aqjl Privacy Policy

01 Who We Are

This Privacy Policy is issued by aqjl ("aqjl," "we," "us," or "our"), the operator of the online gaming platform accessible at aqjl.org and any associated mobile applications or services (collectively, the "Platform"). aqjl operates within the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR).

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules, aqjl acts as the Personal Information Controller with respect to the personal data of registered players and visitors to the Platform. This means aqjl determines the purposes and means by which your personal data is processed.

02 Personal Data We Collect

aqjl collects personal data that is necessary, adequate, and relevant to the purposes described in this Policy. We collect data in three primary ways: information you provide directly, information generated automatically through your use of the Platform, and information received from third parties.

Information You Provide Directly:

• Full legal name as it appears on your government-issued Philippine ID
• Date of birth (to verify the 21+ age requirement)
• Residential address in the Philippines (city, province, postal code)
• Valid email address and mobile phone number
• Government-issued ID documents submitted during KYC verification (e.g., PhilSys ID, passport, UMID, driver's license, SSS/GSIS ID, PRC license)
• Financial information including payment method details, GCash or PayMaya account numbers associated with your profile, and bank account information for BDO, BPI, or Metrobank withdrawals
• Source of funds documentation where required for enhanced due diligence
• Communications you submit via live chat, email, or support tickets

Information Collected Automatically:

• IP address and approximate geolocation (country, region, city)
• Device type, operating system, and browser type and version
• Session timestamps, pages visited, and navigation paths within the Platform
• Game activity logs including games played, wager amounts, win/loss records, and session durations
• Deposit and withdrawal transaction records
• Cookie identifiers and similar tracking data (see Section 6)

Information from Third Parties:

• Identity verification results from accredited KYC service providers
• Transaction status and confirmation data from payment processors including GCash, PayMaya, BDO, BPI, and Metrobank
• Fraud risk signals from licensed fraud prevention services
• Regulatory data received from PAGCOR or law enforcement pursuant to lawful requests

03 How We Use Your Personal Data

aqjl processes your personal data only for specific, legitimate purposes. The table below summarises the primary purposes for which your data is used and the corresponding data categories involved.

aqjl does not use your personal data for automated decision-making that produces legal or similarly significant effects on you without human oversight, except where required by law or expressly disclosed to you at the point of collection.

04 Legal Basis for Processing

Under the Data Privacy Act of 2012 and its implementing rules, aqjl relies on the following lawful bases to process your personal data:

• Contractual necessity: Processing required to fulfil our obligations to you under the aqjl Terms and Conditions — including account creation, KYC verification, gameplay, and financial transactions.
• Legal obligation: Processing necessary to comply with Philippine laws, including PAGCOR regulatory requirements, the Anti-Money Laundering Act (RA 9160 as amended), and the Data Privacy Act itself.
• Legitimate interests: Processing necessary for aqjl's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and service improvement — where these interests are not overridden by your privacy rights.
• Consent: Where we rely on your consent for specific processing activities — such as sending promotional communications — you may withdraw consent at any time without affecting the lawfulness of prior processing. To unsubscribe from promotional emails or SMS, contact our support team or use the unsubscribe mechanism in any marketing message.

05 Data Sharing and Disclosure

aqjl does not sell, rent, or trade your personal information to any third party. Data sharing is strictly limited to the following categories of recipients, each bound by appropriate confidentiality and data protection obligations:

• Regulatory Authorities: PAGCOR (Philippine Amusement and Gaming Corporation) and the Anti-Money Laundering Council (AMLC) as required by Philippine gaming and AML legislation. aqjl is legally obligated to report covered and suspicious transactions to the AMLC under RA 9160.
• Law Enforcement: Philippine law enforcement agencies where required by a lawful court order, warrant, or regulatory directive. aqjl will notify you of such disclosures where legally permitted to do so.
• Payment Processors: GCash, PayMaya, BDO, BPI, Metrobank, and USDT processing partners, to the extent necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and are independently regulated.
• KYC and Identity Verification Providers: Accredited third-party identity verification services engaged to assist with player onboarding and ongoing due diligence. These providers are contractually bound to process your data solely for verification purposes and under strict security standards.
• IT and Platform Service Providers: Cloud hosting, cybersecurity, and platform maintenance vendors who process data on aqjl's behalf under data processing agreements that impose equivalent privacy protections.
• Game Content Providers: Where gameplay data is processed by third-party game studios integrated into the aqjl Platform, minimal technical data necessary for game operation may be shared. No personally identifiable information beyond a pseudonymous player identifier is shared with game providers.

All third-party data processors engaged by aqjl are required to implement appropriate technical and organisational security measures and are prohibited from using your data for any purpose beyond what aqjl has authorised.

06 Cookies and Tracking Technologies

The aqjl Platform uses cookies and similar technologies (such as local storage and session tokens) to operate core platform functionality, maintain session security, and gather analytics that help us improve your experience. We do not deploy third-party advertising networks or sell your behavioural data to ad platforms.

The categories of cookies used on the aqjl Platform are as follows:

You can manage or disable cookies through your browser's settings. Please note that disabling essential cookies will impair Platform functionality and may prevent you from logging in or completing transactions. No consent is required for strictly essential cookies; for functional and analytics cookies, your continued use of the Platform following acceptance of this Policy constitutes consent.

