aah77 Privacy Policy — How We Handle Your Data

01 Data Controller

The data controller responsible for your personal data collected through the aah77 Platform is the operating entity of aah77.org, a PAGCOR-licensed online gaming operator based in the Philippines. For the purposes of Republic Act No. 10173 (Data Privacy Act of 2012), aah77 is the personal information controller (PIC) of your data.

aah77 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable Philippine data privacy law. The DPO can be reached at the contact details provided in Section 14 of this Policy. All data subject requests and privacy-related inquiries should be directed to the DPO.

02 Personal Data We Collect

aah77 collects the following categories of personal data depending on how you interact with the Platform:

aah77 does not collect sensitive personal information as defined under Section 3(l) of RA 10173 (such as racial or ethnic origin, political opinions, religious beliefs, or health data) except where required for responsible gaming interventions or legally mandated AML purposes.

03 Lawful Basis for Processing

aah77 processes your personal data on the following lawful bases under RA 10173 and applicable PAGCOR data governance requirements:

• Contractual necessity: Processing required to perform the contract between aah77 and the User — including account management, payment processing, game provision, and withdrawal services;
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR licensing conditions, AML obligations under RA 9160, KYC requirements, and tax reporting;
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and analytics necessary for aah77 to operate lawfully and safely — where such processing does not unduly override the User's privacy interests;
• Consent: Processing for optional marketing communications, where the User has provided explicit and informed consent that may be withdrawn at any time.

04 Purposes of Processing

aah77 processes your personal data for the following purposes:

• Creating and administering your aah77 Account;
• Verifying your identity and age (21+) in compliance with PAGCOR requirements;
• Processing deposits, withdrawals, and payment transactions via GCash, Maya, and other supported Philippine payment methods;
• Providing access to the game library and delivering gaming services;
• Detecting and preventing fraud, money laundering, and unauthorized account access;
• Monitoring gaming activity for responsible gaming purposes, including identification of at-risk behavior patterns;
• Responding to customer support inquiries;
• Complying with PAGCOR reporting obligations and Philippine legal requirements;
• Sending transactional communications (account confirmations, withdrawal notifications, security alerts);
• Sending promotional communications where you have provided consent;
• Improving Platform performance and user experience through aggregated, anonymized analytics.

05 Data Sharing & Third Parties

aah77 shares personal data with third parties only where necessary and on a lawful basis. The categories of recipients are:

• Payment processors: GCash (G-Xchange Inc.), Maya (PayMaya Philippines Inc.), banks, and other payment service providers — to process your deposit and withdrawal transactions;
• KYC / Identity verification partners: Regulated third-party services that assist aah77 in verifying the identity and age of account holders in compliance with PAGCOR and AML requirements;
• Game software providers: Third-party game studios and platform providers (including JILI, Pragmatic Play, WM Live, and others) — limited to the technical data necessary to deliver their games through the aah77 Platform;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies — where disclosure is required by law or regulatory directive;
• IT and infrastructure service providers: Cloud hosting, security monitoring, and technical support vendors operating under data processing agreements that bind them to confidentiality and Philippine data privacy standards.

aah77 does not transfer personal data to any third party for the third party's own commercial purposes. All third-party data processors are contractually bound to process your data only on aah77's documented instructions and in accordance with applicable Philippine privacy law.

06 Data Retention

aah77 retains personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by Philippine law. Key retention periods are:

Following the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification. Requests for early deletion are addressed in Section 9 (Your Rights).

07 Data Security

aah77 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, loss, destruction, or disclosure. These measures include:

• TLS 1.3 encryption for all data in transit between your device and aah77's servers;
• AES-256 encryption for sensitive data at rest in aah77's databases;
• Multi-factor authentication requirements for all aah77 internal administrative systems;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security vulnerability assessments and penetration testing conducted by independent third-party security firms;
• Intrusion detection and prevention systems monitoring for anomalous access patterns;
• Employee data privacy training conducted regularly under the supervision of the aah77 DPO.

