Privacy Policy

This Privacy Policy (hereinafter "Policy") describes how aceph72 ("aceph72", "we", "us", "our"), the operator of the online gaming platform accessible at aceph72.net, collects, uses, stores, discloses, and otherwise processes the personal data of individuals ("you", "your", "Data Subject") who register for, access, or interact with our platform.

This Policy applies to all personal data processed in connection with the aceph72 platform, including data collected through our website, mobile web interface, customer support channels, and any third-party integrations that connect to your aceph72 account. It does not apply to third-party websites that may be linked from our platform.

aceph72 operates under authorization from the Philippine Amusement and Gaming Corporation (PAGCOR) and processes personal data in accordance with the Republic Act 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and the relevant issuances of the National Privacy Commission (NPC).

For the purposes of the Philippine Data Privacy Act of 2012, aceph72 acts as the Personal Information Controller (PIC) with respect to the personal data it collects directly from users of the platform. Where aceph72 engages third-party service providers to process data on its behalf, those entities act as Personal Information Processors (PIPs) under binding data processing agreements that require them to handle data only as instructed by aceph72 and in accordance with applicable Philippine law.

aceph72 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and the DPA. The DPO can be contacted at [email protected] with the subject line "Data Protection Officer — Privacy Inquiry".

aceph72 collects the following categories of personal data. The specific data points collected depend on the nature of your interaction with the platform and your account verification status.

aceph72 does not intentionally collect sensitive personal information (as defined under Section 3(l) of RA 10173) such as racial or ethnic origin, political opinions, health data, or religious beliefs, except where strictly required by law (for example, health data in a responsible gaming intervention context where you voluntarily provide it).

aceph72 collects your personal data through the following channels and mechanisms:

• Direct registration: When you create an aceph72 account, you provide your name, email address, date of birth, mobile number, and other registration details directly through the signup form.
• Identity verification (KYC): When you submit identity documents — such as a Philippine passport, UMID, PhilSys national ID, driver's license, or PRC ID — for account verification prior to withdrawal.
• Financial transactions: When you make deposits or withdrawals via GCash, Maya, BPI, BDO, Metrobank, UnionBank, InstaPay, PesoNet, or any other supported payment method, your payment provider transmits relevant transaction data to our platform.
• Platform usage: Through automated technical collection as you use the platform — including server logs, session data, game interaction records, and device fingerprinting used for security verification.
• Customer support interactions: When you contact our support team via live chat, email, or any other channel, the contents of that interaction are recorded and retained.
• Cookies and tracking technologies: As described in Section 09 of this Policy, aceph72 uses session cookies, analytics cookies, and preference cookies to improve your experience on the platform.
• Third-party KYC providers: Where identity verification is performed using a third-party electronic verification service, that provider may return identity match data to aceph72 based on the documents you submit.

aceph72 processes your personal data only where there is a lawful basis for doing so under the Data Privacy Act of 2012. The table below sets out the primary purposes for which we process your data, together with the applicable legal basis under the DPA.

• Account creation and management: Processing is necessary for the performance of the contract between you and aceph72 (Section 12(b), DPA). Without this processing, we cannot provide you access to the platform.
• Identity verification (KYC/AML): Processing is required by law — specifically, PAGCOR licensing conditions and the Anti-Money Laundering Act (AMLA) as amended by RA 10927 (Section 12(c), DPA).
• Payment processing: Necessary for contract performance. Financial data is shared with your nominated payment provider solely to execute the transaction you have instructed.
• PAGCOR regulatory reporting: aceph72 is legally obligated to maintain gaming transaction records and submit periodic reports to PAGCOR. This processing is required by law (Section 12(c), DPA).
• Responsible gaming monitoring: Legitimate interest of aceph72 and public interest in preventing gambling harm, including monitoring for signs of problem gambling patterns and enforcing the 21+ age restriction.
• Security and fraud prevention: Legitimate interest — processing technical data to detect unauthorized access, fraudulent activity, and money laundering attempts (Section 12(f), DPA).
• Customer support: Contract performance and legitimate interest in resolving disputes and providing assistance to account holders.
• Marketing communications: Based solely on your freely given, specific, and informed consent (Section 12(a), DPA). You may withdraw consent at any time from account settings, without affecting the lawfulness of prior processing.
• Platform improvement and analytics: Legitimate interest — aceph72 uses aggregated and anonymized analytics to improve platform performance, game selection, and user experience.

