Privacy Policy

1. Information We Collect

1.1 Personal Information You Provide

When you register an account on ace21, we collect personal information that you voluntarily provide to us. This information is necessary to create and maintain your account, verify your identity, process transactions, and comply with legal and regulatory requirements. The personal information we collect includes:

• Identity Information: Full legal name, date of birth, gender, nationality, and government-issued identification documents (such as passport, driver's license, or Philippine national ID)
• Contact Information: Email address, mobile telephone number, residential address, and postal code
• Financial Information: Payment method details including GCash account information, PayMaya account information, bank account details, and transaction history
• Account Credentials: Username, password (stored in encrypted form), and security questions and answers
• Verification Documents: Copies of identification documents, proof of address documents, and proof of payment method ownership
• Communication Records: Records of correspondence with customer support, including live chat transcripts, emails, and phone call recordings

1.2 Information Collected Automatically

When you access and use the ace21 Platform, we automatically collect certain technical and usage information through cookies, web beacons, and similar tracking technologies. This information helps us understand how you interact with our Platform, improve our services, detect fraud, and enhance security. Automatically collected information includes:

• Device Information: Device type, operating system, browser type and version, screen resolution, and device identifiers
• Connection Information: IP address, internet service provider, geographical location (country, city, region), and connection timestamps
• Usage Data: Pages visited, games played, time spent on Platform, clickstream data, referring and exit pages, and navigation patterns
• Gaming Activity: Bet amounts, game selections, win/loss records, deposit and withdrawal history, and bonus usage
• Cookie Data: Preferences, session identifiers, authentication tokens, and analytics information

1.3 Information from Third Parties

We may receive information about you from third-party sources to supplement the information you provide directly, verify your identity, prevent fraud, and comply with legal obligations. Third-party sources may include:

• Payment Providers: Transaction verification and fraud detection information from GCash, PayMaya, banks, and other payment processors
• Identity Verification Services: Age verification, identity authentication, and document validation results from authorized verification providers
• Regulatory Authorities: Information shared by PAGCOR or other regulatory bodies regarding compliance, licensing, or player protection matters
• Fraud Prevention Services: Risk assessment data, fraud indicators, and security alerts from specialized fraud detection providers

2. How We Use Your Information

ace21 uses the personal information we collect for various purposes related to providing, maintaining, and improving our gaming services. We process your data lawfully, fairly, and transparently, and only for the specific purposes outlined below:

2.1 Account Management and Service Provision

• Creating, maintaining, and managing your ace21 account
• Verifying your identity and age to ensure compliance with age restrictions (21+ requirement)
• Processing deposits, withdrawals, and other financial transactions
• Providing access to games, sports betting, and other Platform features
• Managing bonuses, promotions, rewards, and loyalty programs
• Processing and responding to customer support inquiries and requests
• Sending transactional communications including deposit confirmations, withdrawal notifications, and account alerts

2.2 Legal and Regulatory Compliance

• Complying with PAGCOR licensing requirements and gaming regulations
• Fulfilling Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations
• Conducting identity verification and due diligence procedures
• Detecting and preventing fraud, money laundering, terrorist financing, and other illegal activities
• Maintaining records as required by Philippine law and regulatory authorities
• Responding to legal processes, court orders, and requests from law enforcement or regulatory agencies
• Enforcing our Terms & Conditions and other policies

2.3 Security and Fraud Prevention

• Protecting the Platform from unauthorized access, cyber attacks, and security threats
• Monitoring for suspicious activity, fraudulent transactions, and policy violations
• Investigating potential fraud, abuse, or misconduct
• Implementing risk management and fraud detection measures
• Protecting the rights, property, and safety of ace21, our players, and the public

2.4 Platform Improvement and Analytics

• Analyzing usage patterns and player behavior to improve our services
• Conducting market research and gathering feedback to enhance user experience
• Testing new features, games, and functionality
• Optimizing Platform performance, speed, and reliability
• Personalizing content and game recommendations based on your preferences
• Generating aggregated, anonymized statistics and reports for internal business purposes

2.5 Marketing and Communications (With Your Consent)

• Sending promotional emails about new games, bonuses, and special offers
• Providing personalized marketing communications based on your interests and activity
• Informing you about tournaments, events, and Platform updates
• Conducting surveys and requesting feedback on our services

Note: You may opt out of marketing communications at any time by using the unsubscribe link in emails, adjusting your account preferences, or contacting customer support. Opting out of marketing will not affect transactional or service-related communications.

