45ph Privacy Policy

1. Overview

This Privacy Policy ("Policy") applies to all personal information collected by or on behalf of 45ph ("the Company," "we," "us," or "our") through the 45ph online gaming platform accessible at 45ph.one, including all associated services, features, games, account management tools, payment processing functions, and customer support interactions (collectively, "the Platform").

By registering an account on the 45ph Platform, you acknowledge that you have read and understood this Policy and consent to the collection, processing, storage, and use of your personal data as described herein. If you do not agree to this Policy, you must not create an account or use the Platform.

This Policy should be read in conjunction with the 45ph Terms & Conditions, which governs your overall use of the Platform. In the event of any conflict between this Policy and the Terms & Conditions regarding data privacy matters, this Policy shall prevail.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and applicable data protection law, the personal data controller responsible for your information is:

The Company has designated a Data Protection Officer (DPO) in compliance with RA 10173. For data privacy-specific inquiries, requests, or complaints, you may contact the DPO at the email address provided in Section 14 of this Policy.

3. Personal Data We Collect

45ph collects personal data through multiple channels, including direct provision by you during registration and use of the Platform, automated collection through Platform usage, and from third-party sources where permitted by law. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name as it appears on your government-issued Philippine identification document;
• Date of birth (for age verification — 21+ requirement under PAGCOR regulations);
• Residential address (barangay, city/municipality, province, postal code);
• Philippine mobile number (09XX or +63 format) and/or email address;
• Account username and encrypted password hash;
• Nationality and citizenship status.

3.2 Identity Verification (KYC) Data

• Copies of government-issued Philippine identification documents (e.g., PhilSys ID, passport, driver's license, UMID, SSS/GSIS ID, PRC ID, voter's ID);
• Selfie or facial image submitted for liveness verification;
• Additional documents required for enhanced due diligence under Anti-Money Laundering Act (AMLA) obligations.

3.3 Financial & Transaction Data

• GCash mobile number and transaction reference numbers;
• Maya (PayMaya) account identifiers;
• Bank account details for BPI, BDO, Metrobank, and InstaPay transactions (account name, account number — stored in encrypted form);
• Deposit and withdrawal amounts, dates, and payment method used;
• Account balance history and transaction ledger records.

3.4 Gaming & Platform Activity Data

• Game sessions played, bets placed, wins, and losses;
• Games accessed, time spent per session, wagering patterns;
• Bonus claims, promotional participation, and wagering requirement progress;
• VIP program tier status and reward redemption history.

3.5 Technical & Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, browser type and version;
• Session identifiers, login timestamps, and session duration;
• Cookies and similar tracking technologies (see Section 9).

3.6 Communications Data

• Records of communications between you and the 45ph support team, including chat transcripts, email correspondence, and call records;
• Feedback, complaints, and dispute records.

4. How We Use Your Personal Data

The Company uses your personal data for the following specific purposes:

45ph does not use personal data for automated profiling that produces legal or similarly significant effects on Players without human review and, where required, explicit consent.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, the Company processes your personal data on one or more of the following lawful bases:

• Consent: Where you have freely given, specific, informed, and unambiguous consent to processing — such as for marketing communications and optional profiling features. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Contractual necessity: Processing necessary for the performance of the contract between you and 45ph — including account management, payment processing, and provision of gaming services.
• Legal obligation: Processing necessary to comply with applicable Philippine law — including PAGCOR regulations, Anti-Money Laundering Act (RA 9160, as amended), and the Philippine Data Privacy Act itself.
• Legitimate interests: Processing necessary for the legitimate interests of 45ph, including fraud prevention, platform security, responsible gaming monitoring, and business analytics — provided such interests are not overridden by your fundamental rights and freedoms.

6. Data Sharing & Third-Party Disclosure

45ph does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly to the extent necessary for the stated purpose:

• Payment service providers: GCash (G-Xchange, Inc.), Maya Philippines, BPI, BDO, Metrobank, and InstaPay network participants — for processing deposits and withdrawals;
• Game providers: Licensed third-party game software providers — limited to session identifiers and anonymized gaming data necessary for game delivery;
• KYC & identity verification services: Regulated third-party identity verification platforms operating under equivalent data protection standards;
• PAGCOR and regulatory authorities: As required by law or regulatory instruction, including mandatory reporting obligations under the Anti-Money Laundering Act;
• Law enforcement and courts: Where disclosure is required by a valid court order, legal process, or statutory obligation under Philippine law;
• IT and infrastructure service providers: Cloud hosting, security, and technical service providers operating under binding data processing agreements that require equivalent data protection standards.

