ayalawin Privacy Policy

ayalawin is committed to protecting the privacy and personal data of every player who uses our platform. We understand that when you share your personal information with us — whether during registration, during gameplay, or when contacting our support team — you are placing your trust in us. We take that responsibility seriously.

This Privacy Policy applies to all personal data collected by ayalawin through the ayalawin.app website, mobile-optimized browser experience, and any related services, promotions, or communications. It covers data collected from registered players, visitors who browse the Platform without registering, and individuals who contact us through any channel.

This Policy should be read together with the ayalawin Terms & Conditions, which govern your use of the Platform. In the event of any conflict between this Policy and the Terms & Conditions on matters of data privacy, this Privacy Policy shall prevail.

ayalawin collects personal data that is necessary to provide you with a safe, compliant, and enjoyable online casino experience. The categories of personal data we collect include the following:

2.1 Identity & Contact Data

• Full legal name (as it appears on your government-issued ID);
• Date of birth (to verify you are 21 years of age or older);
• Residential address (including barangay, city/municipality, province, and postal code);
• Email address;
• Mobile number (Philippine mobile number preferred);
• Nationality and country of residence.

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, driver's license, SSS ID, UMID, PhilSys National ID);
• Proof of address documents (e.g., utility bills, bank statements);
• Selfie or live photo for identity verification purposes;
• Source of funds documentation where required by applicable AML regulations.

2.3 Financial & Transaction Data

• GCash account details (registered mobile number and account name);
• PayMaya account details;
• Philippine bank account details (BPI, BDO, Metrobank, or other supported banks);
• Deposit and withdrawal history;
• Transaction amounts in Philippine Peso (PHP / ₱);
• Payment method used for each transaction.

2.4 Gaming & Activity Data

• Game history, including games played, wager amounts, and outcomes;
• Session duration and frequency of play;
• Bonus and promotion usage history;
• Responsible gaming tool usage (e.g., deposit limits set, cool-off periods activated);
• Account balance history.

2.5 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser type;
• Unique device identifiers;
• Login timestamps and session data;
• Referring URL and navigation path on the Platform.

2.6 Communications Data

• Records of live chat conversations with our support team;
• Email correspondence with ayalawin;
• Feedback, complaints, and dispute records.

ayalawin collects your personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated collection: Technical and device data collected automatically when you access the Platform, through cookies, web beacons, and similar tracking technologies (see Section 7);
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment confirmation data from GCash, PayMaya, and banking partners;
• Regulatory sources: Data received from PAGCOR or other Philippine regulatory authorities in connection with compliance obligations.

ayalawin uses your personal data only for legitimate, specified purposes. The table below summarizes the primary purposes for which we process your data:

ayalawin will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a new lawful basis for processing.

Under the Philippine Data Privacy Act of 2012, ayalawin processes your personal data on one or more of the following lawful bases:

• Consent: Where you have given clear, informed, and freely given consent to the processing of your personal data for a specific purpose, such as receiving marketing communications or promotional offers from ayalawin;
• Contract performance: Where processing is necessary to fulfill our contractual obligations to you under the ayalawin Terms & Conditions, including providing gaming services, processing transactions, and managing your account;
• Legal obligation: Where processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, the Anti-Money Laundering Act (RA 9160 as amended), and the Data Privacy Act itself;
• Legitimate interest: Where processing is necessary for the legitimate interests of ayalawin or a third party, provided those interests are not overridden by your rights and interests. This includes fraud prevention, platform security, and service improvement activities.

Where we rely on your consent as the legal basis for processing, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

ayalawin does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

6.1 Regulatory and Law Enforcement Authorities

ayalawin is required by Philippine law to share certain data with regulatory and law enforcement bodies, including:

• The Philippine Amusement and Gaming Corporation (PAGCOR) — for licensing compliance and regulatory reporting;
• The Anti-Money Laundering Council (AMLC) — for suspicious transaction reporting under RA 9160;
• The National Privacy Commission (NPC) — in the event of a data breach or upon regulatory inquiry;
• Philippine law enforcement agencies — where required by court order or lawful authority.

6.2 Service Providers and Data Processors

ayalawin engages trusted third-party service providers who process personal data on our behalf, under strict contractual data processing agreements. These include:

• KYC and identity verification service providers;
• Payment processing partners (GCash, PayMaya, and Philippine banking partners);
• Fraud detection and prevention service providers;
• Cloud hosting and data storage providers;
• Customer support platform providers;
• Game software providers (who may receive anonymized gameplay data).