3. Legal Basis for Processing

Under the Data Privacy Act of 2012, we must have a lawful basis for processing your personal information. ace21 processes your data based on one or more of the following legal grounds:

Legal Basis	Processing Activities
Consent	Marketing communications, optional data collection, cookies and tracking technologies (where consent is required)
Contract Performance	Account creation, transaction processing, game provision, customer support, bonus management
Legal Obligation	Identity verification, AML/KYC compliance, regulatory reporting, record retention, responding to legal processes
Legitimate Interests	Fraud prevention, security monitoring, Platform improvement, analytics, business operations (where not overridden by your rights)

4. How We Share Your Information

ace21 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with certain third parties in the following circumstances:

4.1 Service Providers and Business Partners

We engage trusted third-party service providers to perform functions on our behalf and assist with Platform operations. These providers have access to personal information only as necessary to perform their functions and are contractually obligated to maintain confidentiality and security. Service providers include:

• Payment Processors: GCash, PayMaya, banks, and other financial institutions that process deposits and withdrawals
• Game Providers: Licensed software providers whose games are offered on our Platform
• Identity Verification Services: Third-party providers that verify age, identity, and document authenticity
• Cloud Hosting Providers: Companies that host our servers and store data securely
• Customer Support Tools: Live chat, email, and ticketing systems used to provide support services
• Analytics Providers: Services that help us analyze Platform usage and improve user experience
• Security Services: Fraud detection, risk assessment, and cybersecurity providers

4.2 Regulatory Authorities and Legal Compliance

We may disclose your information to regulatory authorities, law enforcement agencies, courts, and other governmental bodies when required by law or when we believe in good faith that disclosure is necessary to:

• Comply with PAGCOR regulations, audit requirements, or licensing obligations
• Respond to subpoenas, court orders, legal processes, or government requests
• Investigate or prevent fraud, money laundering, terrorist financing, or other illegal activities
• Enforce our Terms & Conditions or other policies
• Protect the rights, property, or safety of ace21, our players, or the public

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring or successor entity. We will notify you of any such change in ownership or control of your personal information.

4.4 With Your Consent

We may share your information with third parties for purposes not described in this Privacy Policy when we have obtained your explicit consent to do so.

5. Data Security and Protection

ace21 implements comprehensive technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security practices include:

5.1 Technical Security Measures

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS technology. Sensitive data at rest is also encrypted.
• Secure Infrastructure: Our Platform is hosted on secure servers protected by firewalls, intrusion detection systems, and regular security updates.
• Access Controls: Strict access controls limit who can view or handle personal information, with access granted only on a need-to-know basis.
• Password Protection: User passwords are hashed using industry-standard cryptographic algorithms and are never stored in plain text.
• Regular Security Audits: We conduct periodic security assessments, vulnerability scans, and penetration testing to identify and address potential weaknesses.

5.2 Organizational Security Measures

• Employee Training: Staff members receive regular training on data protection, privacy, and security best practices.
• Confidentiality Agreements: All employees and contractors are bound by confidentiality obligations.
• Data Minimization: We collect and retain only the personal information necessary for specified purposes.
• Incident Response: We maintain an incident response plan to address data breaches or security incidents promptly and effectively.

6. Data Retention

ace21 retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes, and enforce our agreements. Specific retention periods vary depending on the type of information and the purpose for which it was collected:

• Active Accounts: Personal information is retained for the duration of your active account relationship with ace21.
• Closed Accounts: Following account closure, we retain certain information for up to seven (7) years or longer as required by PAGCOR regulations, AML laws, tax laws, and other legal obligations.
• Transaction Records: Financial transaction records are retained for at least seven (7) years in compliance with Philippine financial record-keeping requirements.
• Marketing Data: Marketing-related data is retained until you withdraw consent or for a reasonable period if no consent withdrawal is received.
• Legal Proceedings: If your information is relevant to ongoing litigation, investigations, or disputes, we may retain it until such matters are resolved.

After the applicable retention period expires, we securely delete or anonymize your personal information in accordance with our data retention and destruction policies.