aceph72 does not sell your personal data. We share your personal data only in the following limited and controlled circumstances:

Service Providers (Personal Information Processors)

aceph72 engages the following categories of service providers who process personal data on our behalf, under written agreements that restrict them to processing data only as instructed by aceph72:

• Payment processors: GCash (Mynt), Maya (Voyager Innovations), BancNet, Dragonpay, and other Philippine payment infrastructure providers, solely to process your deposit and withdrawal instructions.
• KYC and identity verification providers: Third-party identity verification platforms used to validate government-issued IDs and perform liveness checks in accordance with PAGCOR's KYC requirements.
• Game content providers: Licensed game studios whose titles are available on the aceph72 platform. These providers receive the minimum data necessary to load and operate the game session.
• Cloud infrastructure and security: Hosting, content delivery, DDoS protection, and fraud analytics providers operating under strict data processing agreements.
• Customer support platforms: Live chat and ticketing system providers used to deliver customer support services.

Regulatory and Law Enforcement Disclosures

aceph72 is required by Philippine law to disclose personal data to the following authorities where legally mandated:

• PAGCOR: Gaming transaction records, player account information, and suspicious activity reports as required under our operating license.
• Anti-Money Laundering Council (AMLC): Covered and suspicious transaction reports as required under the AMLA and its implementing regulations for covered persons in the gaming sector.
• National Privacy Commission (NPC): Personal data breach notifications and compliance reports as required under RA 10173.
• Philippine law enforcement authorities: In response to valid legal process (court order, subpoena, or written request from a competent authority) in connection with a criminal investigation.

aceph72 retains personal data for the minimum period necessary to fulfill the purposes for which it was collected, subject to legal retention obligations that may require us to retain certain data for longer. The following retention periods apply:

• Account and identity data: Retained for the lifetime of your account and for a period of five (5) years following account closure, in accordance with PAGCOR licensing requirements and AMLA obligations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the AMLA and its implementing regulations.
• Gaming history and session logs: Retained for five (5) years from the date of each gaming session, as required under PAGCOR's record-keeping guidelines.
• Customer support communications: Retained for three (3) years from the date of the most recent interaction, for dispute resolution and quality assurance purposes.
• Marketing preference data: Retained until you withdraw your consent or close your account, whichever is earlier. Opt-out records are retained indefinitely to prevent re-enrollment without explicit re-consent.
• Technical and security logs: Retained for one (1) year for routine security monitoring; logs related to a specific security incident may be retained longer for the duration of any investigation or legal proceeding.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification, using industry-standard data destruction methods.

aceph72 implements a comprehensive set of technical, organizational, and physical security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Key measures include:

• Transport encryption: All data in transit between your device and aceph72's servers is protected by TLS 1.2 or higher. Connections using deprecated protocols are rejected.
• Encryption at rest: Sensitive data including identity documents, payment credentials, and personally identifiable account information is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data is strictly limited to aceph72 personnel who have a demonstrated need-to-know. Role-based access controls are enforced, and all access to sensitive data is logged and audited.
• Multi-factor authentication: aceph72's internal systems require multi-factor authentication for all personnel accessing production data environments.
• Penetration testing and vulnerability scanning: aceph72 engages independent security specialists to conduct periodic penetration testing and continuous vulnerability scanning of our platform infrastructure.
• Personal data breach response: aceph72 maintains a formal incident response plan. In the event of a personal data breach that poses a real risk of serious harm to data subjects, we will notify the National Privacy Commission within 72 hours and affected players within a reasonable period, in accordance with NPC regulations.

aceph72 uses cookies and similar technologies on its platform. A cookie is a small text file placed on your device when you access a website. We use only the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the aceph72 platform to function. They manage your login session, maintain security tokens, and enable core platform features. These cookies cannot be disabled without breaking the platform. No consent is required for these cookies under applicable Philippine guidelines.
• Performance and Analytics Cookies: We use first-party analytics cookies to understand how players navigate the platform, which pages and games are most popular, and where technical errors occur. Data collected through these cookies is aggregated and does not identify individual users. These cookies require your consent.
• Preference and Functionality Cookies: These cookies remember your language preference, display settings, and other platform customizations to improve your experience on return visits. These cookies require your consent.

aceph72 does not deploy third-party advertising or tracking cookies. You can manage your cookie preferences at any time through the cookie settings panel accessible from the platform footer. Withdrawing consent for non-essential cookies will not affect your ability to use the platform.

