aceoh Privacy Policy — How We Protect Your Personal Data

01 Introduction & Scope

This Privacy Policy ("Policy") is issued by aceoh ("aceoh", "we", "us", "our") and governs the collection, use, storage, disclosure, and protection of personal data provided by or collected from players, registered account holders, website visitors, and any other individuals ("you", "your", "Data Subject") who interact with the aceoh platform accessible at aceoh.net and any associated mobile or desktop applications.

aceoh is committed to protecting the privacy of all Filipino players and visitors in accordance with the Republic of the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC). This Policy reflects aceoh's obligations as a Personal Information Controller under Philippine law.

This Policy applies to all personal data processed in connection with the aceoh platform regardless of the device used to access the platform — whether desktop, mobile browser, or application — and regardless of the location of the player within the Philippines, including players in Manila, Cebu, Davao, Quezon City, Makati, and all other regions.

02 Data We Collect

aceoh collects the following categories of personal data in the course of operating the platform and providing services to registered players:

03 How We Collect Your Data

aceoh collects personal data through the following channels:

3.1 Directly from You

• When you create and register an aceoh account
• When you complete KYC verification and upload identification documents
• When you make a deposit or withdrawal via GCash, PayMaya, BPI, BDO, or Metrobank
• When you contact aceoh customer support via live chat or email
• When you set responsible gaming limits, cooling-off periods, or self-exclusion
• When you participate in promotions, surveys, or VIP program activities

3.2 Automatically via Platform Technology

• Session and activity logs generated during your use of the aceoh platform
• Cookies, local storage, and similar tracking technologies (see Section 7)
• Device fingerprinting data collected for fraud prevention and account security purposes
• Game event logs generated by the gaming engine during play sessions

3.3 From Third Parties

• Identity verification results from KYC service providers engaged by aceoh
• Payment confirmation data from GCash, PayMaya, and partner Philippine banks
• Fraud and risk scoring data from authorised anti-fraud service providers
• PAGCOR-mandated reporting feeds where required under gaming regulatory obligations

04 Legal Basis for Processing

Under the Philippine Data Privacy Act, aceoh processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to register your account, verify your identity, process your deposits and withdrawals, and deliver the gaming services you have contracted aceoh to provide.
• Legal Obligation: Processing required to comply with Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act itself. aceoh is legally required to collect and retain certain player data as a condition of its gaming operation.
• Legitimate Interests: Processing carried out for aceoh's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and the improvement of aceoh's products and services, where these interests are not overridden by your rights and interests.
• Consent: Where aceoh sends you direct marketing communications or optional promotional materials, this is done on the basis of your explicit consent, which you may withdraw at any time via your account notification settings.

05 How We Use Your Data

aceoh uses the personal data it collects for the following specific purposes:

• Registering and maintaining your aceoh player account
• Verifying your identity and age (21+ requirement) through the KYC process
• Processing PHP deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers
• Providing 24/7 customer support and resolving account or game-related disputes
• Monitoring gaming activity to detect problem gambling and enforce responsible gaming limits
• Detecting and preventing fraudulent activity, money laundering, and unauthorised account access
• Fulfilling PAGCOR regulatory reporting obligations and AMLA compliance requirements
• Sending transactional communications including deposit confirmations, withdrawal updates, and security alerts
• Sending promotional communications and bonus offers where you have consented to receive them
• Improving the aceoh platform, personalising the player experience, and developing new features
• Managing the aceoh Black Diamond VIP program, including tier assessments and personalised rewards

06 Data Sharing & Disclosure

aceoh does not sell your personal data. aceoh may share your personal data with the following categories of recipients, strictly for the purposes described in this Policy:

6.1 Service Providers

aceoh engages third-party service providers to support platform operations, including KYC and identity verification providers, payment processing partners (GCash, PayMaya, partner banks), game content providers, cloud hosting and infrastructure providers, and anti-fraud technology vendors. All service providers are bound by data processing agreements that prohibit use of your data for any purpose other than providing the contracted service to aceoh.

6.2 Regulatory Authorities

aceoh is legally required to disclose player data to the Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities upon lawful demand or as required by applicable law. aceoh will not disclose data to government authorities beyond what is legally required.

6.3 Legal Proceedings

aceoh may disclose personal data where required by a valid court order, subpoena, or other legally binding judicial or administrative process issued by a competent Philippine court or authority. aceoh will seek to notify you of such disclosures where legally permitted to do so.

