Privacy Policy

1. Introduction

aeowin takes the privacy of its players seriously. As a platform operating under PAGCOR regulation and subject to Philippine law, including the Data Privacy Act of 2012 (RA 10173), aeowin is legally obligated to handle your personal data responsibly, transparently, and securely. This Policy applies to all personal information we process in connection with your use of the aeowin platform, whether you access it via mobile browser, desktop, or any other means.

This Policy should be read alongside the aeowin Terms and Conditions. Defined terms used in this Policy have the same meaning as in the aeowin Terms and Conditions unless otherwise stated. If you have questions about how your data is handled at any point, you may contact our Data Protection Officer through the contact details provided in Section 15 of this Policy.

We do not sell your personal data to third parties for their own marketing purposes. That has always been and continues to be our policy. The information we collect is used strictly for the purposes outlined in this document.

2. Data Controller

aeowin Casino is the data controller responsible for your personal information collected through the aeowin.cam platform. As data controller, aeowin determines the purposes and means of processing your personal data and is accountable for ensuring that processing is carried out in accordance with this Policy and applicable Philippine data protection law.

aeowin has appointed a Data Protection Officer (DPO) in accordance with the requirements of the National Privacy Commission of the Philippines. The DPO is responsible for overseeing aeowin's data protection compliance and is the primary point of contact for players who wish to exercise their data rights or raise privacy concerns. Contact details for the DPO are provided in Section 15.

3. Information We Collect

aeowin collects personal data that you provide directly, data generated through your use of the platform, and data received from third parties in the course of identity verification and payment processing. The categories of data we collect are described below.

3.1 Registration & Account Data

• Full legal name as it appears on your government-issued Philippine ID;
• Date of birth (to verify the 21-year minimum age requirement);
• Registered email address and Philippine mobile number;
• Username and encrypted account password;
• Residential address in the Philippines;
• Nationality and, where applicable, tax identification number.

3.2 Identity Verification (KYC) Data

• Copies of government-issued Philippine identification documents (e.g., PhilSys ID, passport, driver's license, UMID);
• Selfie or video verification images submitted during the KYC process;
• Proof of address documentation where required;
• Source of funds documentation for players who reach applicable transaction thresholds.

3.3 Financial & Transaction Data

• GCash account reference numbers and PayMaya wallet identifiers;
• Bank account details for BPI, BDO, UnionBank, Metrobank, and other linked accounts;
• Cryptocurrency wallet addresses used for USDT deposits and withdrawals;
• Complete history of deposits, withdrawals, bonuses, and in-game transactions;
• Records of declined or reversed payment attempts.

3.4 Gaming & Behavioural Data

• Game session history, wagering amounts, and win/loss records;
• Game preferences, favourite categories, and session duration data;
• Responsible gaming tool settings including deposit limits and session reminders;
• Customer support interaction transcripts and complaint records.

3.5 Technical & Device Data

• IP address, device type, operating system, and browser information;
• Geolocation data (country/region level) derived from IP address;
• Login timestamps, session identifiers, and access logs;
• Referral source and marketing attribution data.

4. How We Use Your Data

aeowin processes your personal data for the following purposes. Where a specific legal basis applies to each purpose, it is described in Section 5.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, aeowin processes your personal data on the following legal bases depending on the nature of the processing activity:

• Contractual Necessity: Processing required to enter into or perform the contract between you and aeowin, including account creation, payment processing, and game access;
• Legal Obligation: Processing necessary to comply with PAGCOR regulations, Philippine AML laws (Republic Act No. 9160 as amended), and applicable tax legislation;
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where such interests are not overridden by your data protection rights;
• Consent: Processing for direct marketing communications and non-essential cookies, where your freely given consent has been obtained and may be withdrawn at any time.

6. Data Sharing & Disclosure

aeowin does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your data only in the circumstances described below, and only to the extent necessary for the stated purpose.

6.1 Service Providers

aeowin engages carefully selected third-party service providers who process data on our behalf under binding data processing agreements. These include identity verification providers, payment processors, game content providers, cloud infrastructure operators, and customer support tooling vendors. All such providers are contractually required to handle your data securely and only for the purposes specified by aeowin.

6.2 Regulatory & Law Enforcement Authorities

aeowin will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent Philippine authorities where required by law, court order, or regulatory directive. aeowin will notify affected players of such disclosures where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of aeowin's business or assets, player data may be transferred to the acquiring entity as part of that transaction. Players will be notified in advance of any such transfer and of any changes to data processing that may result.

7. Cookies & Tracking Technologies

aeowin uses cookies and similar tracking technologies on the aeowin.cam platform to provide core functionality, improve your experience, and analyse platform usage. A cookie is a small data file placed on your device by your browser when you visit a website.

7.1 Essential Cookies

These cookies are strictly necessary for the aeowin platform to function. They maintain your login session, remember your game preferences, and ensure the platform loads correctly on your device. Essential cookies cannot be disabled without affecting platform functionality.

