Privacy Policy – aryonplay

1. Data Controller

The data controller responsible for personal information collected through the aryonplay platform at aryonplay.club is the operator of aryonplay, a PAGCOR-licensed online gaming operator with principal operations in Metro Manila, Philippines.

For all data privacy matters, our designated Data Privacy Officer (DPO) can be contacted at: [email protected] — please use the subject line "Data Privacy Request" to ensure your communication is directed to the DPO team.

2. Personal Data We Collect

2.1 Registration Data

When you create an aryonplay account, we collect: full legal name, date of birth, email address, Philippine mobile number, and country of residence. This data is required to create and verify your account and cannot be omitted.

2.2 Identity Verification (KYC) Data

To comply with PAGCOR requirements and the Philippine Anti-Money Laundering Act, we collect government-issued Philippine identification documents (e.g., PhilSys National ID, passport, driver's licence, UMID, SSS card, PRC ID) and proof of address. Selfie/liveness verification may also be required for high-value accounts.

2.3 Financial Data

We collect GCash account details, Maya account details, BDO/BPI/Metrobank account numbers, and other payment method identifiers as provided by you for the purpose of processing deposits and withdrawals. We do not store full credit card numbers or CVV codes — card-based transactions are processed by certified payment processors.

2.4 Gaming & Transaction Data

We record all platform activity, including: game sessions, bet amounts, outcomes, deposit and withdrawal transactions, bonus activations, session timestamps, and responsible gaming tool interactions. This data is used for account management, regulatory reporting, and dispute resolution.

2.5 Technical & Device Data

We collect IP address, device type, operating system, browser type and version, and session activity logs. This data is used for security monitoring, fraud detection, and platform optimisation.

2.6 Communications Data

We retain records of communications between you and aryonplay support — including live chat transcripts, email correspondence, and support ticket records — for a period consistent with our retention schedule (see Section 6).

3. How We Use Your Personal Data

aryonplay uses your personal data for the following purposes:

• Account creation and management — To create, maintain, and administer your aryonplay player account.
• Identity verification and KYC compliance — To fulfil PAGCOR licensing conditions and AMLA obligations requiring us to verify the identity of all players.
• Payment processing — To process deposits and withdrawals via GCash, Maya, bank transfers, and other supported Philippine payment methods.
• Game delivery and platform operation — To provide access to casino games, record game outcomes, maintain game history, and manage bonuses.
• Fraud prevention and security — To detect and prevent unauthorised account access, duplicate accounts, collusive play, money laundering, and other prohibited conduct.
• Regulatory reporting — To submit mandatory reports to PAGCOR and the Anti-Money Laundering Council (AMLC) as required by Philippine law.
• Customer support — To respond to your queries, resolve disputes, and manage complaints.
• Responsible gaming — To monitor play patterns for indicators of problem gambling and administer self-exclusion and deposit limit tools.
• Marketing communications — To send promotional offers and platform updates to players who have opted in. You may withdraw this consent at any time.
• Platform improvement — To analyse aggregate usage patterns and improve aryonplay's products and user experience.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act, aryonplay processes personal data on the following lawful bases:

• Contractual necessity — Processing required to fulfil the player account agreement with you, including account creation, payment processing, and game delivery.
• Legal obligation — Processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act, and other applicable Philippine laws.
• Legitimate interests — Processing for fraud prevention, security monitoring, and responsible gaming compliance, where these interests are not overridden by your privacy interests.
• Consent — Processing for marketing communications and non-essential cookies, where you have provided explicit consent. Consent may be withdrawn at any time.

5. Data Sharing and Disclosure

5.1 Service Providers

aryonplay shares personal data with trusted third-party service providers who assist in operating the platform, including: KYC verification providers, payment processors (GCash/GXI, Maya/Paymaya Philippines, Inc., and banking partners), game software providers, cloud infrastructure providers, and fraud detection service providers. All service providers are bound by data processing agreements that prohibit use of your data outside the scope of services provided to aryonplay.

5.2 Regulatory Authorities

aryonplay discloses personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies when required by law, regulation, or official directive. aryonplay will comply with valid legal process and will notify affected players of such disclosures where legally permitted to do so.

5.3 No Sale of Personal Data

aryonplay does not sell, rent, or otherwise transfer your personal data to third parties for their own marketing or commercial purposes. This is an unconditional commitment.

5.4 Business Transfers

In the event of a merger, acquisition, or transfer of aryonplay's business operations, player personal data may be transferred to the acquiring entity as part of the business assets. Players will be notified of such a transfer and provided with the option to close their account and request data deletion prior to the transfer taking effect.

6. Data Retention

aryonplay retains personal data for the periods specified below, or longer where required by law:

After the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be associated with any individual.

