Privacy Policy —
aryonplay

For the purposes of Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, aryonplay — the online gaming platform accessible at aryonplay.net — is the Personal Information Controller (PIC) in respect of all personal data collected from users of the platform.

aryonplay operates under a valid license issued by the Philippine Amusement and Gaming Corporation (PAGCOR). In that capacity, aryonplay is subject to both PAGCOR's data handling requirements and the data privacy obligations imposed by the National Privacy Commission (NPC) of the Philippines.

As the Personal Information Controller, aryonplay is responsible for determining the purposes and means of processing the personal data it collects from registered players, website visitors, and other data subjects. aryonplay has designated a Data Protection Officer (DPO) whose contact details are set out in Section 15 of this Policy.

This Privacy Policy applies to all personal data collected, processed, stored, or disclosed by aryonplay in connection with:

• Registration for and maintenance of an aryonplay account
• Use of any game, betting product, or other service available on aryonplay.net
• Deposits and withdrawals made via GCash, PayMaya, Philippine bank transfers, or any other accepted payment channel
• Communications between you and aryonplay's customer support team
• Participation in any aryonplay promotion, bonus, or loyalty program
• Browsing aryonplay.net without registering an account

This Policy does not apply to the data practices of third-party game providers, payment processors, or other service providers who maintain their own privacy policies. aryonplay is not responsible for the privacy practices of any third-party operator whose content or services are accessible through the aryonplay platform.

aryonplay collects personal data through multiple channels. The categories of personal data collected and the source of each are described in the table below:

Under the Data Privacy Act, certain categories of information are classified as Sensitive Personal Information (SPI) and are subject to heightened protection. aryonplay processes the following SPI categories where required for regulatory compliance:

• Government identification numbers (e.g., PhilSys number, SSS number, UMID number) — collected for KYC and AML compliance
• Financial account details (GCash, PayMaya, bank account numbers) — collected for payment processing and withdrawal verification

aryonplay does not collect health, biometric, religious, political, or other SPI categories except where strictly required by PAGCOR regulations and with appropriate safeguards in place.

aryonplay uses your personal data for the following purposes:

• Account Creation and Management: To register your aryonplay account, verify your identity, maintain your account, and communicate with you about account-related matters.
• Service Delivery: To provide access to casino games, live dealer tables, sports betting markets, and all other features of the aryonplay platform.
• Payment Processing: To process deposits via GCash, PayMaya, and Philippine banks, verify withdrawal requests, and prevent payment fraud.
• KYC and Regulatory Compliance: To verify your identity and age (minimum 21 years as required by PAGCOR), comply with Anti-Money Laundering Council (AMLC) reporting obligations, and fulfil PAGCOR's know-your-customer requirements.
• Responsible Gaming: To implement deposit limits, session timers, self-exclusion, and other responsible gaming controls on your account as required by PAGCOR's responsible gaming framework.
• Platform Security: To detect, investigate, and prevent fraud, account takeovers, collusion, bonus abuse, and other activities that violate the aryonplay Terms & Conditions.
• Customer Support: To respond to your inquiries, process complaints, and provide assistance through live chat, email, and other support channels.
• Analytics and Improvement: To analyse platform usage, identify technical issues, improve game offerings, and develop new platform features using aggregated and anonymised data where possible.
• Marketing Communications: To send you information about aryonplay promotions, bonuses, and new game releases, where you have provided consent or where we have a legitimate interest, subject to your right to opt out at any time (see Section 11).
• Legal Compliance: To comply with applicable Philippine laws, respond to regulatory enquiries, and cooperate with law enforcement and government authorities where required.

