acephp Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how acephp ("the Platform," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("you" or "your") who access or use the acephp website at acephp.app and all associated services, games, and features.

acephp is committed to protecting the privacy and personal data of all users, particularly Filipino players who entrust us with their information. This Policy is drafted in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

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

This Policy should be read together with the acephp Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, acephp is the Personal Information Controller (PIC) in respect of the personal data collected through the acephp platform. As PIC, acephp determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine privacy laws.

acephp has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. Contact details for the DPO are provided in Section 15 of this Policy.

3 Personal Data We Collect

acephp collects the following categories of personal data from users of the platform:

acephp does not intentionally collect sensitive personal information (as defined under RA 10173) beyond what is strictly necessary for regulatory compliance, such as government ID numbers required for KYC verification. We do not collect information about your race, religion, health, or political affiliations.

4 How We Collect Your Data

acephp collects personal data through the following means:

4.1 Directly from You. When you register for an acephp account, complete KYC verification, make a deposit or withdrawal, contact our support team, participate in promotions, or otherwise interact with the platform, you provide personal data directly to us.

4.2 Automatically. When you access the acephp platform, we automatically collect certain technical and usage data through cookies, web beacons, log files, and similar tracking technologies. This includes your IP address, device identifiers, browser information, and behavioral data about how you use the platform. Please refer to Section 10 for more information about our use of cookies.

4.3 From Third Parties. We may receive personal data about you from third parties in the following circumstances:

• Payment processors (GCash, Maya, Philippine banks) when you make transactions;
• Identity verification service providers during KYC checks;
• Fraud prevention and anti-money laundering screening services;
• PAGCOR and other regulatory authorities as required by law;
• Publicly available sources, such as sanctions lists and politically exposed persons (PEP) databases.

5 Legal Basis for Processing

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

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications from acephp;
• Contractual Necessity: Processing necessary for the performance of the contract between you and acephp, including operating your account, processing transactions, and providing gaming services;
• Legal Obligation: Processing necessary for acephp to comply with its legal obligations under Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act itself;
• Legitimate Interests: Processing necessary for acephp's legitimate business interests, such as fraud prevention, platform security, and improving our services, provided such interests are not overridden by your rights and freedoms.

6 How We Use Your Personal Data

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

• Account Management: Creating and maintaining your acephp account, verifying your identity and age, and managing your account settings and preferences;
• Service Delivery: Providing access to games, processing bets, crediting winnings, and delivering all features of the acephp platform;
• Financial Transactions: Processing deposits and withdrawals via GCash, Maya, and Philippine bank transfers; maintaining accurate financial records;
• Regulatory Compliance: Fulfilling our obligations under PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws, including filing required reports with regulatory authorities;
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, money laundering, and other illegal conduct; protecting the security and integrity of the platform;
• Responsible Gaming: Monitoring gaming behavior to identify signs of problem gambling; administering self-exclusion and limit-setting tools; complying with responsible gaming obligations under PAGCOR's framework;
• Customer Support: Responding to your inquiries, resolving disputes, and providing technical assistance;
• Communications: Sending you transactional notifications (account activity, deposit/withdrawal confirmations, security alerts) and, where you have consented, promotional communications about acephp offers and promotions;
• Platform Improvement: Analyzing usage patterns to improve the acephp platform, fix bugs, and develop new features;
• Legal Claims: Establishing, exercising, or defending legal claims involving acephp.

acephp will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

7 Sharing Your Personal Data

acephp does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

7.1 Regulatory Authorities. We are required by law to share certain personal data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies upon lawful request or as required by applicable regulations.

7.2 Payment Processors. We share financial data with payment service providers (GCash, Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) solely for the purpose of processing your deposits and withdrawals.

7.3 Identity Verification Providers. We engage third-party KYC and identity verification service providers to assist with age verification and fraud prevention. These providers process your identity documents and biometric data under strict contractual data processing agreements.

