ayalawin Privacy Policy

1Introduction

ayalawin ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of every individual who interacts with our platform. Whether you are a registered player, a visitor browsing our website, or someone who has contacted our support team, we handle your personal information with the utmost care, transparency, and respect for your rights under Philippine law.

This Privacy Policy describes in detail the categories of personal data that ayalawin collects, the purposes for which that data is processed, the legal bases that justify such processing, the parties with whom data may be shared, the security measures we employ to protect your information, and the rights available to you as a data subject under the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations.

This Privacy Policy applies to all personal data collected through the ayalawin website, mobile platform, customer support channels, and any other touchpoint through which you interact with ayalawin. It should be read alongside the ayalawin Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

If you have any questions about this Privacy Policy or how ayalawin handles your personal data, please refer to Section 14 for contact details of our Data Protection Officer.

2Data Controller

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, ayalawin is the personal information controller in respect of the personal data collected through the ayalawin platform. As the personal information controller, ayalawin determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

ayalawin has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with the Data Privacy Act, handling data subject requests, and serving as the primary point of contact for the National Privacy Commission (NPC) of the Philippines. The contact details of the ayalawin DPO are provided in Section 14 of this Privacy Policy.

3Personal Data We Collect

ayalawin collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is processed. The categories of personal data we collect include the following:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (for age verification purposes);
• Philippine mobile number and email address;
• Residential address (province, city, barangay);
• Government-issued identification number (e.g., PhilSys ID, passport number, driver's license number).

3.2 Account and Transaction Data

• ayalawin username and account ID;
• Account registration date and login history;
• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method references;
• Bonus and promotional activity records;
• Game history, wagering records, and session data.

3.3 Technical and Device Data

• IP address and approximate geolocation derived therefrom;
• Device type, operating system, and browser information;
• Session duration, pages visited, and clickstream data;
• Cookies and similar tracking technology data (see Section 9).

3.4 Communications Data

• Records of communications between you and ayalawin customer support, including live chat transcripts, email correspondence, and support ticket history;
• Survey responses and feedback submitted through the ayalawin platform.

3.5 Sensitive Personal Information

In certain circumstances, ayalawin may collect sensitive personal information as defined under the Data Privacy Act of 2012, including but not limited to government-issued identification numbers and financial account information. Such sensitive personal information is collected only to the extent strictly necessary for identity verification, KYC compliance, and anti-money laundering obligations, and is subject to enhanced security measures.

4How We Collect Your Data

ayalawin collects personal data through the following means:

• Direct Collection: Information you provide when registering an ayalawin account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Collection: Technical and device data collected automatically when you access the ayalawin platform, including through cookies, web beacons, and server logs.
• Third-Party Sources: Identity verification data from KYC service providers; fraud detection signals from payment processors; geolocation data from IP intelligence services. ayalawin only receives data from third parties where there is a lawful basis for such sharing.
• Publicly Available Sources: In limited circumstances, ayalawin may verify information against publicly available government databases or credit reference agencies for fraud prevention purposes.

5Purpose & Legal Basis for Processing

ayalawin processes your personal data only where there is a lawful basis for doing so under the Data Privacy Act of 2012. The primary purposes for which ayalawin processes personal data, and the corresponding legal bases, are as follows:

• Account Registration and Management: Processing is necessary for the performance of the contract between you and ayalawin (i.e., the Terms & Conditions). Without this data, we cannot create or maintain your ayalawin account.
• Identity Verification and KYC: Processing is required to comply with legal obligations under Philippine anti-money laundering laws (RA 9160, as amended) and PAGCOR regulatory requirements.
• Payment Processing: Processing is necessary for the performance of the contract and to comply with financial regulatory obligations.
• Fraud Prevention and Security: Processing is necessary for the legitimate interests of ayalawin in protecting the platform and its players from fraud, money laundering, and other criminal activity.
• Customer Support: Processing is necessary for the performance of the contract and for the legitimate interest of ayalawin in providing effective player support.
• Marketing and Promotions: Processing is based on your consent, which you may withdraw at any time. ayalawin will only send you promotional communications where you have opted in to receive them.
• Responsible Gaming Monitoring: Processing is necessary to comply with regulatory obligations and for the legitimate interest of ayalawin in protecting player welfare.
• Platform Improvement and Analytics: Processing is based on the legitimate interest of ayalawin in improving the quality and performance of the platform, subject to appropriate safeguards.

6Data Sharing & Disclosure

ayalawin does not sell, rent, or trade your personal data to any third party for commercial purposes. We may, however, share your personal data with the following categories of recipients where necessary and lawful:

• Payment Service Providers: GCash, PayMaya/Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) receive transaction data necessary to process your deposits and withdrawals.
• KYC and Identity Verification Providers: Third-party identity verification services that assist ayalawin in fulfilling its KYC and anti-money laundering obligations.
• Game Software Providers: Licensed game providers whose software powers the ayalawin casino may receive anonymized or pseudonymized session data for game integrity and technical support purposes.
• Regulatory Authorities: The Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory mandate.
• Law Enforcement: Philippine law enforcement agencies where disclosure is required pursuant to a valid legal order, warrant, or subpoena.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and fraud detection service providers who process data on behalf of ayalawin under strict data processing agreements.

