Privacy Policy — ajjl Casino Philippines

1. Overview and Scope of This Policy

This Privacy Policy ("Policy") describes how ajjl ("we," "us," "our," or "the Company") — the operator of the online gaming platform accessible at https://ajjl.cam — collects, processes, stores, discloses, and protects personal information about individuals ("Data Subjects," "you," or "users") who interact with the ajjl platform, its mobile-optimised interface, and all associated services (collectively, the "Service").

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission of the Philippines (NPC). By using any portion of the ajjl Service, you acknowledge and consent to the data practices described in this Policy.

This Policy applies to all registered and unregistered users of the ajjl platform located in the Philippines — including players from Metro Manila, Cebu, Davao, Quezon City, Makati, and all other provinces and cities across Luzon, Visayas, and Mindanao — as well as to any individual who contacts ajjl through any official communication channel.

This Policy should be read in conjunction with ajjl's Terms and Conditions, which together constitute the full legal framework governing your relationship with the ajjl platform.

2. Personal Data We Collect

ajjl collects personal information through several channels, including account registration, ongoing platform use, customer support interactions, and automated technical systems. The categories of personal data we collect are described below.

2.1 Information You Provide Directly

• Identity Data: Full legal name, date of birth, nationality, and gender;
• Contact Data: Email address, mobile number, and residential address (barangay, city/municipality, province);
• Account Credentials: Username and encrypted password;
• KYC/Verification Documents: Government-issued identification (e.g., Philippine passport, UMID, LTO driver's licence, PhilSys National ID, PRC ID) and selfie verification images submitted during identity verification;
• Financial Data: GCash or PayMaya account numbers, BPI/BDO/Metrobank/UnionBank account details, and transaction records;
• Communications Data: The content of support tickets, live chat messages, and other correspondence with the ajjl team.

2.2 Information Collected Automatically

• Device and Technical Data: IP address, device type, operating system, browser type and version, and screen resolution;
• Usage Data: Pages visited, games played, session duration, bet amounts, wagering patterns, and click paths within the platform;
• Location Data: General geographic location derived from your IP address (used for compliance and fraud prevention purposes only — we do not collect precise GPS coordinates);
• Cookie Data: Session identifiers, preference tokens, and analytics tracking data as described in Section 5 of this Policy.

3. How We Use Your Personal Data

ajjl processes your personal data only for lawful, specified, and legitimate purposes. We do not use your data in ways that are incompatible with the purposes for which it was collected. Specific uses of your data include:

• Account Management: Creating and maintaining your ajjl player account, verifying your identity, and administering your account preferences;
• Service Delivery: Enabling you to access and enjoy all gaming services available on the ajjl platform, including slots, bingo, live casino games, Deuces Wild, and sports betting markets;
• Payment Processing: Facilitating deposits via GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank, and processing withdrawal requests in Philippine Peso (PHP);
• Regulatory Compliance: Fulfilling obligations under PAGCOR's regulations, the Anti-Money Laundering Act (AMLA), the Terrorism Financing Prevention and Suppression Act, and other applicable Philippine laws;
• KYC and Fraud Prevention: Verifying your identity, detecting suspicious activity, and preventing account misuse, multi-accounting, and financial crimes;
• Customer Support: Responding to your enquiries, resolving disputes, and processing responsible gaming requests such as self-exclusion;
• Platform Improvement: Analysing aggregated, anonymised usage data to improve the ajjl user experience, fix technical issues, and optimise game performance;
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates by email or SMS, where you have provided your consent to receive such communications.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, ajjl relies on the following lawful bases for processing your personal data:

1. Consent: For marketing communications and non-essential cookie placement, we rely on your freely given, informed consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing;
2. Contractual Necessity: Processing your identity, contact, and financial data is necessary for the performance of the contract between you and ajjl — specifically, the Terms and Conditions you accept at registration;
3. Legal Obligation: We process KYC documents, transaction records, and certain usage data to comply with our obligations under PAGCOR regulations, AMLA, and related Philippine statutes;
4. Legitimate Interests: We process device and usage data to detect and prevent fraud, maintain platform security, and improve the quality of our Service — provided this processing does not override your fundamental privacy rights.

5. Cookies and Tracking Technologies

ajjl uses cookies — small text files stored on your device — and similar tracking technologies to operate and improve the platform. Cookies are categorised as follows:

5.1 Strictly Necessary Cookies

These cookies are essential for the platform to function correctly. They manage your login session, maintain your game state, and protect against cross-site request forgery (CSRF). These cookies cannot be disabled without severely disrupting your experience on ajjl.

5.2 Analytics Cookies

We use aggregated analytics tools to understand how users navigate the ajjl platform — which games are most popular, where users encounter friction, and how long sessions typically last. This data is anonymised and used solely to improve platform performance. You may opt out of analytics cookies at any time through your browser settings.

5.3 Preference Cookies

These cookies remember your platform preferences, such as language settings and display choices, so you do not have to re-enter them on subsequent visits.

You can manage cookie preferences through your browser settings. Note that disabling certain categories of cookies may affect the functionality of some features on the ajjl platform.

