About this document: This Privacy Policy explains how Aironply ("we," "us," or "our") collects, uses, shares, and protects personal information provided by users ("you") of the aironply Platform at aironply.com. It is written in compliance with the Republic of the Philippines Data Privacy Act of 2012 (RA 10173). If you have questions, contact our Data Protection Officer at privacy@aironply.com.
1. Who We Are
Aironply is a licensed online gaming platform operating in the Philippines. References to "aironply," "we," "us," or "our" in this Privacy Policy refer to the company operating the aironply Platform, including its website at aironply.com and all associated digital services.
Aironply acts as the Personal Information Controller in relation to the personal data you provide. This means we determine the purpose and means of processing your personal information, and we are responsible for ensuring it is handled in accordance with applicable Philippine data protection law.
Our Data Protection Officer (DPO) is the designated point of contact for all data privacy matters. You can reach the DPO directly at privacy@aironply.com.
2. Personal Data We Collect
Aironply collects personal data through several channels — directly from you when you register or use the Platform, automatically through your use of the site, and from third parties where relevant and permitted by law.
2.1 Data You Provide Directly
- Registration data: Full name, date of birth, email address, mobile number, and username.
- Identity verification data: Government-issued ID (e.g., PhilSys ID, passport, driver's licence), proof of address, and selfie photo for liveness verification.
- Payment data: GCash number, Maya account details, bank account details (BDO, BPI, UnionBank), or card details (Visa/Mastercard). Note: Full card numbers are not stored by aironply — they are processed by PCI-DSS compliant payment processors.
- Communication data: Messages sent to aironply support, survey responses, and feedback submitted through the Platform.
2.2 Data Collected Automatically
- Device and usage data: IP address, browser type, operating system, device identifiers, pages visited, session duration, and clickstream data.
- Gaming data: Bet history, game session logs, deposit and withdrawal activity, and bonus usage records.
- Location data: Approximate geographic location derived from your IP address, used to verify that you are accessing the Platform from a permitted jurisdiction.
- Cookie data: See Section 5 for full details of cookies used by aironply.
2.3 Data from Third Parties
- Identity verification providers may confirm or supplement the identity data you provide.
- Payment processors may return transaction reference numbers and status codes.
- Fraud detection services may flag account activity patterns for our review.
| Data Category | Examples | Source |
|---|---|---|
| Identity | Name, DOB, government ID | You / Verification provider |
| Contact | Email, mobile number | You |
| Financial | GCash number, bank account, card details | You / Payment processor |
| Technical | IP address, device ID, browser | Automatically collected |
| Behavioural | Bet history, session logs, game preferences | Automatically collected |
| Communications | Support chat transcripts, emails | You |
3. How Aironply Uses Your Personal Data
Aironply uses personal data for specific, legitimate purposes. We do not use data for purposes incompatible with those stated here without first obtaining your consent or having another lawful basis.
- Account creation and management: To register your account, verify your identity, and maintain your player profile on aironply.
- Processing transactions: To process deposits, bets, and withdrawals through your chosen payment method in Philippine pesos.
- Legal and regulatory compliance: To meet our obligations under Philippine gaming regulations, anti-money laundering requirements (AMLA), and the Data Privacy Act of 2012.
- Fraud prevention and security: To detect and prevent fraudulent activity, unauthorized access, and other misuse of the aironply Platform.
- Customer support: To respond to your queries, complaints, and requests via email, chat, or phone.
- Platform improvement: To analyze usage patterns, fix bugs, improve game performance, and develop new features based on aggregated player data.
- Responsible gaming: To monitor gaming patterns, enforce deposit limits and self-exclusions, and flag accounts that may need responsible gaming intervention.
- Marketing communications: To send you promotional offers, bonuses, and updates about aironply — only where you have given valid consent, and with a clear opt-out option on every communication.
4. Legal Basis for Processing
Under the Data Privacy Act of 2012 (RA 10173), aironply relies on the following lawful bases for processing your personal data:
- Contract performance: Processing necessary to provide you with the aironply service, including account management, transaction processing, and game delivery.
- Legal obligation: Processing required to comply with Philippine gaming regulations, AMLA reporting requirements, and the National Privacy Commission's directives.