Local Storage and Session Storage

In addition to cookies , aceph72 may use browser local storage and session storage to maintain temporary state data (such as your current game session state, UI preferences, and authentication tokens). This data is stored locally on your device and is not transmitted to our servers independently of normal platform requests. Session storage data is automatically cleared when you close your browser tab.

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by aceph72. These rights are subject to applicable legal limitations and retention obligations described in Section 07.

How to Exercise Your Rights

To exercise any of the rights described above, submit a written request to our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request — [Right Type]". Please include your full name, registered email address, and a clear description of your request. We may request additional information to verify your identity before processing the request.

aceph72 will acknowledge all data subject rights requests within five (5) business days and will provide a substantive response within thirty (30) calendar days. Where the request is complex or involves a large volume of data, we may extend this period by a further thirty (30) days, with notice to you explaining the reason for the extension.

aceph72 strictly enforces the minimum gambling age of 21 years mandated by PAGCOR for all online gaming activities in the Philippines. The aceph72 platform is not intended for, and must not be accessed by, any individual under the age of 21.

aceph72 does not knowingly collect personal data from individuals under the age of 21. During the registration process, all applicants are required to confirm their date of birth, and age verification is performed as part of the mandatory KYC process before any real-money gaming or withdrawal activity is permitted.

If aceph72 discovers that personal data has been collected from an individual who was under 21 at the time of registration, we will immediately suspend the account, void any associated transactions in accordance with PAGCOR guidelines, and delete the personal data of the underage individual from our systems, subject to any mandatory reporting obligations.

The aceph72 platform serves players in the Philippines and its primary data processing infrastructure is located in data centers within or serving the Asia-Pacific region. However, some of our third-party service providers — including cloud infrastructure providers, security vendors, and game content studios — may process data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, aceph72 ensures that such transfers are subject to appropriate safeguards in accordance with Section 21 of the Data Privacy Act and the NPC's guidelines on cross-border data transfers. These safeguards include:

• Binding contractual clauses in our data processing agreements with service providers, requiring them to maintain data protection standards equivalent to those required under Philippine law.
• Transfer only to jurisdictions or recipients that have been assessed to provide an adequate level of data protection.
• Strict data minimization — only the minimum necessary data is transferred to any third-party processor outside the Philippines.

A list of the countries to which personal data may be transferred is available upon request from our Data Protection Officer.

aceph72 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. Material changes to this Policy will be communicated to registered players via email to the address on file and/or via a prominent notice displayed on the platform no less than seven (7) days before the changes take effect.

The current version of this Privacy Policy, along with the effective date and version number, is always accessible at aceph72.net/privacy-policy. We recommend bookmarking this page and reviewing it periodically. Your continued use of the aceph72 platform following the effective date of any amendment constitutes acceptance of the revised Policy.

Where changes are required by regulatory directive or urgent legal obligation, aceph72 may implement those changes with immediate effect and provide notice as soon as practicable thereafter.

aceph72 has designated a Data Protection Officer (DPO) in accordance with Section 21 of the Data Privacy Act of 2012. The DPO is responsible for ensuring aceph72's compliance with the DPA, its IRR, and all relevant NPC issuances, and serves as the primary point of contact for data subjects wishing to exercise their rights or raise privacy concerns.

• General Privacy Inquiries: [email protected] — use subject line "Privacy Inquiry" for fastest routing.
• Data Subject Rights Requests: [email protected] — use subject line "Data Subject Rights Request — [Right Type]".
• Data Breach Notifications: If you believe you have discovered a security vulnerability affecting aceph72 player data, please contact us immediately at [email protected] with subject line "Security Disclosure".
• NPC Complaints: If you are unsatisfied with aceph72's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on the NPC complaints process is available through the NPC's official government website.