07 Data Retention

aqjl retains personal data only for as long as necessary to fulfil the purposes for which it was collected or as required by applicable Philippine law. The following retention schedule applies:

• Account data and KYC documents: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AML record-keeping obligations.
• Game activity logs: Retained for two (2) years from the date of the gaming session, unless a longer period is required for dispute resolution or regulatory review.
• Customer support communications: Retained for two (2) years from the date the support ticket is closed.
• Marketing consent records: Retained until you withdraw consent, plus one (1) additional year for compliance record-keeping purposes.
• IP address and device logs: Retained for twelve (12) months from the date of the session for fraud prevention and security purposes.

Upon expiry of the applicable retention period, data is securely deleted or irreversibly anonymised so that it can no longer be linked to any individual. Anonymised, aggregated data may be retained indefinitely for statistical and platform improvement purposes.

08 Security Measures

aqjl takes the security of your personal data seriously and implements a layered set of technical and organisational measures designed to protect your information against unauthorised access, disclosure, alteration, or destruction. Key measures include:

• Transport Encryption: All data transmitted between your device and aqjl servers is protected by 256-bit SSL/TLS encryption. Our platform enforces HTTPS across all pages and rejects unencrypted connections.
• Data-at-Rest Encryption: Sensitive personal and financial data stored in aqjl databases is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All staff with data access undergo background verification and regular data privacy training aligned with NPC guidelines.
• Multi-Factor Authentication: Administrative access to aqjl's data systems requires multi-factor authentication. Players are strongly encouraged to enable 2FA on their accounts.
• Penetration Testing and Audits: aqjl engages independent cybersecurity firms to conduct regular penetration tests and security audits of the Platform and underlying infrastructure.
• Incident Response: In the event of a personal data breach, aqjl will notify affected players and the National Privacy Commission within the timeframes prescribed by RA 10173 and NPC Circular 16-03.

09 Your Data Subject Rights

Under the Data Privacy Act of 2012 and its implementing rules, you — as a data subject — have the following rights with respect to your personal data held by aqjl. These rights may be exercised by submitting a verified written request to our Data Protection Officer (see Section 12).

Right to be Informed: You have the right to be told what personal data aqjl collects about you and the purposes for which it is used — which is the primary purpose of this Privacy Policy.

Right to Access: You may request a copy of the personal data aqjl holds about you and information about how it is being processed. aqjl will provide this within fifteen (15) business days of receiving a verified request.

Right to Correction: If your personal data held by aqjl is inaccurate, incomplete, or outdated, you have the right to have it corrected. Basic account details can be updated through your account profile; corrections to KYC documents must be submitted through our support team.

Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (for consent-based processing), or where it has been unlawfully processed. This right is subject to aqjl's legal retention obligations, including those under the Anti-Money Laundering Act.

Right to Object: You have the right to object to processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests on grounds relating to your particular situation.

Right to Data Portability: Where processing is based on your consent or contractual necessity and is carried out by automated means, you have the right to receive your personal data in a structured, commonly used, machine-readable format.

10 Minors and Age Restriction

The aqjl Platform is strictly intended for individuals who are 21 years of age or older, consistent with Philippine gaming regulations. aqjl does not knowingly collect or process personal data from persons under the age of 21.

If aqjl discovers or reasonably suspects that an account has been registered by or on behalf of an individual under 21, the account will be immediately suspended, all funds held pending investigation and potential return, and the matter referred to PAGCOR as appropriate. Any personal data collected in connection with an underage account will be retained only for the period necessary to complete the regulatory investigation and then securely deleted.

Parents and guardians who believe their minor child has accessed or registered on the aqjl Platform should contact our support team immediately at [email protected] so that we can take prompt action.

11 Changes to This Privacy Policy

aqjl reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. The effective date at the top of this document will be updated whenever a revised version is published.

For material changes — such as changes to the categories of data collected, the introduction of new processing purposes, or changes to data sharing arrangements — aqjl will provide advance notice of at least seven (7) days via email to your registered address or through a prominent in-Platform notification, prior to the new version taking effect.

For non-material clarifications or formatting updates, the revised Policy will take effect immediately upon publication. We encourage you to review this page periodically to stay informed about how aqjl protects your privacy. The most current version of this Policy always supersedes all prior versions.

12 Contact Us and Data Protection Officer

aqjl has designated a Data Protection Officer (DPO) as required under the Data Privacy Act of 2012 and NPC Circular 17-01. Our DPO is responsible for overseeing aqjl's compliance with RA 10173, handling data subject rights requests, and serving as the primary point of contact with the National Privacy Commission.

For any privacy-related questions, data subject rights requests, concerns about data processing, or to report a suspected data breach involving your personal information, please contact:

Data Protection Officer — aqjl
Email: [email protected]

Please include "Privacy / DPO Request" in the subject line of your communication. Our DPO will acknowledge receipt of your inquiry within three (3) business days and provide a substantive response within fifteen (15) business days, or within the shorter period required by NPC regulations for specific request types.

If you are not satisfied with aqjl's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines through their official complaint mechanism. aqjl fully cooperates with NPC investigations and takes all regulatory inquiries seriously.