Privacy Policy

1. Introduction

ace291 ("we", "us", or "the Company") operates the online casino platform accessible at https://ace291.app (the "Platform"). We are committed to protecting the privacy and personal data of every player and visitor who interacts with the ace291 Platform.

This Privacy Policy ("Policy") describes how ace291 collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform. It also explains the rights available to you under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

By registering for an ace291 account or using any part of the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform immediately.

This Policy should be read together with the ace291 Terms & Conditions, which govern your overall use of the Platform.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, ace291 is the Personal Information Controller in respect of the personal data collected through the Platform. This means ace291 determines the purposes and means of processing your personal information.

ace291 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data protection laws and for handling data subject requests and complaints. You may contact the DPO using the contact details provided in Section 14 of this Policy.

3. Data We Collect

ace291 collects personal data from you in the following categories:

• Registration Data: Full legal name, date of birth, gender, nationality, residential address (including city – e.g., Manila, Cebu, Davao, Quezon City, Makati), email address, and Philippine mobile number provided when you create your ace291 account.
• Identity Verification (KYC) Data: Government-issued photo identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence), proof of address documents, and selfie photographs submitted for Know Your Customer verification as required by Philippine anti-money laundering regulations.
• Financial Data: GCash account details, Maya (PayMaya) account details, Philippine bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), debit card details, transaction history, deposit and withdrawal records, and account balance information.
• Gaming Activity Data: Game session logs, bet history, win/loss records, bonus usage, and responsible gaming tool settings (deposit limits, session limits, self-exclusion status).
• Technical Data: IP address, device type and model, operating system, browser type and version, screen resolution, time zone, and unique device identifiers collected automatically when you access the Platform.
• Usage Data: Pages visited, features used, click-stream data, session duration, and navigation patterns collected through cookies and analytics tools.
• Communications Data: Records of your correspondence with ace291 customer support, including live chat transcripts, email exchanges, and support ticket history.
• Marketing Preferences: Your opt-in or opt-out status for promotional emails, SMS notifications, and push notifications from ace291.

ace291 collects only the minimum personal data necessary for the purposes described in this Policy. We do not collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for regulatory compliance.

4. How We Use Your Data

ace291 uses the personal data we collect for the following purposes:

• Account Management: To create, verify, maintain, and administer your ace291 player account, including processing your registration, verifying your identity, and managing your account settings.
• Service Delivery: To provide you with access to the ace291 Platform, process your deposits and withdrawals in Philippine Peso (₱), credit bonuses to your account, and deliver the gaming services you have requested.
• Regulatory Compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML) and counter-terrorism financing (CTF) regulations, PAGCOR licensing requirements, and the Data Privacy Act of 2012. This includes conducting KYC verification and filing mandatory reports with relevant Philippine authorities.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, account takeovers, money laundering, and other illegal or prohibited activities on the Platform.
• Responsible Gaming: To monitor gaming behaviour for signs of problem gambling, enforce responsible gaming limits set by players, and administer self-exclusion requests in accordance with our Responsible Gaming policy.
• Customer Support: To respond to your enquiries, resolve complaints, and provide technical assistance through our support channels.
• Platform Improvement: To analyse usage patterns, conduct A/B testing, and improve the features, performance, and user experience of the ace291 Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and news about ace291 – but only where you have given your explicit consent to receive such communications. You may withdraw this consent at any time.
• Legal Proceedings: To establish, exercise, or defend legal claims in connection with the ace291 Platform or your use thereof.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, ace291 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and ace291 (i.e., the Terms & Conditions) – for example, to create your account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with ace291's legal obligations under Philippine law, including AML/CTF regulations and PAGCOR licensing requirements.
• Legitimate Interests: Processing is necessary for ace291's legitimate interests in operating a secure, fair, and commercially viable gaming platform – for example, fraud detection, platform analytics, and responsible gaming monitoring – provided these interests are not overridden by your rights and interests.
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6. Sharing Your Data

ace291 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, Maya (PayMaya), and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals.
• KYC & Identity Verification Providers: Third-party identity verification services engaged by ace291 to conduct KYC checks as required by Philippine AML regulations.
• Game Software Providers: Licensed game studios and software providers whose games are available on the ace291 Platform, to the extent necessary to deliver game services and resolve disputes.
• IT & Hosting Providers: Cloud hosting, data storage, and cybersecurity service providers engaged by ace291 to operate and secure the Platform infrastructure.
• Regulatory & Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where disclosure is required by law or regulatory directive.
• Professional Advisers: Lawyers, auditors, and accountants engaged by ace291 in connection with legal proceedings, regulatory compliance, or corporate transactions, subject to professional confidentiality obligations.