- Legitimate interests: Processing for fraud detection, platform security, and internal analytics — where those interests do not override your data privacy rights.
- Consent: Processing for direct marketing communications and non-essential cookies, where you have given clear, informed, and freely withdrawable consent.
Where consent is the legal basis, you may withdraw it at any time without affecting the lawfulness of prior processing. Withdrawing consent for marketing will not affect your ability to use aironply.
5. Cookies and Tracking Technologies
Aironply uses cookies and similar technologies to operate the Platform, improve your experience, and gather analytics data. A cookie is a small text file stored on your device by your browser. Here's how aironply uses them:
- Essential cookies: Required for the Platform to function. These maintain your login session, remember your language preference, and enable secure transactions. You cannot opt out of essential cookies while using aironply.
- Analytics cookies: Used to understand how players navigate aironply — which pages are visited most, where sessions drop off, and how the Platform performs on different devices. Data is aggregated and anonymised. These are only placed with your consent.
- Preference cookies: Remember your settings, such as your preferred game category or display preferences, so you don't have to set them again each visit.
- Security cookies: Help detect and prevent fraudulent login attempts and unusual account activity.
You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using aironply, but some personalisation features may not function as expected.
6. Sharing Your Personal Data
Aironply does not sell or trade your personal data. We may share your data with third parties only in the following limited circumstances:
- Payment processors: GCash (Mynt), Maya (Paymaya Philippines), GrabPay, Coins.ph, InstaPay/PESONet network members, BDO, BPI, UnionBank, and card processing networks. These receive only the data necessary to process your transaction.
- Identity verification providers: Third-party KYC (Know Your Customer) services that help verify government IDs and conduct liveness checks as required by our regulatory obligations.
- Regulatory authorities: The Philippine gaming regulatory authority and other government agencies (e.g., AMLC, NPC) where required by law or valid legal process.
- Fraud prevention services: Third-party tools used to detect and prevent fraudulent account activity. These services process data under strict data processing agreements.
- Technology service providers: Cloud hosting, customer support software, and analytics platforms that help operate aironply. All processors are bound by contractual data protection obligations.
- Business transfers: In the event of a merger, acquisition, or sale of all or part of aironply's business, your data may be transferred to the successor entity, subject to the same privacy protections.
All third parties who process personal data on behalf of aironply are required to sign data processing agreements obligating them to handle data securely and in accordance with Philippine data protection law.
7. Data Security
Aironply implements comprehensive technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, and destruction. These measures include:
- TLS/SSL encryption for all data in transit between your device and our servers.
- Encryption at rest for sensitive stored data, including identity documents and financial information.
- Role-based access controls limiting internal access to personal data on a need-to-know basis.
- Regular security audits, vulnerability assessments, and penetration testing.
- Secure, geographically redundant server infrastructure with continuous monitoring.
- Employee data protection training and a strict internal data handling policy.
Despite these measures, no online platform can guarantee absolute security. If aironply becomes aware of a data breach that is likely to result in harm to affected individuals, we will notify the National Privacy Commission and affected users in accordance with the timelines required by RA 10173.
You also play a role in keeping your account secure. Choose a strong, unique password, do not share your login credentials, and contact aironply support immediately if you suspect unauthorized access to your account.
8. Data Retention
Aironply retains personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable law. Key retention periods are as follows:
- Account data: Retained for the duration of your active account plus five years following account closure, as required by anti-money laundering regulations.
- Transaction records: Retained for five years from the date of the transaction in compliance with AMLA and gaming regulatory requirements.
- Identity verification documents: Retained for five years following account closure or the last verified transaction, whichever is later.
- Support communications: Retained for two years from the date of the communication, unless the matter involves an ongoing legal or regulatory issue.
- Analytics data: Aggregated, anonymised analytics data may be retained indefinitely as it no longer constitutes personal data once anonymised.
- Cookie data: Varies by cookie type — session cookies are deleted when you close your browser; persistent cookies expire according to their individual settings (typically 30 days to 12 months).
When personal data is no longer required, aironply securely deletes or anonymises it using methods that make re-identification impossible.
9. Your Rights as a Data Subject
Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by aironply. These rights are yours — you don't need to give a reason to exercise most of them.