7.2 Analytics Cookies

With your consent, aeowin uses analytics cookies to understand how players interact with the platform — which pages are visited most, where players encounter issues, and how gaming sessions are structured. This data is aggregated and anonymised and is used solely to improve the aeowin platform.

7.3 Marketing Cookies

With your consent, aeowin may use marketing cookies to track referral sources and measure the effectiveness of aeowin's own promotional campaigns. aeowin does not use marketing cookies to serve third-party advertisements on external websites.

You may manage your cookie preferences at any time through your browser settings. Note that disabling certain cookies may affect the functionality of the aeowin platform.

8. Data Retention

aeowin retains personal data only for as long as necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes or enforce agreements. The retention periods applicable to the main categories of data are as follows:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR AML compliance standards and Philippine financial record-keeping obligations;
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction;
• Gaming session logs: Retained for a minimum of three (3) years for regulatory audit purposes;
• Marketing preferences and consent records: Retained until you withdraw consent, plus an additional twelve (12) months for compliance record-keeping;
• Customer support records: Retained for two (2) years from the date of resolution of the relevant interaction.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be attributed to a specific individual.

9. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the aeowin platform;
• Encryption at rest for all stored personal data and payment information;
• Two-factor authentication available for all player accounts;
• Real-time fraud detection and anomaly monitoring systems;
• Regular penetration testing and security audits conducted by independent third-party specialists;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Regular staff training on data protection obligations and information security practices.

10. Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by aeowin. To exercise any of these rights, please contact aeowin's Data Protection Officer using the contact details in Section 15.

• Right to be Informed: The right to be informed that your personal data is being processed, and the manner and extent of such processing, as described in this Policy;
• Right of Access: The right to request a copy of the personal data aeowin holds about you, along with information about how it is processed;
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected or updated without undue delay;
• Right to Erasure: The right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to aeowin'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 aeowin's legitimate interests;
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

aeowin will respond to all verified data rights requests within 30 days. Where a request is complex or numerous, we may extend this period by a further 30 days and will notify you accordingly. Requests may be subject to identity verification to protect the security of your account.

11. Children's Privacy

Parents or guardians who believe that their child has registered on the aeowin platform or has provided personal data to aeowin should contact our Data Protection Officer immediately. aeowin will investigate and take appropriate action without undue delay, including permanent account closure and deletion of all associated personal data.

12. International Data Transfers

aeowin's primary operations and data storage infrastructure are based in Asia. In the course of providing services, some personal data may be processed by aeowin's service providers in jurisdictions outside the Philippines. Where such transfers occur, aeowin ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries that provide an adequate level of data protection under Philippine law;
• Requiring all overseas processors to execute binding data processing agreements that impose obligations equivalent to those applicable under Philippine law;
• Implementing standard contractual clauses or other approved transfer mechanisms as required by the National Privacy Commission.

You may request information about the specific safeguards applied to international transfers of your personal data by contacting aeowin's Data Protection Officer.

13. Marketing Communications

With your consent, aeowin may send you promotional communications about bonuses, new game launches, tournaments, and platform news via email and SMS to your registered Philippine mobile number. Your consent to marketing communications is obtained at the point of registration and can be withdrawn at any time.

To opt out of marketing communications from aeowin, you may:

• Click the unsubscribe link included in any marketing email received from aeowin;
• Update your communication preferences in your aeowin account settings panel;
• Contact aeowin's support team via live chat and request removal from marketing communications.

Please note that opting out of marketing communications does not affect transactional communications that are necessary for the operation of your account, such as deposit confirmations, withdrawal notifications, security alerts, or account-related notices. These will continue to be sent regardless of your marketing preferences.

Players who have activated a responsible gaming self-exclusion will automatically be removed from all aeowin marketing communications for the duration of the exclusion period.

14. Changes to This Policy

aeowin may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. When material changes are made, aeowin will notify registered players via email to the registered address or via a prominent in-platform notification prior to the changes taking effect.

The effective date of the current version of this Policy is displayed at the top of this page. We encourage you to review this Policy periodically so that you are aware of how aeowin processes your personal data. Your continued use of the aeowin platform following notification of material changes constitutes your acceptance of the updated Policy.

Where a proposed change would require aeowin to process your personal data in a way that requires fresh consent, aeowin will obtain that consent before proceeding with the new processing activity.

15. Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or wish to raise a privacy concern, please contact aeowin's Data Protection Officer through the following channels:

• Email (DPO): [email protected] — please mark the subject line "Privacy / Data Rights Request" (displayed as plain text — not a clickable link);
• Live Chat: Available 24/7 through the aeowin platform — request to speak with the Data Protection team;
• Response Time: Data rights requests will receive written acknowledgement within 5 business days and a full response within 30 days.

If you are not satisfied with aeowin's response to a privacy complaint, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC). Information on how to file a complaint with the NPC is available through official Philippine government channels. aeowin will cooperate fully with any NPC investigation.