All third parties with whom ace291 shares personal data are required to process that data in accordance with applicable Philippine data protection law and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

7. Data Retention

ace291 retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC Data: Retained for a minimum of 5 years from the date of account closure, as required by Philippine AML regulations and PAGCOR licensing conditions.
• Financial Transaction Records: Retained for a minimum of 5 years from the date of each transaction, in compliance with the Anti-Money Laundering Act of 2001 (as amended) and its implementing regulations.
• Gaming Activity Logs: Retained for a minimum of 3 years from the date of each gaming session, for dispute resolution and regulatory audit purposes.
• Customer Support Records: Retained for 3 years from the date of the last interaction, to support ongoing customer service and complaint resolution.
• Marketing Consent Records: Retained for the duration of your marketing consent plus 3 years thereafter, to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, ace291 will securely delete or anonymise your personal data in accordance with our internal data disposal procedures. Where data is anonymised rather than deleted, the anonymised data may be retained indefinitely for statistical and analytical purposes.

8. Cookies & Tracking Technologies

ace291 uses cookies and similar tracking technologies (including web beacons and local storage) on the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These cookies enable core features such as user authentication, session management, and security. They cannot be disabled without impairing Platform functionality.
• Performance & Analytics Cookies: Used to collect anonymised information about how players use the Platform – for example, which pages are visited most frequently and whether error messages are received. This data helps ace291 improve Platform performance and user experience.
• Functional Cookies: Used to remember your preferences and personalise your experience on the Platform, such as your preferred language, display settings, and responsible gaming limit configurations.
• Marketing Cookies: Used only with your explicit consent to deliver relevant promotional content and measure the effectiveness of ace291's marketing campaigns. These cookies may track your activity across sessions.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the ace291 Platform. For detailed information on the specific cookies used by ace291, please refer to our Cookie Notice available within the Platform settings.

9. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ace291:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed – which this Policy fulfils.
• Right of Access: The right to request a copy of the personal data ace291 holds about you, together with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data ace291 holds about you. You may update most of your account information directly through your ace291 account settings.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ace291's legal obligations to retain certain data (see Section 7).
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on ace291's legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe ace291 has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact ace291's Data Protection Officer using the contact details in Section 14. ace291 will respond to all verified data subject requests within 30 calendar days of receipt. We may request proof of identity before processing your request to protect against unauthorised access to your data.

10. Data Security

ace291 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and the ace291 Platform is encrypted using 256-bit SSL/TLS protocols. Sensitive data stored in our databases is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data is restricted to ace291 personnel and authorised third parties who have a legitimate need to access it. All staff with access to personal data are subject to confidentiality obligations and receive regular data protection training.
• Firewalls & Intrusion Detection: The ace291 Platform infrastructure is protected by enterprise-grade firewalls and real-time intrusion detection and prevention systems.
• Regular Security Audits: ace291 conducts regular internal and third-party security audits and penetration tests to identify and remediate vulnerabilities in the Platform.
• Incident Response: ace291 maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, ace291 will notify the National Privacy Commission and affected players within the timeframes required by the Data Privacy Act of 2012.

While ace291 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your ace291 login credentials and for ensuring that your device is adequately secured.

11. Children's Privacy

The ace291 Platform is strictly intended for adults aged 21 years and older in accordance with Philippine law applicable to casino-style gambling. ace291 does not knowingly collect personal data from any person under the age of 21.

If ace291 becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the ace291 Platform, please contact us immediately using the details in Section 14.

Parents and guardians are encouraged to use parental control software to prevent minors from accessing online gambling platforms. ace291 supports the responsible gaming principle that gambling is an adult activity and must never be accessible to persons under the legal age.

12. Third-Party Links

The ace291 Platform may contain references to third-party services such as payment processors (GCash, Maya) and game software providers. While ace291 takes care to work only with reputable partners, we are not responsible for the privacy practices of third-party websites or services that are not operated by ace291.

We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of ace291. This Policy applies solely to personal data collected and processed by ace291 through the Platform.

13. Changes to This Privacy Policy

ace291 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When material changes are made, ace291 will notify registered players via email or an in-platform notification at least 7 days before the changes take effect.

The most current version of this Policy will always be available on this page, with the "Last Updated" date at the top reflecting the date of the most recent revision. Your continued use of the ace291 Platform after the effective date of any amendment constitutes your acknowledgement of the updated Policy. If you do not agree with the revised Policy, you must cease using the Platform and may request account closure.

14. Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or ace291's data processing practices, or if you wish to exercise any of your data subject rights, please contact our Data Protection Officer:

Data Protection Officer – ace291
Email: [email protected]

ace291 aims to acknowledge all privacy-related enquiries within 5 business days and to resolve complaints within 30 calendar days of receipt. If you are not satisfied with ace291's response to your complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.

For general customer support enquiries unrelated to data privacy, please contact: [email protected]