Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") applies to all personal data collected and processed by r85aa ("r85aa," "we," "us," or "our") in connection with your use of the r85aa online gaming platform, accessible at r85aa.app, including all associated mobile applications, games, promotions, customer support channels, and related services (collectively, the "Platform").

This Policy applies to all registered players, visitors, and any other individuals whose personal data r85aa processes in the course of operating the Platform. It covers data collected directly from you, data collected automatically through your use of the Platform, and data received from third parties such as payment processors and identity verification providers.

r85aa is committed to handling your personal data in accordance with applicable Philippine data protection laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

2. Data Controller

For the purposes of applicable data protection law, r85aa is the data controller responsible for your personal data collected through the Platform. As data controller, r85aa determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable law.

r85aa has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection regulations. You may contact the DPO at any time using the contact details provided in Section 14 of this Policy.

3. Information We Collect

3.1 Information You Provide Directly

When you register for an r85aa account, complete KYC verification, make transactions, or contact our support team, you provide us with personal data including:

• Identity Data: Full legal name, date of birth, nationality, and gender.
• Contact Data: Email address, mobile number, and residential address (including city, province, and postal code within the Philippines).
• Identity Verification Documents: Copies of government-issued Philippine identification documents such as a PhilSys National ID, passport, driver's license, SSS ID, GSIS ID, or PRC ID.
• Financial Data: Bank account details (BPI, BDO, Metrobank), GCash or PayMaya account numbers, and transaction history on the Platform.
• Account Credentials: Username and encrypted password (r85aa never stores passwords in plain text).
• Communications: Records of your interactions with r85aa customer support, including live chat transcripts, emails, and support ticket content.
• Responsible Gaming Data: Self-exclusion requests, deposit limits, loss limits, and session time preferences you set on your account.

3.2 Information Collected Automatically

When you access and use the r85aa Platform, we automatically collect certain technical and behavioral data, including:

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, session duration, bet amounts, game outcomes, features accessed, and navigation patterns within the Platform.
• Location Data: General geographic location derived from your IP address, used to verify that you are accessing the Platform from a permitted jurisdiction.
• Log Data: Server logs recording your interactions with the Platform, including login timestamps, transaction logs, and error reports.
• Cookie Data: Data collected through cookies and similar tracking technologies as described in Section 9 of this Policy.

3.3 Information from Third Parties

r85aa may receive personal data about you from third parties in the following circumstances:

• Payment Processors: Transaction confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment providers.
• Identity Verification Providers: Results of identity and document verification checks conducted by our KYC service partners.
• Fraud Prevention Services: Risk scores and fraud indicators from third-party fraud detection providers.
• Regulatory Authorities: Information shared by PAGCOR or other Philippine regulatory bodies in connection with licensing compliance or investigations.

4. How We Use Your Information

r85aa uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your r85aa account, including processing your registration, verifying your identity, and managing your account settings.
• Service Delivery: To provide you with access to all games, promotions, payment services, and other features of the r85aa Platform.
• Payment Processing: To process deposits, withdrawals, and refunds, and to maintain accurate financial records of all transactions on your account.
• KYC & AML Compliance: To verify your identity, age, and source of funds in compliance with Philippine anti-money laundering regulations and PAGCOR licensing requirements.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, cheating, and other prohibited conduct on the Platform.
• Responsible Gaming: To administer responsible gaming tools including deposit limits, self-exclusion, and reality checks, and to identify players who may be exhibiting signs of problem gambling.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing & Promotions: To send you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the r85aa Platform.
• Legal Compliance: To comply with applicable Philippine laws, regulations, court orders, and regulatory requirements, including reporting obligations to PAGCOR and the Anti-Money Laundering Council (AMLC).

5. Legal Basis for Processing

r85aa processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary to perform our contract with you — i.e., to provide the r85aa gaming services you have registered for.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including KYC/AML obligations, tax reporting, and regulatory requirements.
• Legitimate Interests: Processing necessary for r85aa's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Information

r85aa does not sell your personal data to third parties. We share your personal data only in the following limited circumstances:

• Service Providers: Third-party vendors who assist r85aa in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), KYC verification providers, cloud hosting providers, customer support software providers, and fraud detection services. All service providers are contractually bound to process your data only on r85aa's instructions and in accordance with applicable data protection law.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where disclosure is required by law or regulation.
• Law Enforcement: Philippine law enforcement agencies where disclosure is required by a valid court order, subpoena, or other legal process.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of r85aa's assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.
• With Your Consent: To any other third party where you have given your explicit prior consent to such disclosure.

7. Data Retention

r85aa retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account Data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in compliance with Philippine AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by applicable law or regulatory instruction.
• Support Communications: Retained for a minimum of two (2) years from the date of the last interaction.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years to demonstrate compliance.

Upon expiry of the applicable retention period, r85aa will securely delete or anonymize your personal data in accordance with its data disposal procedures.

8. Data Security

r85aa implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the r85aa Platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Strict access controls limiting employee access to personal data on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform.
• Multi-factor authentication options for player accounts.
• Comprehensive employee training on data protection and information security.

While r85aa takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. In the event of a personal data breach that poses a risk to your rights and freedoms, r85aa will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

9. Cookies & Tracking Technologies

r85aa uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential Cookies: Required for the Platform to function correctly, including maintaining your login session, remembering your language preferences, and enabling secure transactions. These cookies cannot be disabled without impairing Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform, helping r85aa identify areas for improvement. These cookies do not identify you personally.
• Functional Cookies: Used to remember your preferences and personalize your experience on the Platform, such as your preferred game categories or display settings.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may prevent you from accessing certain features of the r85aa Platform. r85aa does not use cookies to serve third-party advertising.

10. Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by r85aa:

• Right to Be Informed: The right to be informed about how your personal data is collected and processed — which this Policy fulfills.
• Right of Access: The right to request a copy of the personal data r85aa holds about you, along with information about how it is being used.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data r85aa holds about you.
• 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 r85aa's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another data controller.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe r85aa has violated your data privacy rights.

To exercise any of these rights, please contact r85aa's Data Protection Officer using the contact details in Section 14. r85aa will respond to all valid requests within thirty (30) days. Identity verification may be required before processing your request.

11. Minors & Age Restriction

The r85aa Platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gaming regulations. r85aa does not knowingly collect personal data from individuals under the age of 21. If r85aa discovers that personal data has been collected from a person under 21, that account will be immediately closed, all associated data will be deleted, and any funds will be returned to the depositing payment method after verification.

If you are a parent or guardian and believe that a minor has registered on the r85aa Platform, please contact our support team immediately so that we can take appropriate action.

12. International Data Transfers

r85aa primarily processes your personal data within the Philippines. In certain circumstances, your data may be transferred to and processed in other countries — for example, where r85aa uses cloud infrastructure or service providers with operations outside the Philippines. In all such cases, r85aa ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses consistent with the requirements of the Data Privacy Act of 2012 and NPC regulations on cross-border data transfers.

13. Changes to This Policy

r85aa reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. When material changes are made, r85aa will notify registered players via email or in-platform notification before the changes take effect. The updated Policy will be published on this page with a revised "Last Updated" date.

Your continued use of the r85aa Platform after the effective date of any updated Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically.

14. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way r85aa handles your personal data, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC is the Philippine government authority responsible for administering and enforcing the Data Privacy Act of 2012.