Right to Be Informed
You have the right to know that aironply is collecting your data, what data is collected, how it is used, and with whom it is shared — which is exactly what this Privacy Policy tells you.
Right to Access
You can request a copy of the personal data aironply holds about you at any time. We will respond within 15 business days of a verified request.
Right to Rectification
If any personal data we hold is inaccurate or incomplete, you have the right to have it corrected. Update basic details directly in your account settings, or contact our DPO for identity document corrections.
Right to Erasure
You may request deletion of your personal data where it is no longer needed for its original purpose, subject to legal retention obligations. Note that some data must be retained to comply with AMLA and gaming regulations even after account closure.
Right to Object
You may object to processing of your personal data for direct marketing purposes at any time. You can also object to processing based on legitimate interests where you have grounds relating to your particular situation.
Right to Data Portability
You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another controller where technically feasible.
Right to Withdraw Consent
Where aironply relies on consent as the legal basis for processing, you may withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.
Right to Lodge a Complaint
If you believe aironply has mishandled your personal data, you may lodge a complaint with the National Privacy Commission (NPC) of the Philippines — the supervisory authority for data protection.
To exercise any of these rights, contact our Data Protection Officer at privacy@aironply.com. Please include your full name and registered email address so we can verify your identity before processing the request.
10. Children's Privacy
Aironply is strictly intended for individuals aged 21 and above. We do not knowingly collect personal data from persons under 21 years of age. Age verification is a mandatory step in the registration and withdrawal process.
If we become aware that personal data has been collected from a person under 21 without verified parental or guardian consent, we will delete that data and close the associated account immediately. If you believe a minor has registered on aironply, please notify us at privacy@aironply.com without delay.
11. Cross-Border Data Transfers
Aironply primarily processes and stores data in the Philippines. Where we engage service providers located outside the Philippines — such as cloud infrastructure providers or international fraud detection services — we ensure that adequate safeguards are in place before transferring your personal data.
These safeguards may include standard contractual clauses approved by the National Privacy Commission, binding corporate rules where the provider is part of a multinational group, or adequacy decisions confirming the receiving country provides comparable data protection. We will not transfer your data to a country that does not meet these requirements.
12. Marketing Communications
Aironply may send you promotional messages about bonuses, new games, and special offers via email or SMS. These are only sent where you have given consent during registration or have subsequently opted in through your account settings.
Every marketing communication from aironply includes a clear unsubscribe link or opt-out instruction. You can also manage your marketing preferences at any time from your account settings page, or by emailing support@aironply.com with your opt-out request. Opting out of marketing will not affect your ability to use aironply or receive service-related communications (such as transaction confirmations and security alerts).
13. Third-Party Links
The aironply Platform may contain links to third-party websites or services — for example, links to payment provider portals. These third-party sites have their own privacy policies that are independent of aironply's. We are not responsible for the privacy practices of those sites, and this Privacy Policy does not apply to them.
We recommend reviewing the privacy policy of any third-party site before providing personal information on it. Aironply does not endorse or make any representations about third-party sites linked from the Platform.
14. Changes to This Privacy Policy
Aironply may update this Privacy Policy from time to time to reflect changes in our data practices, new legal requirements, or Platform developments. When changes are made, the updated policy will be posted on this page with a new "Last Updated" date at the top.
For material changes — those that significantly affect your rights or how we use your data — aironply will send a notification to the email address on your account before the changes take effect. We will also display a notice on the Platform for a reasonable period following any material update.
Your continued use of aironply after an updated Privacy Policy has been posted constitutes your acceptance of the updated terms, to the extent permitted by applicable law.
15. Contact Us
If you have questions about this Privacy Policy, want to exercise your data subject rights, or wish to raise a data protection concern, please reach out to us:
- Data Protection Officer: privacy@aironply.com
- General Support: support@aironply.com
- Response Time: Within 15 business days for data subject rights requests; within 5 business days for general privacy queries.
If you are not satisfied with aironply's response to a data protection concern, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC). Information about how to lodge a complaint with the NPC is available on the NPC's official website.
For general account questions and platform help, our FAQ page is a good starting point. For responsible gaming support, visit our Responsible Gaming page.