aoe6mm Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how aoe6mm ("we", "us", "our"), the operator of the online gambling platform available at aoe6mm.club, collects, uses, discloses, retains, and protects the personal information of users ("you", "your", "Player") who access or use the aoe6mm Platform.

aoe6mm is committed to protecting the privacy and personal data of all Filipino players who use the Platform. This Policy is published in compliance with Republic Act 10173, known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and relevant issuances of the National Privacy Commission (NPC) of the Philippines.

By creating an account on the aoe6mm Platform, you acknowledge that you have read, understood, and consented to the collection and processing of your personal data as described in this Policy. If you do not agree to this Policy, do not create an account or use the Platform.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, the personal information controller (PIC) responsible for your data is the operator of the aoe6mm Platform, a PAGCOR-licensed entity operating the online gambling services available at aoe6mm.club.

Inquiries regarding the processing of your personal data, including the exercise of your data subject rights, should be directed to the aoe6mm Data Privacy Officer (DPO) at the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

aoe6mm collects the following categories of personal data in connection with your use of the Platform:

3.1 Identity and Registration Data

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification – 21+ requirement)
• Gender
• Current residential address in the Philippines
• Philippine mobile number
• Email address
• Username and encrypted account password

3.2 Identity Verification (KYC) Data

• Copy or image of a valid Philippine government-issued photo ID (e.g., UMID, SSS ID, PhilHealth ID, Passport, Driver's Licence, Voter's ID, PRC ID)
• Proof of address documents (e.g., utility bill, bank statement, barangay certificate)
• Source-of-funds documentation where applicable under PAGCOR or AMLA requirements
• Selfie or liveness verification image for identity matching purposes

3.3 Financial and Transaction Data

• GCash account number or registered mobile number associated with GCash
• PayMaya account details
• Bank account details for BPI, BDO, Metrobank, or UnionBank transfers
• Transaction history including deposit amounts, withdrawal amounts, dates, and payment method references
• Bet history, wagering records, and game session data
• Wallet balance history

3.4 Technical and Device Data

• IP address at the time of login and transactions
• Device type, operating system, and browser type
• Session duration and login timestamps
• Geolocation data (city and region level, derived from IP)
• Cookies and similar tracking technologies (see Section 9)

3.5 Communications Data

• Records of live chat conversations with aoe6mm support
• Email correspondence with the aoe6mm support team
• Complaint and dispute records
• Responses to optional surveys or feedback requests

4. How We Collect Your Data

aoe6mm collects personal data through the following channels:

• Directly from you – when you register an account, complete KYC verification, make deposits or withdrawals, contact support, or respond to surveys.
• Automatically – when you use the Platform, technical data including IP address, device information, session logs, and cookie data is collected automatically by our servers and analytics systems.
• From payment providers – GCash, PayMaya, and bank partners may share transaction confirmation data and account holder verification information necessary to process deposits and withdrawals.
• From identity verification services – third-party KYC processors may provide identity match results and document authenticity assessments in connection with your KYC submission.
• From regulatory authorities – PAGCOR and law enforcement agencies may provide or request data in connection with licensing compliance, anti-money laundering obligations, or investigations.

5. Purposes of Processing and Legal Basis

aoe6mm processes your personal data for the following purposes. Each processing activity is grounded in at least one lawful basis under RA 10173:

6. Data Sharing and Disclosure

aoe6mm does not sell, rent, or trade your personal data to third-party advertisers, data brokers, or any entity for commercial purposes unrelated to the provision of the Platform's services. Data is shared with third parties only in the following circumstances:

6.1 Service Providers and Processors

aoe6mm engages third-party processors to operate specific Platform functions. These include:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and cryptocurrency processing partners receive the financial data necessary to process your transactions.
• KYC verification services: Third-party identity verification providers receive your submitted ID documents and personal details solely for the purpose of verifying your identity.
• Game content providers: Providers such as JILI, PG Soft, and Pragmatic Play receive session identifiers and wallet balance data necessary to operate game rounds. They do not receive your full identity data.
• IT infrastructure and hosting providers: Cloud infrastructure partners who store Platform data under contractual data processing agreements are subject to equivalent data protection obligations.

6.2 Regulatory and Legal Disclosure

aoe6mm is required by Philippine law to disclose personal data to the following authorities when lawfully directed to do so:

• PAGCOR – in connection with licensing audits, compliance reviews, and player complaint investigations
• Anti-Money Laundering Council (AMLC) – for suspicious transaction reporting under RA 9160
• National Privacy Commission (NPC) – in connection with data privacy investigations or breach notifications
• Philippine courts and law enforcement agencies – pursuant to valid court orders, subpoenas, or lawful requests
• Bureau of Internal Revenue (BIR) – for tax reporting obligations

6.3 Corporate Transactions

In the event of a merger, acquisition, business transfer, or sale of all or part of aoe6mm's operations, player data may be transferred to the acquiring entity. You will be notified of any such transfer and the applicable privacy terms of the acquiring entity before the transfer takes effect.

7. Data Retention Periods

aoe6mm retains personal data only for as long as is necessary for the purposes set out in this Policy, taking into account applicable legal, regulatory, and operational requirements:

Upon expiry of the applicable retention period, personal data is permanently deleted from aoe6mm's systems or irreversibly anonymised so that it can no longer be linked to an identifiable individual. Anonymised or aggregated data may be retained indefinitely for statistical analysis and Platform improvement purposes.

