Privacy Policy
Last updated: June 2026
NEMO Interactive Group Corporation (“We”, “Us”, “Our”, “the Company”), operator of the ArionPlay platform at sodalisgame.com, is committed to protecting your personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, “DPA”) and its implementing rules. This Privacy Policy explains what data we collect, how we use it, how we protect it, and what rights you have as a data subject.
By registering an Account on ArionPlay or using our 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.
1. Scope
This Privacy Policy applies to all personal data collected by ArionPlay in connection with your use of the Platform, including data collected through the website, mobile application, customer support interactions, and third-party payment processors. It does not apply to third-party websites linked from our Platform.
2. Personal Data We Collect
We collect the following categories of personal data:
Identity Data: Full name, date of birth, nationality, government-issued identification number (as provided during KYC verification).
Contact Data: Philippine mobile number, email address, and any additional contact details provided at registration or during Account management.
Financial Data: GCash account details, Maya account details, bank account information, transaction records, deposit and withdrawal history, and payment method verification documents.
Verification Data: Photographs of government-issued identification documents, selfie photographs submitted during KYC, and any additional documentation provided for source of funds verification.
Usage Data: Login timestamps, IP addresses, device identifiers, browser type, pages visited, games played, bet amounts, session duration, and other Platform activity logs.
Cookies and Tracking Data: Information collected through cookies, web beacons, and similar tracking technologies as described in Section 9 of this Policy.
Communications Data: Records of your correspondence with our support team, including live chat transcripts and email exchanges.
3. How We Use Your Personal Data
Account Management: To create and maintain your Account, verify your identity, and provide access to the Platform.
Service Delivery: To process deposits and withdrawals, deliver gaming services, and manage bonuses and promotions.
Legal Compliance: To meet our obligations under the Philippine Data Privacy Act, PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), and other applicable Philippine laws. This includes KYC verification, transaction monitoring, and suspicious activity reporting.
Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, account abuse, and security threats. We use automated monitoring systems to flag unusual patterns.
Responsible Gaming: To identify and respond to signs of problem gambling, apply player protection tools, and process responsible gaming requests including self-exclusion.
Customer Support: To respond to your enquiries, resolve disputes, and process complaints.
Marketing Communications: To send promotional offers, bonus notifications, and platform updates to Players who have opted in. You may opt out of marketing communications at any time through your Account settings or by contacting support.
Analytics and Improvement: To analyse Platform usage patterns, improve our services, and develop new features. Analytics data is typically aggregated and anonymised.
4. Legal Basis for Processing
We process your personal data on the following legal bases under the Philippine Data Privacy Act and applicable regulations:
Contractual necessity: Processing required to perform the contract with you, including Account management, service delivery, and payment processing.
Legal obligation: Processing required to comply with PAGCOR regulations, AML obligations, tax requirements, and other applicable Philippine law.
Legitimate interests: Processing for fraud prevention, security, and responsible gaming purposes, where our interests do not override your fundamental rights.
Consent: Processing for marketing communications, where you have opted in. You may withdraw consent at any time without affecting the lawfulness of prior processing.
5. Information Sharing
We do not sell your personal data to third parties. We share your data only in the following circumstances:
Payment Processors: GCash (Globe Fintech Innovations), Maya (Maya Philippines Inc.), and partner banks, to the extent necessary to process deposits and withdrawals. These processors are bound by their own privacy policies and applicable Philippine data protection law.
Game Providers: Information necessary for game functionality may be shared with licensed game providers (JILI, PG Soft, Pragmatic Play, Evolution). These providers process data under their own data protection frameworks.
Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other government bodies where we are legally required to report or disclose information.
PlaySafe Alliance: Anonymised responsible gaming data shared for the purposes of industry-wide safer gambling research and programme development.
Professional Advisors: Legal, accounting, and audit professionals bound by professional confidentiality obligations.
Business Transfer: In the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, subject to equivalent privacy protections.
6. Data Security
We implement appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include SSL/TLS encryption for data in transit, access controls limiting data access to authorised personnel, and security monitoring of our systems.
While we take reasonable precautions, no system is completely secure. You are responsible for keeping your Account credentials confidential and for notifying us immediately of any suspected unauthorised access.
7. Data Retention
We retain your personal data for as long as your Account is active and for a period after closure as required by applicable law. Under Philippine AML and gaming regulations, transaction records and identity verification documents are retained for a minimum of five years from the date of the transaction or Account closure, whichever is later. Communications data is retained for a period sufficient to resolve any related disputes.
At the end of the applicable retention period, data is deleted or anonymised in a manner consistent with our legal obligations.
8. Your Rights as a Data Subject
Under the Philippine Data Privacy Act, you have the following rights with respect to your personal data:
Right to be Informed: The right to know what data we collect and how we use it — fulfilled by this Privacy Policy.
Right of Access: The right to request a copy of the personal data we hold about you.
Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
Right to Erasure: The right to request deletion of your personal data, subject to our legal retention obligations. Note that we cannot delete data that we are legally required to retain.
Right to Object: The right to object to processing based on legitimate interests, including direct marketing.
Right to Data Portability: The right to receive your data in a structured, commonly used format where technically feasible.
Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) at privacy.gov.ph if you believe your data rights have been violated.
To exercise any of these rights, contact us through our Contact page or by emailing our support team. We will respond within 30 calendar days.
9. Cookies and Tracking Technologies
ArionPlay uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us remember your preferences, maintain your login session, and analyse Platform usage.
Essential cookies are required for the Platform to function and cannot be disabled. They include session cookies that maintain your login and security cookies that protect against fraud.
Analytics cookies collect anonymised information about how players use the Platform. We use this data to improve game performance, page loading, and user experience.
Marketing cookies may be placed by third-party advertising partners where you have consented. You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to use the Platform.
10. International Data Transfers
Some of our service providers, including game providers and infrastructure partners, may process data outside the Philippines. Where such transfers occur, we ensure that appropriate safeguards are in place consistent with our obligations under the Philippine Data Privacy Act and applicable implementing regulations of the National Privacy Commission.
11. Children’s Privacy
The Platform is strictly for individuals aged 21 and over. We do not knowingly collect personal data from persons under 21. If we become aware that we have collected data from a person under 21, we will delete that data and close the associated Account immediately.
12. Policy Updates
We may update this Privacy Policy from time to time. Material changes will be communicated to you via email or in-Platform notification before they take effect. Your continued use of the Platform after the effective date of any update constitutes acceptance of the revised Policy.
13. Contact for Privacy Matters
For questions, requests, or complaints regarding this Privacy Policy or the handling of your personal data, contact us through our Contact page. For complaints to the regulator, the National Privacy Commission can be reached at privacy.gov.ph. See also our Terms and Conditions and Responsible Gaming page.