged by aajljl — including cloud infrastructure partners and certain game technology providers — may process personal data outside the Republic of the Philippines. Where such transfers occur, aajljl ensures that:

• The receiving entity is located in a country recognised by the National Privacy Commission as providing an adequate level of data protection, or
• Appropriate safeguards are in place via binding contractual clauses, data transfer agreements, or equivalent mechanisms that provide protections substantially equivalent to those afforded under Philippine law, or
• The transfer is necessary for the performance of our contract with you (e.g., processing a payment through an international payment gateway).

8. Data Retention Periods

aajljl retains personal data only for as long as necessary to fulfil the purpose for which it was collected, subject to any longer retention obligations imposed by Philippine law. The following retention schedules apply as a general guide:

At the end of the applicable retention period, personal data is securely deleted or irreversibly anonymised, whichever is technically appropriate.

9. Security Measures

aajljl implements a layered approach to data security designed to protect your personal information against unauthorised access, accidental loss, destruction, or disclosure. Key technical and organisational measures include:

• 256-bit SSL/TLS Encryption applied to all data in transit between your device and our servers, equivalent to the standard used by Philippine banks and government e-services.
• Encryption at Rest for all sensitive data stored in our databases, including identity documents, financial records, and password hashes (using bcrypt with per-user salts — plain-text passwords are never stored).
• Multi-Factor Authentication (MFA) available to all Members and enforced for all staff with access to Member data.
• Access Controls and Role-Based Permissions ensuring that only authorised personnel with a documented business need can access identifiable Member data, and then only to the minimum extent necessary.
• Regular Penetration Testing and Vulnerability Assessments conducted by independent cybersecurity firms to identify and remediate potential weaknesses before they can be exploited.
• Intrusion Detection and DDoS Protection systems that continuously monitor for anomalous network activity and automatically block suspicious requests.
• Data Breach Response Plan maintained and tested regularly, including procedures for notifying the National Privacy Commission and affected Members within 72 hours of a confirmed breach, in accordance with NPC Circular No. 16-03.

While no security system is entirely infallible, aajljl continuously reviews and upgrades its security posture to keep pace with evolving threats and to maintain the trust of our Filipino player community.

10. Your Data Subject Rights

As a data subject under Republic Act No. 10173, you have the following rights in relation to your personal data held by aajljl. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13:

• Right to Be Informed: The right to know whether we hold data about you and to receive clear, accessible information about how it is processed — which this Privacy Policy is designed to provide.
• Right of Access: The right to obtain a copy of the personal data we hold about you, along with information about the processing purposes and any third parties with whom it has been shared.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected or completed without undue delay.
• Right to Erasure ("Right to be Forgotten"): The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations under PAGCOR and AMLA requirements.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller where technically feasible.
• Right to Object: The right to object to processing based on legitimate interests or for direct marketing purposes. Where you object to marketing, we will cease processing for that purpose immediately.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

We will respond to all verified data subject requests within thirty (30) calendar days of receipt. Identity verification may be required before we process your request to ensure we do not disclose personal data to unauthorised parties.

11. Children's Privacy and Age Restrictions

The aajljl platform is strictly prohibited to persons under the age of twenty-one (21) years, in accordance with Philippine gambling regulations. We do not knowingly collect personal data from minors. All account registrations require submission of a government-issued Philippine ID confirming the applicant is at least 21 years old before any gaming activity or financial transaction is permitted.

If aajljl becomes aware that personal data has been collected from an individual under 21 years of age, we will immediately suspend the account, delete all associated personal data, and — where applicable — refund any deposits to the original payment source. Parents or guardians who believe a minor has registered an account are encouraged to contact our support team without delay at [email protected].

12. Changes to This Privacy Policy

aajljl reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. The updated Policy will be published on this page with a revised effective date. Where changes are material, we will notify registered Members by email or in-platform notification at least fourteen (14) calendar days before the changes take effect, except where immediate revision is required by law.

Your continued use of the aajljl platform after the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this page periodically to stay informed about how we protect your data.

13. Contact and Data Protection Officer

aajljl has designated 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 wish to exercise any of your data subject rights, please contact our DPO using the following details:

• Email: [email protected] (Subject line: "Data Privacy Request")
• Response Time: Within thirty (30) calendar days of receipt of a verified request.
• Availability: 24/7 via live chat for general privacy inquiries; formal data subject requests handled via email during business hours.

If you are not satisfied with our response to your data privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines at [email protected].