8. Data Security Measures

aoe6mm implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• Encryption in transit: All data transmitted between your device and the aoe6mm Platform is encrypted using TLS 1.2 or higher (256-bit SSL).
• Encryption at rest: Sensitive personal data stored on aoe6mm servers, including KYC documents and financial records, is encrypted at rest using industry-standard AES-256 encryption.
• Access controls: Access to personal data is restricted to authorised aoe6mm personnel and processors who require it for defined operational purposes. Role-based access controls and multi-factor authentication are enforced for all internal systems.
• Penetration testing and vulnerability assessments: aoe6mm conducts regular third-party security assessments to identify and remediate vulnerabilities in the Platform infrastructure.
• Audit logging: All access to sensitive personal data by internal systems and personnel is logged and reviewed periodically.
• Two-factor authentication (2FA): Players are encouraged and supported in enabling 2FA on their accounts to protect against unauthorised login.

9. Cookies and Tracking Technologies

The aoe6mm Platform uses cookies and similar tracking technologies to operate essential Platform functions, analyse usage patterns, and improve user experience. The following types of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These include session cookies that maintain your logged-in state, security tokens, and load-balancing cookies. These cannot be disabled without preventing Platform functionality.
• Functional cookies: Remember your preferences such as language settings, game display preferences, and recent activity to personalise your experience.
• Analytics cookies: Collect anonymised data about how players use the Platform – pages visited, session duration, error events – to help us improve the Platform. Data collected is aggregated and does not identify individual users.
• Security cookies: Used to detect and prevent fraudulent access, bot activity, and suspicious login patterns.

aoe6mm does not use third-party advertising cookies or allow third-party advertisers to set cookies through the Platform. You may adjust your browser settings to block or delete cookies; however, doing so may affect the functionality of the aoe6mm Platform. For session-critical functionality, strictly necessary cookies must remain enabled.

10. Minors and Age Restrictions

The aoe6mm Platform is strictly restricted to individuals who are 21 years of age or older. This is a mandatory requirement under PAGCOR licensing conditions for all online gambling platforms in the Philippines. aoe6mm does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from an individual who does not meet the minimum age requirement, we will immediately suspend the associated account, delete the personal data collected in connection with that account, and refer the matter to PAGCOR as required. Any funds deposited by an underage user will be handled in accordance with PAGCOR's directives on unlawful account activity.

If you are aware of a minor who has created or is attempting to create an aoe6mm account, please notify us immediately at [email protected].

11. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in respect of your personal data held by aoe6mm. These rights may be exercised by submitting a written request to the aoe6mm Data Privacy Officer at [email protected]:

• Right to Access You have the right to request a copy of the personal data aoe6mm holds about you, together with information about how it is processed, the legal basis for processing, retention periods, and any third parties with whom it has been shared.
• Right to Correction You have the right to request correction of any inaccurate, incomplete, or outdated personal data we hold about you. Where feasible, corrections will be made within a reasonable timeframe.
• Right to Erasure You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (and no other legal basis applies), or where processing is unlawful. This right is subject to overriding legal retention obligations such as AMLA and PAGCOR requirements.
• Right to Object You have the right to object to the processing of your personal data for marketing purposes at any time. You may also object to processing based on legitimate interests, subject to aoe6mm's ability to demonstrate compelling legitimate grounds.
• Right to Block or Restrict Processing You have the right to request that aoe6mm restrict the processing of your personal data in defined circumstances, such as where you contest accuracy or where you have objected to processing pending a determination of overriding legitimate grounds.
• Right to Data Portability Where processing is based on your consent or the performance of a contract and is carried out by automated means, you may request that your personal data be provided to you in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint If you believe that aoe6mm has processed your personal data in a manner inconsistent with RA 10173, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through its official complaint procedures.

aoe6mm will respond to all data subject rights requests within thirty (30) days of receipt. Where a request is complex or voluminous, we may extend this period by a further two months with written notice and explanation provided to you within the initial 30-day window.

12. Cross-Border Data Transfers

aoe6mm's primary data storage and processing infrastructure is located within the Philippines. In certain circumstances, personal data may be transferred to or accessed from servers or processors located outside the Philippines – for example, where global cloud infrastructure providers or international game content providers are used.

Any cross-border transfer of personal data is conducted in accordance with the requirements of RA 10173 and NPC regulations on cross-border data transfers. This includes ensuring that the recipient country or organisation provides an adequate level of data protection, or that appropriate safeguards are in place through contractual data processing agreements incorporating standard data protection clauses.

13. Data Breach Notification

In the event of a personal data breach that is likely to result in a real risk of harm to affected data subjects, aoe6mm will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, as required by RA 10173 and NPC Circular 16-03.

Where a breach poses a high risk to the rights and freedoms of affected players, aoe6mm will also notify the affected individuals without undue delay. Breach notifications will include the nature of the breach, the categories and approximate number of individuals affected, the likely consequences, and the measures taken or proposed to address the breach and mitigate its possible adverse effects.

14. Changes to This Privacy Policy

aoe6mm reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. Material changes to this Policy will be communicated to registered players via email notification or a prominent in-platform notice at least seven (7) calendar days before the updated Policy takes effect.

Continued use of the aoe6mm Platform after the effective date of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to the updated Policy, you must stop using the Platform and may request closure of your account.

The effective date and last updated date at the top of this Policy reflect the date of the most recent version. Previous versions of this Policy are available upon written request to [email protected].

15. Contact the Data Privacy Officer

For any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by aoe6mm, please contact the aoe6mm Data Privacy Officer: