aroonplay Privacy Policy

1. Introduction

aroonplay ("we," "us," "our," or "the Platform") operates an online casino and sports betting platform serving Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, Makati, and provincial areas. We are committed to protecting the privacy and personal data of every player who uses the aroonplay platform.

This Privacy Policy has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). It describes how aroonplay collects, uses, stores, shares, and protects your personal data, and explains the rights available to you as a data subject.

This Privacy Policy should be read together with the aroonplay Terms & Conditions, which govern your use of the platform. Capitalized terms not defined in this policy have the meanings given to them in the Terms & Conditions.

2. Personal Data We Collect

aroonplay collects personal data from you in the following categories:

2.1 Registration & Identity Data

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification — aroonplay is strictly 21+)
• Philippine mobile number and email address
• Username and encrypted password
• Residential address in the Philippines

2.2 Identity Verification (KYC) Data

• Copies of government-issued Philippine ID (passport, driver's license, PhilSys National ID, SSS/UMID, PRC ID, voter's ID)
• Proof of address documents (utility bills, bank statements)
• Selfie or liveness check images for identity confirmation
• Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account)

2.3 Financial & Transaction Data

• Deposit and withdrawal transaction records
• Payment method details (GCash number, PayMaya number, bank account details — stored in tokenized form)
• Transaction amounts, timestamps, and reference numbers
• Bonus and promotional activity records

2.4 Gaming & Betting Activity Data

• Game session logs, bet amounts, win/loss records
• Sports betting selections and outcomes
• Responsible gaming tool usage (deposit limits, session timers, self-exclusion requests)
• Game preferences and lobby interaction data

2.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Session duration and login timestamps
• Cookies and similar tracking technologies (see Section 6)

2.6 Communications Data

• Live chat transcripts with aroonplay support agents
• Email correspondence with aroonplay
• Feedback, complaints, and dispute records

3. How aroonplay Uses Your Personal Data

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

• Account Management: To create, maintain, and manage your aroonplay player account, including processing your registration, verifying your identity, and enabling login access.
• Age Verification: To confirm that you are at least 21 years of age, as required by Philippine law governing online gambling. aroonplay takes underage gambling prevention seriously.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported Philippine payment methods.
• Regulatory Compliance: To comply with anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, and any other applicable Philippine regulatory requirements.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, account takeovers, bonus abuse, and other security threats to the aroonplay platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide assistance through aroonplay's 24/7 live chat and email support channels.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools including deposit limits, session timers, cooling-off periods, and self-exclusion.
• Platform Improvement: To analyze usage patterns, improve game offerings, optimize the aroonplay user interface, and develop new features for Filipino players.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided consent or where we have a legitimate interest, and always with an easy opt-out option.
• Legal Obligations: To comply with court orders, regulatory investigations, or other legal processes requiring disclosure of personal data.

4. Legal Basis for Processing

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

• Contractual Necessity: Processing required to perform the contract between you and aroonplay (i.e., operating your player account, processing payments, providing games and services).
• Legal Obligation: Processing required to comply with Philippine law, including AML regulations, KYC requirements, and PAGCOR-related compliance obligations.
• Legitimate Interests: Processing for fraud prevention, platform security, and improving aroonplay services, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

aroonplay does not sell, rent, or trade your personal data to third-party marketers. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

5.1 Service Providers

aroonplay engages trusted third-party service providers to assist in operating the platform, including:

• Payment processors: GCash (GXI), PayMaya (Voyager Innovations), BPI, BDO, Metrobank — for processing deposits and withdrawals
• KYC/identity verification providers: For automated document verification and liveness checks
• Cloud hosting and infrastructure providers: For secure data storage and platform operation
• Customer support platform providers: For live chat and ticketing systems
• Fraud detection and AML screening providers

All service providers are contractually bound to process your data only as instructed by aroonplay and to maintain appropriate security standards.

5.2 Regulatory & Legal Authorities

aroonplay may disclose your personal data to Philippine government agencies, law enforcement, or regulatory bodies (including PAGCOR and the Anti-Money Laundering Council) where required by law, court order, or regulatory directive.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of aroonplay's business assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy. You will be notified of any such transfer.

6. Cookies & Tracking Technologies

aroonplay uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyze how Filipino players interact with our services. This section explains what cookies we use and how you can manage them.

6.1 What Are Cookies?

Cookies are small text files placed on your device when you visit the aroonplay website. They allow the platform to recognize your device, maintain your session, and remember certain preferences between visits. Cookies do not contain your password or payment details.