Under the Data Privacy Act of 2012, aryonplay processes your personal data on the following legal bases:

• Contract Performance: Processing your identity, contact, financial, and gaming activity data is necessary to provide the aryonplay platform services you have contracted for by creating an account and agreeing to the Terms & Conditions.
• Legal Obligation: Processing your KYC documents, transaction records, and related financial data is required to comply with PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and NPC requirements.
• Legitimate Interest: Processing technical and analytical data to improve platform security, detect fraud, and enhance user experience serves aryonplay's legitimate interests, balanced against your right to privacy.
• Consent: Where no other legal basis applies — such as sending promotional marketing communications beyond transactional messages — aryonplay will obtain your explicit consent before processing and will respect your right to withdraw that consent at any time.

aryonplay uses cookies and similar tracking technologies on aryonplay.net to ensure the platform functions correctly and to improve your experience. A cookie is a small text file stored on your device when you visit a website.

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies, load-balancing cookies, and security tokens. These cannot be disabled.
• Functional Cookies: Enable the platform to remember your preferences, such as your language settings and whether you have chosen to keep your account logged in on a trusted device.
• Analytics Cookies: Used to collect aggregated, anonymised information about how visitors use aryonplay.net, including pages visited, session duration, and error events. This data is used to improve the platform.
• Security Cookies: Used to detect suspicious activity, including multiple failed login attempts, and to flag potentially fraudulent account behaviour for investigation.

You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies may impair your ability to log in to your aryonplay account or access certain platform features. aryonplay does not use third-party advertising cookies or cross-site tracking technologies.

aryonplay does not sell, rent, or trade your personal data to third parties for commercial or marketing purposes. Your personal data is shared only in the following circumstances:

• PAGCOR and Regulatory Authorities: aryonplay is legally required to share player data — including identity information, transaction records, and gaming activity logs — with PAGCOR upon request as part of its licensing obligations.
• Anti-Money Laundering Council (AMLC): aryonplay is required to report covered transactions and suspicious transactions to the AMLC as defined under the Anti-Money Laundering Act (RA 9160, as amended). This includes transactions that meet AMLC thresholds or that exhibit characteristics indicative of money laundering.
• Payment Service Providers: aryonplay shares financial data with GCash, PayMaya, and Philippine banks (BPI, BDO, Metrobank, UnionBank) solely for the purpose of processing deposits and withdrawals. Each provider operates under its own privacy policy and applicable BSP regulations.
• KYC Verification Partners: aryonplay may engage third-party identity verification service providers to assist with KYC processing. These providers are bound by confidentiality obligations and may only use your data for the specified verification purpose.
• Game Content Providers: Game providers whose titles appear on the aryonplay platform may receive aggregated, anonymised game session data for performance analysis and game improvement purposes. Individually identifiable player data is not shared with game providers.
• Law Enforcement and Courts: aryonplay will disclose personal data to law enforcement agencies, courts, or other government authorities where required by a valid legal process, court order, or applicable Philippine law.

In all cases of data sharing, aryonplay applies appropriate safeguards to ensure that your personal data is protected and that recipients use it only for the stated purpose.

aryonplay implements a layered security framework to protect your personal data from unauthorised access, disclosure, alteration, and destruction. The technical and organisational security measures in place include:

• 256-bit SSL/TLS Encryption: All data transmitted between your browser or device and the aryonplay platform is encrypted using industry-standard SSL/TLS protocols.
• Encrypted Data Storage: Personal data and financial records stored on aryonplay's servers are encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to aryonplay personnel who require it for their specific job functions. Role-based access controls and multi-factor authentication are applied to all internal systems containing player data.
• Intrusion Detection and Prevention: aryonplay's infrastructure includes real-time intrusion detection systems (IDS), automated anomaly alerts, and regular penetration testing conducted by independent cybersecurity professionals.
• Payment Card Industry (PCI) Standards: Financial transaction data is processed in accordance with applicable PCI Data Security Standards.
• Staff Training: All aryonplay personnel who handle personal data receive regular data privacy and security training in line with NPC-recommended practices.

aryonplay retains your personal data for the minimum period necessary to fulfil the purposes described in this Policy, subject to mandatory minimum retention periods imposed by Philippine regulatory requirements:

At the end of the applicable retention period, aryonplay will securely delete or anonymise your personal data so that it can no longer be associated with you, unless a longer retention period is required by a court order or ongoing regulatory investigation.

Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights in respect of your personal data held by aryonplay:

To exercise any of the above rights, contact aryonplay's Data Protection Officer via the details in Section 15. aryonplay will respond to rights requests within 30 calendar days. In complex cases, this period may be extended by a further 30 days with notice to you.

aryonplay may send you marketing communications about promotions, new games, cashback offers, VIP program updates, and other platform news via SMS (to your registered Philippine mobile number) and email (to your registered address).

You may opt out of marketing communications at any time by:

• Adjusting your communication preferences in your aryonplay account settings under the "Notifications" section
• Contacting aryonplay customer support via live chat or email and requesting to be removed from marketing communications

Please note that even after opting out of marketing communications, aryonplay will continue to send you transactional and service communications that are necessary for the administration of your account — including deposit confirmations, withdrawal notifications, security alerts, and mandatory responsible gaming messages required by PAGCOR.

aryonplay will not share your mobile number or email address with any third party for the purpose of that third party sending marketing communications to you.

In the event that aryonplay discovers or has reason to believe that personal data belonging to a person under the age of 21 has been collected, aryonplay will:

• Immediately close and suspend the associated account
• Delete the personal data of the minor as soon as it is safe and legally permissible to do so
• Retain only such records as are required for regulatory and legal compliance purposes
• Notify PAGCOR as required under the licensing conditions

Parents or guardians who believe their child (under 21) has registered on aryonplay should contact support immediately using the details in Section 15. aryonplay takes age restriction seriously and cooperates fully with families and regulators in such cases.

In certain circumstances, aryonplay may transfer personal data to service providers or technical infrastructure located outside the Philippines — for example, cloud hosting providers, game server infrastructure, or KYC verification technology partners whose systems are hosted in other countries.

Where cross-border transfers occur, aryonplay ensures that such transfers are compliant with Section 21 of the Data Privacy Act, which requires that the receiving country or organisation provides a level of data protection that is at least equivalent to that required by Philippine law. Safeguards in place include:

• Data transfer agreements incorporating standard contractual clauses consistent with NPC guidelines
• Contractual requirements binding the receiving party to data protection obligations equivalent to those under the DPA
• Transfer to jurisdictions that have been assessed as providing adequate data protection, where applicable

aryonplay's primary data processing infrastructure is located within facilities that serve the Asian-Pacific region. All KYC data is processed in systems that comply with applicable Philippine regulatory requirements.

aryonplay reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, NPC guidance, or PAGCOR regulatory requirements. The most current version of this Policy will always be published at aryonplay.net/privacy-policy, with the "Last Updated" date at the top reflecting the date of the most recent revision.

Where changes to this Policy are material — meaning they significantly affect how aryonplay processes your personal data or your rights as a data subject — aryonplay will provide at least 7 days' prior notice to registered Players via the email address associated with their account before the updated Policy takes effect.

Continued use of the aryonplay platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of the updated terms. If you do not agree to the changes, you must cease using the platform and request account closure before the effective date.

If you have questions about this Privacy Policy, wish to exercise any of your rights under the Data Privacy Act, or wish to lodge a privacy complaint, please contact aryonplay's Data Protection Officer through the following channels:

• Email (DPO): [email protected] — subject line: "Privacy Request / DPO" (plain text — not a clickable link)
• Live Chat: Available 24/7 from within your aryonplay account dashboard — mention "Privacy Request" at the start of your chat

aryonplay will acknowledge all privacy-related requests within 24 hours and provide a substantive response within 30 calendar days.

If you are not satisfied with aryonplay's response to your privacy complaint, you have the right to escalate the complaint to the National Privacy Commission (NPC) of the Philippines. Information about the NPC complaint process is available on the NPC's official website.

For matters relating to gambling-related disputes, aryonplay's regulatory supervisor is PAGCOR. Complaints about aryonplay's conduct as a licensed operator can also be directed to PAGCOR through its official complaint channels.