aeowin Privacy Policy

aeowin is the data controller responsible for the personal information you provide when registering for, accessing, or using the aeowin Platform at aeowin.club. As data controller, aeowin determines the purposes and means by which your personal data is processed and is responsible for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission ("NPC").

The contact details of aeowin's designated Data Protection Officer ("DPO") are set out in Section 14 of this Policy. If you have any question, concern, or complaint relating to the processing of your personal data by aeowin, the DPO is your primary point of contact.

aeowin collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect are described in the table below:

aeowin collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or responding to promotions and surveys.
• Automated Collection: Technical data and usage data collected automatically when you visit the aeowin Platform, including through cookies, server logs, and session analytics tools.
• Payment Processors: Limited financial confirmation data received from GCash, Maya, BPI, BDO, Metrobank, and other payment partners when transactions are processed. aeowin does not receive or store full payment credentials directly.
• Third-Party Game Providers: Game performance and session data received from licensed game providers such as Pragmatic Play, PG Soft, and JILI in connection with the games you play on the Platform.
• Identity Verification Partners: Results of identity verification checks conducted by third-party KYC service providers acting on aeowin's instructions.

aeowin processes your personal data only for specified, legitimate purposes. We do not process personal data in a manner that is incompatible with the purpose for which it was originally collected. Our processing purposes include:

To register and maintain your aeowin account, verify your identity and age (as required for all players to be 21 years of age or above), process your deposits and withdrawals in Philippine Pesos, and provide access to the full aeowin game library including Color Game, live casino, slots, and sports betting.

To comply with applicable Philippine gaming regulations, PAGCOR guidelines, anti-money laundering (AML) laws, counter-terrorism financing (CTF) obligations, and other legal requirements. This includes conducting enhanced due diligence on transactions that meet certain thresholds and maintaining records as required by law. We are obligated to retain certain records for regulatory purposes regardless of account closure.

To monitor, detect, investigate, and prevent fraud, cheating, collusion, money laundering, unauthorised access, and other prohibited conduct on the aeowin Platform. This includes analysis of login patterns, transaction behaviour, and game play activity to identify anomalies.

To respond to your enquiries, complaints, and support requests submitted via email or live chat, and to maintain records of communications for quality assurance and dispute resolution purposes.

To administer and enforce responsible gaming tools including deposit limits, loss limits, session break reminders, cool-off periods, and self-exclusion requests. To monitor gaming behaviour patterns and proactively identify players who may benefit from responsible gaming intervention.

To analyse aggregate usage data in order to improve the aeowin Platform's performance, game selection, user interface, and overall player experience. Analytics data used for this purpose is processed in aggregate or pseudonymised form where possible.

To send you promotional offers, bonuses, news, and updates about aeowin by SMS or email, but only if you have opted in to receive such communications at registration or subsequently via your account settings. You may opt out at any time by updating your communication preferences in your account or contacting [email protected].

aeowin processes your personal data on the following legal bases as recognised under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform our obligations under the aeowin Terms & Conditions, including account management, game provision, and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine law, including PAGCOR regulations, AML legislation, and tax obligations.
• Legitimate Interests: Processing for fraud prevention, platform security, and analytics, where aeowin's legitimate interests are not overridden by your rights and freedoms.
• Consent: Processing of data for marketing communications and non-essential cookies, which requires your affirmative opt-in consent and which you may withdraw at any time.

aeowin does not sell, rent, or otherwise commercially transfer your personal data to third parties. We may share your data only in the following limited circumstances:

aeowin shares personal data with carefully selected third-party service providers who assist in operating the Platform, including payment processors (GCash, Maya), game providers (Pragmatic Play, PG Soft, JILI), identity verification services, IT infrastructure providers, and customer support platforms. All service providers are contractually bound to handle personal data solely in accordance with aeowin's instructions and applicable data protection law.

aeowin will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, or other regulatory bodies when required to do so by applicable Philippine law, court order, or lawful regulatory direction. aeowin will notify you of any such disclosure where legally permitted to do so.

In the event of a merger, acquisition, or sale of all or part of aeowin's business, personal data held by aeowin may be transferred to the acquiring entity as part of that transaction, subject to the acquiring entity agreeing to honour the obligations set out in this Privacy Policy.

aeowin retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our retention periods are guided by the following principles:

• Active Accounts: Personal data associated with an active aeowin account is retained for the duration of the account relationship and for a period of five (5) years following account closure, unless a longer retention period is required by law.
• Financial and Transaction Records: Transaction histories and related financial records are retained for a minimum of five (5) years following each transaction, in compliance with Philippine AML legislation and PAGCOR requirements.
• KYC Documents: Identity verification documents are retained for five (5) years from the date of verification or account closure, whichever is later.
• Marketing Data: Opt-in records and marketing communication history are retained for three (3) years from the date of last consent, or until consent is withdrawn.
• Technical Logs: Server and access logs are retained for up to twelve (12) months for security and fraud monitoring purposes, after which they are securely deleted.

When personal data is no longer required for any lawful purpose, aeowin securely destroys or anonymises it in accordance with industry best practices.

The aeowin Platform uses cookies and similar technologies to operate effectively, maintain your session, and understand how players interact with the site. The following types of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in to your aeowin account and security cookies that help detect and prevent fraud. These cannot be disabled without affecting core functionality.
• Functional Cookies: Enable enhanced features such as remembering your language preference, game settings, and display preferences. Disabling these may affect your experience on the Platform.
• Analytics Cookies: Allow aeowin to understand how players use the Platform — which pages are visited most, where errors occur, and how long sessions last. This data is used in aggregate to improve the Platform. Analytics cookies require your consent.

aeowin implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction:

• All data transmitted between your device and aeowin servers is protected by industry-standard Transport Layer Security (TLS) with 256-bit encryption.
• Passwords are stored using one-way cryptographic hashing; aeowin employees cannot see or retrieve your password in plain text.
• Access to personal data within aeowin's systems is restricted to authorised personnel on a strict need-to-know basis, enforced by role-based access controls.
• KYC documents and financial records are stored in encrypted, access-logged secure storage environments.
• Regular internal security assessments and vulnerability reviews are conducted to identify and remediate potential weaknesses in the Platform's security posture.
• Incident response procedures are in place to detect, contain, and notify affected players and the National Privacy Commission in the event of a personal data breach within the mandatory 72-hour reporting window.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by aeowin. aeowin is committed to responding to all valid rights requests within thirty (30) calendar days:

If aeowin becomes aware that personal data has been submitted by or on behalf of a person under the age of 21, that account will be immediately suspended and all associated personal data will be securely deleted, subject to any mandatory regulatory reporting obligations. Any funds held in such an account will be handled in accordance with aeowin's Terms & Conditions.

aeowin uses mandatory age verification as part of its KYC process to prevent underage registration. If you believe a minor has accessed the aeowin Platform or provided personal data, please contact [email protected] immediately.

While aeowin primarily serves Philippine players and holds data on servers subject to Philippine jurisdiction, certain service providers — including game providers and technology infrastructure partners — may process data in jurisdictions outside the Philippines. Where such transfers occur, aeowin ensures that appropriate safeguards are in place to protect the transferred data to a standard equivalent to that required under the Philippine Data Privacy Act, including the use of data processing agreements incorporating the NPC's prescribed data transfer mechanisms.

aeowin does not transfer personal data to jurisdictions that have not been assessed as providing an adequate level of data protection without implementing appropriate contractual and technical safeguards.

aeowin may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or Platform features. The "Effective Date" at the top of this Policy indicates when the current version came into force.

Material changes to this Policy — changes that significantly affect how we process your personal data or that expand the purposes for which it is used — will be communicated to registered players by email or by prominent notice on the aeowin Platform at least fourteen (14) days before the changes take effect. For non-material clarifications and updates, the revised Policy will be published on this page without separate notification.

Your continued use of the aeowin Platform following the effective date of any revision to this Privacy Policy constitutes your acknowledgement of the changes. If you do not agree to the revised Policy, you should cease using the Platform and may request account closure by contacting [email protected].

For any question, concern, or formal request relating to this Privacy Policy or the processing of your personal data by aeowin, please contact us through the following channels. All written requests should clearly state your full name as registered on your aeowin account, the nature of your request, and any relevant details to help us respond efficiently.