6.2 Types of Cookies aroonplay Uses

• Strictly Necessary Cookies: Required for the aroonplay platform to function. These include session authentication cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, preferred game categories, and responsible gaming tool configurations. Disabling these may affect your aroonplay experience.
• Analytics Cookies: Help aroonplay understand how players navigate the platform — which games are most popular, where players encounter issues, and how to improve the overall experience. Data collected is aggregated and anonymized.
• Marketing Cookies: Used to deliver relevant aroonplay promotional content. These are only placed with your explicit consent and can be withdrawn at any time via your cookie preferences.

6.3 Managing Cookies

You can manage your cookie preferences through the aroonplay cookie consent banner displayed on your first visit. You may also configure your browser to block or delete cookies; however, disabling strictly necessary cookies will prevent you from logging into your aroonplay account. Note that clearing cookies will log you out of your current aroonplay session.

7. Data Retention

aroonplay retains your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your aroonplay account and for a period of five (5) years following account closure, in compliance with Philippine AML record-keeping requirements.
• KYC & Identity Documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later, as required by the Anti-Money Laundering Act of 2001 (RA 9160) and its amendments.
• Transaction Records: Retained for five (5) years from the date of each transaction.
• Customer Support Records: Retained for three (3) years from the date of the last interaction.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of compliance.
• Technical Logs: Retained for up to twelve (12) months for security and fraud investigation purposes.

Upon expiry of the applicable retention period, aroonplay will securely delete or anonymize your personal data in accordance with our internal data disposal procedures.

8. Data Security

aroonplay implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and aroonplay servers is encrypted using industry-standard SSL/TLS protocols.
• Encrypted Data Storage: Sensitive personal data, including KYC documents and payment details, is stored in encrypted form on secured servers.
• Access Controls: Access to personal data is restricted to aroonplay staff and service providers who require it to perform their functions, on a strict need-to-know basis. All access is logged and audited.
• Two-Factor Authentication (2FA): aroonplay offers 2FA for player accounts to provide an additional layer of login security.
• Regular Security Audits: aroonplay conducts periodic security assessments and penetration testing to identify and address vulnerabilities in the platform.
• Staff Training: All aroonplay staff who handle personal data receive regular data privacy and security training.

9. Your Data Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by aroonplay:

• Right to Be Informed: You have the right to be informed about how aroonplay collects and processes your personal data — which is the purpose of this Privacy Policy.
• Right of Access: You may request a copy of the personal data aroonplay holds about you, along with information about how it is being used.
• Right to Rectification: If any personal data aroonplay holds about you is inaccurate or incomplete, you have the right to request correction. You can update basic account details directly in your aroonplay account settings.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to aroonplay's legal retention obligations under Philippine AML and regulatory law.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time via the unsubscribe link in any aroonplay email or by contacting support.
• Right to Data Portability: You may request that aroonplay provide your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: If you believe aroonplay has violated your data privacy rights, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC).

To exercise any of the above rights, please contact aroonplay's Data Protection Officer (DPO) using the contact details in Section 13. aroonplay will respond to all data rights requests within thirty (30) days of receipt, in accordance with NPC guidelines.

10. Children's Privacy

The aroonplay platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law governing online gambling and casino-style gaming. aroonplay does not knowingly collect personal data from individuals under the age of 21.

If aroonplay discovers or is notified that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, delete the personal data in question, and — where applicable — return any deposits made, in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that your child has registered an aroonplay account or provided personal data to aroonplay, please contact us immediately at [email protected] so we can take prompt action.

11. International Data Transfers

aroonplay's primary operations and data storage are based in the Philippines. However, some of our third-party service providers — including cloud infrastructure providers, KYC verification platforms, and fraud detection services — may process your personal data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, aroonplay ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Philippine Data Privacy Act. These safeguards may include:

• Contractual data processing agreements incorporating NPC-approved standard contractual clauses
• Transfers to jurisdictions recognized by the NPC as providing adequate data protection
• Binding corporate rules where applicable

By using the aroonplay platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described above.

12. Updates to This Privacy Policy

aroonplay may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When material changes are made, aroonplay will notify registered players via email or an on-platform notification at least seven (7) days before the changes take effect.

The effective date at the top of this page indicates when the current version of the Privacy Policy was last updated. The most current version of this policy is always available at aroonplay.one/privacy-policy. We encourage you to review this page periodically to stay informed about how aroonplay protects your personal data.

Your continued use of the aroonplay platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the updated policy, you may request account closure as described in the aroonplay Terms & Conditions.

13. Contact & Data Protection Officer

aroonplay has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact the aroonplay DPO:

• Email: [email protected]
• Live Chat: Available 24/7 via the aroonplay platform — mention "Data Privacy Request" to be directed to the DPO team
• Response Time: Within 30 days for formal data rights requests; within 2 business days for general privacy inquiries

If you are not satisfied with aroonplay's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC). The NPC is the government body responsible for administering and enforcing the Data Privacy Act of 2012.