07 Cookies & Tracking Technologies

aceoh uses cookies and similar tracking technologies on the aceoh.net platform. Cookies are small text files stored on your device that help aceoh recognise your browser, maintain your login session, remember your preferences, and analyse platform usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the aceoh platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your platform preferences such as language settings, display preferences, and responsible gaming reminders. Disabling these may reduce platform convenience but will not prevent access.
• Analytics Cookies: Used by aceoh's internal analytics tools to understand how players navigate the platform, which game categories are most popular, and where technical issues are occurring. Data is aggregated and anonymised before analysis.
• Security Cookies: Used for device fingerprinting and fraud detection purposes, helping aceoh identify suspicious login attempts or unusual account activity patterns that may indicate account compromise.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to use the aceoh platform. aceoh does not use third-party advertising cookies or cross-site tracking pixels for commercial advertising purposes.

08 Data Retention

aceoh retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following retention guidelines:

• Active Account Data: Retained for the full duration of your aceoh account's active status, plus a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AMLA obligations.
• KYC and Identity Documents: Retained for a minimum of five (5) years following the conclusion of the business relationship, in line with AMLA implementing regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years in compliance with AMLA and PAGCOR regulatory requirements. These records may be subject to mandatory disclosure to the AMLC.
• Customer Support Communications: Retained for a minimum of two (2) years following resolution of the relevant support interaction, for dispute resolution and quality assurance purposes.
• Marketing Consent Records: Retained for the duration of your marketing consent plus three (3) years, to demonstrate compliance with consent requirements.

09 Data Security

aceoh implements a multi-layered technical and organisational security framework to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Key security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and aceoh servers
• AES-256 encryption for sensitive personal data and financial information stored at rest
• Multi-factor authentication options for player accounts, with mandatory 2FA for withdrawal requests above defined thresholds
• Role-based access controls ensuring that aceoh staff can only access the player data required for their specific job function
• Regular penetration testing and security audits conducted by qualified cybersecurity professionals
• 24/7 automated intrusion detection systems monitoring the aceoh platform for anomalous activity
• Documented data breach response procedures aligned with NPC notification requirements

10 Your Rights 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 aceoh. To exercise any of these rights, contact aceoh customer support via the 24/7 live chat or by emailing [email protected]:

• Right to be Informed: You have the right to know what personal data aceoh holds about you, how it is being processed, and with whom it has been shared.
• Right to Access: You may request a copy of the personal data aceoh holds about you. aceoh will respond to access requests within thirty (30) days in accordance with NPC guidelines.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data held by aceoh. Certain corrections may require re-verification of your identity.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to aceoh's regulatory retention obligations under PAGCOR and AMLA requirements.
• Right to Object: You may object to processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, and aceoh will cease such processing unless there are compelling legitimate grounds that override your interests.
• Right to Data Portability: You may request that aceoh provide your personal data in a structured, commonly used, machine- readable format where technically feasible.
• Right to Damages: You have the right to be indemnified for any damages sustained as a result of a violation of your rights under the Philippine Data Privacy Act.
• Right to File a Complaint: If you believe aceoh has violated your rights under the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) at privacy.gov.ph.

11 Children & Minors

The aceoh platform is strictly for adults aged 21 years and above, in accordance with Philippine gaming regulations. aceoh does not knowingly collect personal data from individuals under the age of 21. The KYC verification process is designed to confirm that every registered aceoh account holder meets the 21+ age requirement before any gaming activity is permitted.

Parents and guardians who believe a minor has registered an aceoh account should contact aceoh customer support immediately via live chat or at [email protected] so that the account can be suspended and the matter resolved promptly.

12 Policy Amendments & Contact

aceoh reserves the right to amend this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC guidance, PAGCOR regulatory requirements, or aceoh's internal data practices. When material changes are made, aceoh will notify registered players via the email address on file and will update the "Last Updated" date at the top of this document. Continued use of the aceoh platform after the effective date of an amended Policy constitutes acceptance of the updated terms.

We encourage you to review this Privacy Policy periodically to remain informed about how aceoh is protecting your data. Archived versions of previous Privacy Policies are available upon request to aceoh customer support.

Contact aceoh's Data Protection Team

For all privacy-related inquiries, data subject rights requests, or to report a potential data privacy concern, please contact aceoh through the following channels:

• 24/7 Live Chat: Available directly on the aceoh platform — the fastest way to reach our team
• Email: [email protected] — mark your subject line "Data Privacy Request" for priority routing

aceoh will acknowledge all data privacy inquiries within seventy-two (72) hours and will endeavour to resolve all requests within thirty (30) days, consistent with NPC guidelines. Complex requests may require additional time, in which case aceoh will notify you of the extended timeline and the reasons for the delay.