08 Cookies & Tracking Technologies

aah77 uses cookies and similar tracking technologies on aah77.org for the following purposes:

• Strictly necessary cookies: Required for core Platform functionality — maintaining your logged-in session, remembering language preferences, and enabling secure authenticated access. These cannot be disabled without impairing Platform functionality;
• Functional cookies: Remember your Platform preferences (e.g., game lobby view settings, notification preferences) to personalize your experience;
• Analytics cookies: Collect anonymized usage data to help aah77 understand how the Platform is used and identify technical issues. These are used internally and are not shared with advertising networks;
• Security cookies: Help detect fraudulent behavior and protect account security by maintaining session integrity tokens.

aah77 does not use third-party advertising or retargeting cookies. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from maintaining a logged-in session on aah77.org.

09 Your Data Subject Rights

Under Philippine Republic Act No. 10173, you have the following rights with respect to your personal data processed by aah77:

• Right to be informed: The right to know what personal data aah77 holds about you, the purposes for which it is processed, and how it is protected — as provided in this Privacy Policy;
• Right of access: The right to request a copy of the personal data aah77 holds about you, including the basis for processing and recipients of your data;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. For account information, many corrections can be made directly through your aah77 Account settings;
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected — subject to aah77's legal obligations to retain certain records under PAGCOR and AML regulations;
• Right to object: The right to object to certain processing activities, including direct marketing communications;
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible and where processing is based on consent or contract;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe aah77 has breached its obligations under RA 10173.

To exercise any of the above rights, contact the aah77 Data Protection Officer as detailed in Section 14. aah77 will respond to verified data subject requests within 15 business days in accordance with NPC guidelines. Identity verification may be required before processing your request.

10 Minors & Age Restriction

If aah77 discovers that personal data has been collected from an individual who is under 21 years of age, that data will be promptly deleted and the associated Account closed. Parents or guardians who believe a minor may have accessed aah77 are urged to contact the aah77 DPO immediately for account review and data deletion.

aah77 employs age verification procedures during account registration and KYC to prevent minors from accessing the Platform. Documentary proof of age (Philippine government-issued ID) is required for all accounts prior to withdrawal processing.

11 Cross-Border Data Transfers

Some of aah77's service providers and game software partners are located outside the Philippines. Where personal data is transferred to recipients in other countries, aah77 ensures that such transfers are conducted with appropriate safeguards as required by RA 10173, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under RA 10173;
• Transfers only to jurisdictions with adequate data protection frameworks recognized as comparable to Philippine standards;
• Where required, registration of such transfers with the National Privacy Commission.

aah77's primary data processing infrastructure is located within the Asia-Pacific region. All cross-border transfers are documented and subject to regular review by the aah77 Data Protection Officer.

12 Marketing Communications

aah77 may send you promotional communications about bonuses, new games, seasonal offers, and other aah77 features via SMS, email, or in-Platform notifications — but only where you have provided explicit consent during registration or account settings.

You may withdraw your consent to marketing communications at any time by:

• Updating your notification preferences in your aah77 Account settings;
• Clicking the unsubscribe link in any marketing email from aah77;
• Contacting the aah77 DPO or customer support.

Withdrawal of marketing consent does not affect your ability to receive transactional and account-related communications (such as deposit confirmations, withdrawal notifications, and security alerts), which are sent regardless of marketing preference as they are necessary for Platform operation.

13 Changes to This Privacy Policy

aah77 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable Philippine law, or PAGCOR requirements. Material changes will be communicated to registered Users via the email address or mobile number on file, or by prominent notice on the aah77 Platform, at least 7 days prior to the effective date of the change.

The effective date and version number at the top of this Policy indicate when it was last updated. Your continued use of the aah77 Platform following the effective date of any change constitutes your acknowledgment of the updated Privacy Policy. We encourage you to review this page periodically.

14 Contact & Data Protection Officer

For all privacy-related inquiries, data subject requests, or to contact the aah77 Data Protection Officer, please reach out through the following channels:

aah77 will acknowledge receipt of your request within 3 business days and respond substantively within 15 business days of identity verification. Complex requests may require additional time, in which case you will be notified of the extended timeline.

If you are not satisfied with aah77's response to your privacy request, you have the right to escalate your concern to the National Privacy Commission of the Philippines, which may be reached through official NPC channels.