6. Sharing Your Personal Information

ajjl does not sell, trade, or rent your personal information to third parties. We may share your data with the following categories of recipients only to the extent necessary and only under appropriate safeguards:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank receive only the minimum financial data required to process your transactions. These providers are bound by their own privacy obligations under Philippine law;
• Identity Verification Partners: KYC documents may be shared with accredited third-party identity verification services to fulfil our PAGCOR and AMLA compliance obligations;
• Technology and Platform Partners: Game content providers, server infrastructure operators, and security monitoring services may process technical and usage data under strict data processing agreements with ajjl;
• Regulatory and Law Enforcement Authorities: We will disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities when required to do so by law, court order, or valid regulatory directive;
• Professional Advisers: Legal counsel, auditors, and compliance consultants who are bound by professional confidentiality obligations.

7. Data Retention

ajjl retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with our legal and regulatory obligations, and to resolve any disputes or enforce our agreements.

As a general guide, our data retention periods are as follows:

• Account and Identity Data: Retained for the duration of your account relationship with ajjl, plus a minimum of five (5) years after account closure, in line with PAGCOR's record-keeping requirements and AMLA obligations;
• Transaction and Financial Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act and its implementing rules;
• KYC Documents: Retained for the period required by applicable PAGCOR and AMLC regulations, and deleted securely thereafter;
• Communications Data: Customer support interactions are retained for two (2) years from the date of the last communication in a given support thread;
• Analytics and Usage Data: Aggregated and anonymised usage data may be retained indefinitely for platform improvement purposes.

When personal data reaches the end of its applicable retention period, ajjl will securely delete or anonymise it in a manner that prevents reconstruction of the original personal information.

8. Your Privacy Rights Under Philippine Law

As a data subject under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by ajjl. These rights may be exercised at any time by contacting our Data Protection Officer.

To exercise any of the above rights, please submit a written request to our Data Protection Officer at [email protected]. We will acknowledge all valid data subject requests within seventy-two (72) hours and fulfil them within thirty (30) calendar days of receipt, or inform you of any extensions required.

9. Data Security Measures

ajjl implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Transport Layer Security (TLS): All data transmitted between your browser and the ajjl platform is encrypted using TLS 1.2 or higher, preventing interception during transit;
• Data Encryption at Rest: Sensitive data fields — including KYC document images and financial account details — are encrypted at rest using AES-256 standards;
• Access Controls: Access to personal data within ajjl's systems is restricted to authorised personnel on a strict need-to-know basis, enforced through role-based access control (RBAC) and multi-factor authentication (MFA);
• Intrusion Detection and Monitoring: Our infrastructure is monitored around the clock for anomalous activity, with automated alerting for potential security incidents;
• Penetration Testing: ajjl engages independent security firms to conduct regular penetration testing and vulnerability assessments of the platform;
• Incident Response: In the event of a personal data breach that is likely to adversely affect your rights, ajjl will notify the National Privacy Commission and affected data subjects within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular No. 16-03.

While ajjl takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You also play a role in keeping your account secure — use a strong unique password, enable any available two-factor authentication, and never share your login credentials with anyone.

10. Children, Minors, and the 21+ Requirement

The ajjl platform is strictly intended for adults aged twenty-one (21) years and above, in accordance with Philippine gaming laws. We do not knowingly collect, solicit, or retain personal data from individuals under the age of 21.

If ajjl discovers that personal data has been collected from a minor during the registration process or at any later point, we will immediately suspend the relevant account, delete all associated personal data, and report the incident as required by applicable regulations. Any gaming activity conducted by an underage user will be voided and all associated winnings will be forfeited.

11. Third-Party Links and Services

The ajjl platform may display references to third-party services such as payment gateways (GCash, PayMaya, BPI, BDO) and responsible gaming resources. These third parties operate their own websites and privacy policies, which are entirely separate from and independent of this Policy.

ajjl is not responsible for the privacy practices, data handling, or content of any third-party service. Once you leave the ajjl platform and interact with a third-party website or application, this Privacy Policy no longer applies. We encourage you to review the privacy policy of any third-party service you access in connection with your use of ajjl.

12. Amendments to This Privacy Policy

ajjl reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. Where changes are material — such as the introduction of a new category of data processing or a change in how we share data with third parties — we will provide advance notice to registered users by email or through a prominent notice on the platform, at least seven (7) days before the changes take effect.

The "Effective Date" at the top of this Policy will be updated whenever amendments are made. Your continued use of the ajjl platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with the amended Policy, you may request account closure at any time by contacting our support team.

13. Contact Information and Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or ajjl's data processing practices, please contact our Data Protection Officer (DPO) through the following channel:

Email: [email protected]

Our DPO is available to assist Filipino players across the Philippines — from Luzon to Mindanao — and will respond to all written privacy enquiries in English within seventy-two (72) hours on business days.

If you are not satisfied with ajjl's response to your privacy concern, or if you believe that your rights under the Data Privacy Act of 2012 have been violated, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines through its official channels. The NPC is the competent supervisory authority for data protection matters in the Philippines.