All third parties with whom ayalawin shares personal data are required to handle such data in accordance with the Data Privacy Act of 2012 and are bound by contractual obligations that prohibit them from using your data for any purpose other than those specified by ayalawin.

7Data Retention

ayalawin retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following retention periods apply:

• Account and Transaction Data: Retained for a minimum of five (5) years from the date of the last transaction, in compliance with the Anti-Money Laundering Act (RA 9160, as amended) and PAGCOR record-keeping requirements.
• KYC and Identity Verification Documents: Retained for a minimum of five (5) years from account closure or the date of the last transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last support interaction.
• Marketing Consent Records: Retained for the duration of your ayalawin account and for three (3) years following account closure, to demonstrate compliance with consent requirements.
• Technical and Device Data: Retained for up to twelve (12) months from collection, unless required for longer periods for fraud investigation or legal proceedings.

Upon expiry of the applicable retention period, ayalawin will securely delete or anonymize your personal data in accordance with its data disposal procedures, unless retention is required by a specific legal obligation or ongoing legal proceedings.

8Data Security

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

• Encryption: All data transmitted between your device and the ayalawin platform is encrypted using Transport Layer Security (TLS) protocol. Sensitive data at rest, including financial information and government ID details, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data within ayalawin is restricted on a strict need-to-know basis. All staff with access to personal data undergo background checks and regular data privacy training.
• Two-Factor Authentication: ayalawin offers two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
• Penetration Testing: The ayalawin platform undergoes regular independent security audits and penetration testing to identify and remediate vulnerabilities.
• Incident Response: ayalawin maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, ayalawin will notify the National Privacy Commission and affected data subjects within the timeframes prescribed by the Data Privacy Act.

9Cookies & Tracking Technologies

ayalawin uses cookies and similar tracking technologies to enhance your experience on the platform, ensure platform security, and gather analytics data that helps us improve our services. The types of cookies used by ayalawin include:

• Strictly Necessary Cookies: Essential for the operation of the ayalawin platform, including session management, authentication, and security functions. These cookies cannot be disabled without affecting platform functionality.
• Performance and Analytics Cookies: Used to collect anonymized data about how players use the ayalawin platform, including pages visited, session duration, and error reports. This data helps us improve platform performance and user experience.
• Functional Cookies: Used to remember your preferences, such as language settings and display preferences, to provide a more personalized experience on ayalawin.
• Marketing Cookies: Used, with your consent, to deliver relevant promotional content and to measure the effectiveness of ayalawin's marketing campaigns. You may opt out of marketing cookies at any time through your browser settings or by contacting our DPO.

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the ayalawin platform. For detailed information on managing cookies in your specific browser, refer to your browser's help documentation.

10Your Data Subject Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by ayalawin. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

ayalawin will respond to all data subject requests within thirty (30) days of receipt. Complex requests may require additional time, in which case ayalawin will notify you of the extended timeframe and the reasons for the delay. ayalawin reserves the right to verify your identity before processing any data subject request to prevent unauthorized disclosure of personal data.

11Children's Privacy

The ayalawin platform is strictly intended for adults aged twenty-one (21) years and above. ayalawin does not knowingly collect, process, or retain personal data from individuals under the age of 21. The collection of personal data from minors is strictly prohibited under both the Data Privacy Act of 2012 and Philippine gaming regulations.

If ayalawin becomes aware that personal data has been collected from an individual under the age of 21, such data will be immediately deleted and the associated account will be closed in accordance with the ayalawin Terms & Conditions. If you are a parent or guardian and believe that your child has registered on the ayalawin platform, please contact our Data Protection Officer immediately using the contact details in Section 14.

ayalawin employs age verification procedures during the registration process and reserves the right to request government-issued proof of age at any time. 21+

12Cross-Border Data Transfers

In the course of providing its services, ayalawin may transfer your personal data to service providers or partners located outside the Philippines, including game software providers, cloud infrastructure providers, and fraud detection services. Any such cross-border transfer of personal data is carried out in compliance with Section 21 of the Data Privacy Act of 2012 and the relevant NPC issuances on cross-border data transfers.

ayalawin ensures that all cross-border transfers of personal data are subject to appropriate safeguards, which may include:

• Data processing agreements incorporating standard contractual clauses approved by the NPC;
• Transfers to countries or organizations that have been assessed as providing an adequate level of data protection;
• Binding corporate rules where transfers occur within a corporate group.

You may request information about the specific safeguards applicable to any cross-border transfer of your personal data by contacting the ayalawin Data Protection Officer.

13Amendments to This Privacy Policy

ayalawin 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 to this Privacy Policy, ayalawin will notify registered players via email or through a prominent notice on the platform at least seven (7) days before the changes take effect, where practicable.

The "Last Updated" date at the top of this Privacy Policy indicates when it was most recently revised. Your continued use of the ayalawin platform after the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy. We encourage you to review this Privacy Policy periodically to stay informed about how ayalawin protects your personal data.

If any amendment materially affects the way ayalawin processes your personal data in a manner that requires fresh consent, ayalawin will seek your explicit consent before the amended processing commences.

14Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ayalawin, please contact our Data Protection Officer through the following channels:

For general customer support inquiries unrelated to data privacy, you may contact the ayalawin support team at [email protected] or via live chat on the ayalawin platform, available 24 hours a day, 7 days a week.

If you are not satisfied with ayalawin's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.