7. Your Privacy Rights

Under the Data Privacy Act of 2012, you have certain rights regarding your personal information. ace21 respects these rights and provides mechanisms for you to exercise them:

7.1 Right to Access

You have the right to request access to the personal information we hold about you. We will provide you with a copy of your data in a commonly used electronic format upon request.

7.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most information directly through your account settings or by contacting customer support.

7.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal information in certain circumstances, such as when it is no longer necessary for the purposes collected or when you withdraw consent. However, we may be legally required to retain certain information for regulatory, legal, or legitimate business purposes.

7.4 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes. You may also object to processing based on legitimate interests in certain circumstances.

7.5 Right to Data Portability

You have the right to receive personal information you provided to us in a structured, commonly used, machine-readable format and to transmit it to another data controller where technically feasible.

7.6 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to withdrawal.

7.7 Right to Lodge a Complaint

You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe we have violated your privacy rights or applicable data protection laws.

Exercising Your Rights: To exercise any of these rights, please contact our Data Protection Officer using the contact information provided in Section 11 below. We will respond to your request within the timeframe required by law, typically within fifteen (15) days for straightforward requests.

8. Cookies and Tracking Technologies

ace21 uses cookies, web beacons, and similar tracking technologies to enhance your experience on our Platform, analyze usage patterns, and deliver personalized content. A cookie is a small text file stored on your device that helps us recognize you, remember your preferences, and improve Platform functionality.

8.1 Types of Cookies We Use

• Essential Cookies: Necessary for Platform operation, authentication, security, and access to features. These cannot be disabled.
• Performance Cookies: Collect information about how you use the Platform to help us improve performance and user experience.
• Functionality Cookies: Remember your preferences and settings to provide personalized features.
• Analytics Cookies: Help us understand visitor behavior and measure Platform effectiveness through aggregated statistics.
• Marketing Cookies: Used to deliver relevant advertisements and measure campaign effectiveness (where consent is obtained).

8.2 Managing Cookies

Most web browsers allow you to control cookies through browser settings. You can typically set your browser to refuse all cookies or to alert you when cookies are being sent. However, disabling cookies may affect Platform functionality and limit your ability to use certain features.

9. Third-Party Links and Services

The ace21 Platform may contain links to third-party websites, services, or applications that are not operated by us. This Privacy Policy applies only to ace21 and does not cover the privacy practices of third parties. We are not responsible for the privacy policies or practices of third-party sites. We encourage you to review the privacy policies of any third-party services you access through our Platform.

10. Children's Privacy

ace21 does not knowingly collect personal information from individuals under the age of twenty-one (21). Our services are intended exclusively for adults who meet the legal gambling age in the Philippines. If you are under 21, you are prohibited from creating an account or using our services. If we discover that we have inadvertently collected information from a person under 21, we will delete such information promptly. Parents or guardians who believe their child has provided information to ace21 should contact us immediately.

11. Changes to This Privacy Policy

ace21 reserves the right to modify, update, or revise this Privacy Policy at any time to reflect changes in our practices, legal requirements, or Platform features. When we make material changes, we will notify you by posting the updated Privacy Policy on our Platform with a revised "Last Updated" date. We may also notify you via email or through a prominent notice on the Platform. Your continued use of ace21 following the posting of changes constitutes acceptance of those changes. We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information.

12. International Data Transfers

Your personal information is primarily stored and processed in the Philippines. However, some of our service providers and business partners may be located outside the Philippines. When we transfer your information internationally, we ensure that appropriate safeguards are in place to protect your data in accordance with this Privacy Policy and applicable data protection laws. Such safeguards may include standard contractual clauses, adequacy decisions, or other legally recognized transfer mechanisms.

13. Contact Information and Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or our data protection practices, or if you wish to exercise your privacy rights, please contact our Data Protection Officer:

• Email: [email protected] (Subject: Privacy Inquiry / Data Protection Request)
• Live Chat: Available 24/7 on the ace21 Platform
• Response Time: We aim to respond to all privacy-related inquiries within 15 business days

For formal complaints or concerns about our compliance with the Data Privacy Act of 2012, you may also contact the National Privacy Commission of the Philippines:

• National Privacy Commission
• 5th Floor, Philippine International Convention Center, Vicente Sotto Street, Pasay City, Philippines
• Email: [email protected]
• Website: www.privacy.gov.ph