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of ayalawin's assets, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and the privacy practices of the acquiring entity prior to the transfer taking effect.

ayalawin uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and gather analytics data that helps us improve our services. A cookie is a small text file placed on your device when you visit the Platform.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as your preferred language and display settings, to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how players use the Platform — which pages are visited most, how long sessions last, and where players encounter errors. This data helps us improve the Platform.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your interests and gaming activity. These are only placed with your consent.

7.2 Managing Cookies

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a new cookie is placed. Please note that disabling strictly necessary cookies may impair the functionality of the Platform and prevent you from accessing certain features.

ayalawin retains your 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 regulation. The following retention periods apply:

Upon expiry of the applicable retention period, ayalawin will securely delete or anonymize your personal data in accordance with our internal data disposal procedures. Anonymized data that can no longer be linked to an identifiable individual may be retained indefinitely for statistical and analytical purposes.

ayalawin implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security framework includes:

• Encryption in transit: All data transmitted between your device and the ayalawin Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols;
• Encryption at rest: Sensitive personal data stored in our databases is encrypted using AES-256 encryption;
• Access controls: Access to personal data is restricted to authorized ayalawin personnel on a strict need-to-know basis. All access is logged and audited;
• Two-factor authentication: Available for player accounts and mandatory for all internal administrative access;
• Regular security audits: ayalawin conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities;
• Data breach response: ayalawin maintains a documented data breach response plan. In the event of a breach affecting your personal data, we will notify the National Privacy Commission (NPC) within 72 hours and affected players within a reasonable timeframe, as required by RA 10173.

While ayalawin takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your account credentials and for notifying ayalawin immediately if you suspect unauthorized access to your account.

The Philippine Data Privacy Act of 2012 grants you the following rights with respect to your personal data held by ayalawin. You may exercise any of these rights by contacting our Data Protection Officer using the contact details in Section 14.

ayalawin will respond to all data rights requests within thirty (30) days of receipt. In complex cases, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reason for it.

ayalawin is an online casino platform intended exclusively for adults. In the Philippines, the minimum legal age for participation in casino-style gambling is 21 years old. ayalawin strictly enforces this age restriction and does not knowingly collect personal data from individuals under the age of 21.

During the registration process, all applicants are required to declare their date of birth and submit valid government-issued identification confirming they are 21 years of age or older. Accounts found to belong to individuals under 21 will be immediately suspended and all funds returned in accordance with our responsible gaming procedures.

If ayalawin discovers that personal data has been collected from an individual under the age of 21 without verifiable parental or guardian consent, we will delete that data promptly and close the associated account. We encourage parents and guardians in Manila, Cebu, Davao, Quezon City, Makati, and across the Philippines to make use of parental control tools to prevent minors from accessing online gambling platforms.

ayalawin primarily stores and processes your personal data within the Philippines. However, some of our third-party service providers — including cloud infrastructure providers, KYC verification partners, and game software providers — may process data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, ayalawin ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under RA 10173. These safeguards may include:

• Contractual clauses requiring the recipient to process data in accordance with Philippine data privacy standards;
• Transfers to jurisdictions that the National Privacy Commission has recognized as providing an adequate level of data protection;
• Binding corporate rules where the recipient is part of the same corporate group as ayalawin.

You may request information about the specific safeguards in place for any international transfer of your personal data by contacting our Data Protection Officer.

ayalawin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When we make material changes to this Policy, we will:

• Post the updated Privacy Policy on this page with a revised effective date;
• Send a notification to your registered email address summarizing the key changes;
• Display a prominent notice on the Platform for a period of at least 30 days following the update.

Your continued use of the ayalawin Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you should discontinue use of the Platform and may request closure of your account.

We encourage you to review this Privacy Policy periodically to stay informed about how ayalawin protects your personal data. The current version of this Policy is always available at ayalawin.app/privacy-policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way ayalawin handles your personal data, please contact our Data Protection Officer (DPO) using the details below. All data privacy inquiries are handled with strict confidentiality.

If you are not satisfied with our response to your data privacy inquiry or believe that ayalawin has violated your rights under RA 10173, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. The NPC is the independent regulatory body responsible for administering and enforcing the Data Privacy Act of 2012 in the Philippines.

ayalawin is committed to resolving all data privacy concerns promptly and fairly. We view every inquiry as an opportunity to improve our data protection practices and strengthen the trust of our players across the Philippines.