7.4 Technology Service Providers. We work with technology partners who provide hosting, cloud infrastructure, analytics, customer support software, and other platform services. These providers act as Personal Information Processors (PIPs) under the Data Privacy Act and are contractually bound to process your data only on our instructions and in accordance with applicable law.

7.5 Game Providers. Where acephp offers games developed by third-party game studios, limited gaming data may be shared with those studios for the purpose of operating the games and resolving technical disputes.

7.6 Legal and Professional Advisors. We may share personal data with our lawyers, auditors, and other professional advisors where necessary for the provision of their services, subject to professional confidentiality obligations.

7.7 Business Transfers. In the event of a merger, acquisition, or sale of all or part of acephp's business, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

8 Data Retention

acephp retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

Upon expiry of the applicable retention period, acephp will securely delete or anonymize your personal data in accordance with NPC guidelines. Where data is anonymized, it may be retained indefinitely for analytical purposes as it no longer constitutes personal data.

9 Data Security

acephp implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and acephp is protected by SSL/TLS encryption. Sensitive data at rest, including financial information and identity documents, is encrypted using industry-standard algorithms;
• Access Controls: Access to personal data is restricted to acephp personnel and authorized service providers who have a legitimate need to access it. All staff with access to personal data are subject to confidentiality obligations and regular data protection training;
• Two-Factor Authentication: acephp supports two-factor authentication (2FA) for user accounts to provide an additional layer of security against unauthorized access;
• Regular Security Audits: acephp conducts regular security assessments, penetration testing, and vulnerability scans to identify and address potential security weaknesses;
• Incident Response: acephp maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected users within the timeframes required by the Data Privacy Act.

While acephp takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the security of your acephp account credentials and for notifying us immediately if you suspect unauthorized access to your account.

10 Cookies & Tracking Technologies

acephp uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze usage patterns, and support security functions. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the platform to function. These include session cookies that keep you logged in and security cookies that prevent fraudulent use. These cannot be disabled without affecting platform functionality;
• Functional Cookies: Remember your preferences such as language settings, game preferences, and responsible gaming limits you have set;
• Analytics Cookies: Help us understand how users interact with the acephp platform so we can improve it. Data collected is aggregated and anonymized where possible;
• Security Cookies: Used for fraud detection, bot prevention, and platform integrity monitoring.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the acephp platform. For strictly necessary cookies, no consent is required as they are essential to the operation of the service you have requested.

11 Your Data Privacy Rights

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

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. acephp will respond to all verified data subject requests within thirty (30) calendar days of receipt, as required by the Data Privacy Act. If your request is complex or numerous, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reasons for it.

If you are not satisfied with acephp's response to your privacy request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

12 Minors & Age Verification

The acephp platform is strictly intended for adults aged 21 years and older, in accordance with Philippine law and PAGCOR regulations governing the minimum age for participation in casino-style gambling activities.

acephp does not knowingly collect personal data from individuals under the age of 21. As part of our registration and KYC process, we require all users to verify their age by providing a valid government-issued photo identification document. Where acephp discovers that personal data has been collected from a person under the age of 21, we will immediately suspend the relevant account, delete the personal data, and return any funds deposited to the payment source.

13 International Data Transfers

acephp primarily processes and stores personal data within the Republic of the Philippines. However, some of our technology service providers and game studio partners may be located in other countries, which may result in your personal data being transferred to and processed in jurisdictions outside the Philippines.

Where such international transfers occur, acephp ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to provide a level of data protection equivalent to that required under the Data Privacy Act of 2012. acephp will not transfer your personal data to a country that does not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

14 Amendments to This Policy

acephp reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify registered users by email or via a prominent notice on the acephp platform, and we will update the "Last Updated" date at the top of this page.

Your continued use of the acephp platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy. We encourage you to review this Policy periodically. The most current version will always be available at acephp.app/privacy-policy.

15 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by acephp, please contact our Data Protection Officer:

For complaints about acephp's handling of your personal data that remain unresolved after contacting our DPO, you may file a complaint with the National Privacy Commission (NPC) of the Philippines.