7. Security Measures

aryonplay implements the following technical and organisational security measures to protect your personal data:

• 256-bit SSL/TLS encryption on all data transmissions between your device and aryonplay servers.
• Encryption of sensitive personal data at rest, including KYC documents and financial information.
• Role-based access controls limiting staff access to personal data on a need-to-know basis.
• Two-factor authentication required for all internal administrative access to player data systems.
• Regular penetration testing and vulnerability assessments by independent third-party security firms.
• Security incident response procedures aligned with NPC breach notification requirements — aryonplay will notify affected players and the NPC within 72 hours of discovering a breach that poses a real risk to the rights and freedoms of data subjects.

8. Cookies and Tracking Technologies

aryonplay uses the following categories of cookies:

• Strictly necessary cookies — Session authentication tokens and CSRF protection tokens required for platform operation. These cannot be disabled without breaking core functionality.
• Functional cookies — Preference storage for language settings, responsible gaming tool states, and login "Remember me" state. These can be managed through browser settings.
• Analytics cookies — Anonymised page view and navigation analytics collected solely for internal platform improvement purposes. aryonplay does not use third-party analytics platforms that track users across sites.

aryonplay does not use advertising tracking cookies, cross-site tracking pixels, or third-party retargeting technologies. You can manage or delete cookies through your browser's privacy settings at any time.

9. Your Data Rights

Under the Philippine Data Privacy Act (Republic Act No. 10173), you have the following rights regarding your personal data held by aryonplay:

• Right to be informed — You have the right to know what personal data aryonplay holds about you, how it is being used, and with whom it is shared.
• Right of access — You may request a copy of the personal data aryonplay holds about you. Requests will be fulfilled within 30 calendar days.
• Right to rectification — You may request correction of inaccurate or incomplete personal data. Identity-critical data (name, date of birth) requires supporting documentation for correction.
• Right to erasure / blocking — You may request deletion or blocking of personal data that is no longer necessary for the purposes for which it was collected, subject to legal retention obligations under PAGCOR/AMLA requirements.
• Right to data portability — You may request your personal data in a structured, commonly used machine-readable format where technically feasible.
• Right to object — You may object to processing of your personal data on grounds of legitimate interest, including for direct marketing purposes.
• Right to lodge a complaint — You have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph) if you believe your data rights have been violated.

To exercise any of these rights, contact aryonplay's Data Privacy Officer at [email protected] with the subject line "Data Privacy Request." You will be required to verify your identity before requests are processed.

10. Children and Minors

The aryonplay platform is strictly intended for individuals aged 21 years and above. aryonplay does not knowingly collect personal data from persons under 21 years of age. All registrations are subject to mandatory age verification during the KYC process. If aryonplay discovers that personal data has been collected from a person under 21 years of age, the account will be closed immediately and all collected data will be deleted — except where retention is required to comply with legal obligations.

If you believe a minor has registered an account on aryonplay, please contact [email protected] immediately. 🔞

11. Third-Party Services

The aryonplay platform integrates with third-party service providers to deliver payment processing, game content, and identity verification. These providers operate under their own privacy policies. aryonplay selects service providers with data protection standards consistent with Philippine DPA requirements and PAGCOR vendor compliance rules. The key third-party categories include:

• Payment providers: GXI Inc. (GCash), PayMaya Philippines Inc. (Maya), BDO Unibank, Bank of the Philippine Islands, Metrobank, Coins.ph — for deposit and withdrawal processing.
• KYC / identity verification providers: Certified identity verification platforms used to validate government-issued Philippine IDs.
• Game content providers: Licensed international and regional casino game software providers whose games are certified for use on PAGCOR-licensed platforms.
• Cloud infrastructure: Data centre and hosting providers operating under contractual data processing obligations consistent with Philippine DPA requirements.

12. Account Closure and Data Handling

12.1 When you close your aryonplay account, your account profile is deactivated. Personal data required to be retained under PAGCOR and AMLA obligations will be retained for the statutory periods set out in Section 6. All other personal data will be deleted or anonymised within 90 days of account closure.

12.2 If you wish to exercise your right to erasure at the time of account closure, note that data retained for legal compliance purposes cannot be deleted ahead of the applicable statutory retention period. aryonplay will confirm in writing which data categories are being retained and on what legal basis.

12.3 Self-excluded players' exclusion records are retained for the duration of the exclusion and for a period after to prevent re-registration during the exclusion window.

13. Changes to This Privacy Policy

aryonplay may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or platform operations. Material changes will be communicated to registered players via the email address associated with their account at least 7 days before the change takes effect. The "Last Updated" date at the top of this page reflects when the policy was most recently revised. Your continued use of the aryonplay platform after a policy update constitutes your acknowledgment of the revised policy.

14. Contact and Data Privacy Officer

For all data privacy enquiries, requests, or complaints, please contact aryonplay's Data Privacy Officer:

• Email: [email protected] (subject line: "Data Privacy Request")
• Response time: Acknowledgement within 3 business days; substantive response within 30 calendar days as required under the Philippine DPA.
• Regulatory authority: National Privacy Commission of the Philippines — for unresolved complaints after aryonplay's internal process has been exhausted.