AAAVIP Privacy Policy

AAAVIP operates the online gaming platform accessible at aaavip.app (the "Platform"). We are committed to protecting the privacy and personal data of every individual who interacts with our Platform, whether as a registered Player, a visitor, or a prospective user.

This Privacy Policy has been prepared in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). It sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by AAAVIP.

By accessing the AAAVIP Platform, completing the registration process, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should not use the AAAVIP Platform.

This Policy applies to all personal data collected through the Platform, our mobile application, customer support channels, and any other means by which you interact with AAAVIP.

AAAVIP collects the following categories of personal data from Players and Platform visitors:

2.1 Registration and Identity Data

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Gender
• Nationality and country of residence
• Email address
• Mobile phone number
• Username and encrypted password

2.2 Identity Verification (KYC) Data

• Government-issued identification documents (e.g., Philippine passport, driver's license, SSS ID, UMID, PhilSys National ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or facial image for identity matching purposes
• Source of funds documentation where required by anti-money laundering regulations

2.3 Financial and Transaction Data

• Deposit and withdrawal transaction records
• Payment method identifiers (e.g., GCash mobile number, PayMaya account reference, bank account name and last digits)
• Transaction amounts, dates, and reference numbers
• Bonus and promotional credit history

2.4 Gaming Activity Data

• Game session history, including games played, wagers placed, and outcomes
• Betting patterns and frequency of play
• Responsible gaming tool usage (e.g., deposit limits set, self-exclusion requests)

2.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps and duration
• Cookies and similar tracking technology data (see Section 7)

2.6 Communications Data

• Records of correspondence with AAAVIP customer support, including live chat transcripts and email exchanges
• Survey responses and feedback submitted through the Platform
• Marketing communication preferences

AAAVIP collects personal data through the following means:

• Direct submission: 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 Platform, including through cookies, web beacons, log files, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud detection signals from security partners; payment confirmation data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank.
• Regulatory sources: Information received from Philippine regulatory authorities or law enforcement agencies in connection with legal obligations or investigations.

AAAVIP does not collect personal data from social media platforms or third-party advertising networks without your explicit consent.

AAAVIP uses the personal data we collect for the following purposes:

AAAVIP will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

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

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to upon registration, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering laws, gaming regulations, and tax reporting requirements.
• Legitimate interests: Processing necessary for AAAVIP's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of marketing communications and the use of non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

AAAVIP does not sell your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification service providers engaged to assist with regulatory compliance.
• Fraud prevention and security partners: Service providers that assist AAAVIP in detecting and preventing fraudulent activity, money laundering, and unauthorized access.
• IT and infrastructure providers: Cloud hosting, data storage, and platform maintenance providers who process data on AAAVIP's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Philippine government agencies, including the National Privacy Commission, and law enforcement bodies, where disclosure is required by law, court order, or regulatory directive.
• Professional advisors: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third-party service providers who process personal data on AAAVIP's behalf are required to implement appropriate technical and organizational security measures and to process data only in accordance with AAAVIP's instructions and applicable Philippine data protection law.

AAAVIP uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain session security, and analyze Platform performance. The following types of cookies may be used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session authentication and security tokens. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming tool configurations.
• Analytics cookies: Used to collect aggregated, anonymized data about how Players use the Platform, helping us improve performance and user experience.
• Marketing cookies: Used, with your consent, to deliver relevant promotional content within the AAAVIP Platform. AAAVIP does not use third-party advertising networks.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For strictly necessary cookies, no opt-out is available as they are required for the Platform to operate.

AAAVIP retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

The following general retention periods apply:

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable financial regulations.
• Gaming activity data: Retained for a minimum of three (3) years from the date of the activity.
• Customer support communications: Retained for three (3) years from the date of the last interaction.
• Marketing preferences: Retained until you withdraw your consent or request deletion, whichever is earlier.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with AAAVIP's data disposal procedures. Where data is anonymized, it may be retained indefinitely for statistical and analytical purposes.

AAAVIP implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and AAAVIP servers;
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial records;
• Multi-factor authentication for access to internal systems containing personal data;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing of the Platform and supporting infrastructure;
• Incident response procedures for detecting, reporting, and responding to personal data breaches in accordance with NPC notification requirements.

While AAAVIP takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying AAAVIP immediately if you suspect any unauthorized access to your account.

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

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

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data AAAVIP holds about you, along with information about how it is being used.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to AAAVIP's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details provided in Section 14 of this Policy. AAAVIP will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

AAAVIP employs age verification measures during the registration process to prevent underage individuals from accessing the Platform. If AAAVIP becomes aware that personal data has been collected from an individual under the age of 21 without appropriate parental or guardian consent, 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 under the age of 21 has registered on the AAAVIP Platform or provided us with personal data, please contact our Data Protection Officer immediately using the contact details in Section 14. We will investigate and take appropriate action promptly.

For guidance on parental controls and tools to prevent underage access to online gaming platforms, please visit our Responsible Gaming page.

AAAVIP primarily stores and processes personal data within the Philippines. However, certain service providers engaged by AAAVIP — including cloud infrastructure providers and KYC verification partners — may be located in other countries. Where personal data is transferred outside the Philippines, AAAVIP ensures that:

• The recipient country provides an adequate level of data protection as recognized by the National Privacy Commission; or
• Appropriate safeguards are in place, such as contractual data protection clauses that impose obligations on the recipient equivalent to those required under the Data Privacy Act; or
• The transfer is necessary for the performance of a contract between you and AAAVIP, or for the implementation of pre-contractual measures taken at your request.

You may request further information about the safeguards in place for international data transfers by contacting our Data Protection Officer.

AAAVIP 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. When material changes are made, we will notify registered Players by email or through a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this page indicates when the Policy was most recently revised. We encourage you to review this Privacy Policy periodically to stay informed about how AAAVIP protects your personal data.

Your continued use of the AAAVIP Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with the changes, you should cease using the Platform and may request closure of your account.

AAAVIP has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact us through the following channels:

If you are not satisfied with AAAVIP's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory body responsible for administering and implementing the Data Privacy Act of 2012.

For more information about your rights under the Data Privacy Act and how to file a complaint with the NPC, please refer to the NPC's official resources. AAAVIP cooperates fully with the NPC in all matters relating to data privacy compliance.