All third-party data processors engaged by 45ph are contractually bound to process personal data only on the Company's documented instructions, maintain appropriate security measures, and comply with applicable data protection law.

7. Data Retention

45ph retains personal data for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and audit obligations. Specific retention periods include:

• Account and identity data: For the duration of the active account relationship plus five (5) years following account closure — consistent with PAGCOR record-keeping requirements and the Anti-Money Laundering Act;
• Transaction and financial records: Minimum of five (5) years from the date of the transaction, as required under Philippine AML regulations;
• KYC documentation: Five (5) years from account closure or the completion of the relevant transaction, whichever is later;
• Communications data (support records): Three (3) years from the date of the communication;
• Gaming session logs: Three (3) years from the date of the session;
• Technical and device data: Twelve (12) months from collection, unless extended for ongoing fraud investigations.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymized in accordance with the Company's data disposal procedures.

8. Security Measures

45ph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption in transit: All data transmitted between your device and the 45ph Platform is encrypted using TLS 1.3 with 256-bit encryption — the same standard used by Philippine online banking platforms including BPI and BDO;
• Encryption at rest: Sensitive personal data — including KYC documents, payment account details, and password hashes — is encrypted at rest using AES-256;
• Access controls: Strict role-based access controls limit employee access to personal data on a need-to-know basis, with access logs maintained and reviewed;
• Two-factor authentication: Available for all 45ph accounts; mandatory for privileged administrative access to Platform systems;
• Penetration testing & vulnerability management: Regular security assessments conducted by qualified third-party security professionals;
• Incident response: Documented data breach response procedures, including obligations to notify the National Privacy Commission (NPC) and affected data subjects within timeframes prescribed by RA 10173.

9. Cookies & Tracking Technologies

The 45ph Platform uses cookies and similar tracking technologies to provide, maintain, and improve the Platform's functionality and user experience. The categories of cookies used include:

• Strictly necessary cookies: Required for the Platform to function correctly — including session management, login state maintenance, and security tokens. These cookies cannot be disabled without impairing Platform functionality;
• Performance and analytics cookies: Collect anonymized or aggregated information about how Players use the Platform — page load times, error rates, and navigation patterns — to improve Platform performance;
• Functionality cookies: Remember your Platform preferences such as language settings and display options between sessions;
• Security cookies: Used for fraud detection, bot prevention, and identifying suspicious login patterns.

The Platform does not use third-party advertising or behavioral targeting cookies. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to log in and use the Platform.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 45ph:

• Right to be informed: The right to know whether your personal data is being processed and to receive clear, accessible information about how it is used — as provided in this Policy;
• Right of access: The right to obtain a copy of the personal data we hold about you, together with information about how it is processed;
• Right to rectification: The right to have inaccurate or incomplete personal data corrected. You may update most account information directly through your 45ph account settings. For KYC-related corrections, contact support;
• Right to erasure (right to be forgotten): The right to request deletion of your personal data where retention is no longer legally required. Note that this right is subject to our legal obligations under PAGCOR regulations and the AMLA, which require retention of certain records for defined periods;
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to have it transmitted to another data controller where technically feasible;
• Right to object: The right to object to processing of your personal data for direct marketing purposes at any time, and to processing based on legitimate interests where your rights and freedoms override those interests;
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, submit a written request to the 45ph Data Protection Officer at the contact details provided in Section 14. We will respond within fifteen (15) working days of receiving a valid request, as required under RA 10173.

11. Minors

The 45ph Platform is strictly intended for individuals who are twenty-one (21) years of age or older, in compliance with PAGCOR minimum age requirements for all Philippine online gaming. The Company does not knowingly collect personal data from individuals under 21 years of age.

If the Company becomes aware that it has inadvertently collected personal data from an individual under the age of 21, it will promptly delete such data and close the associated account. If you believe that a minor has registered an account on the 45ph Platform, please contact [email protected] immediately.

12. Cross-Border Data Transfers

In certain circumstances, your personal data may be transferred to, stored, or processed in countries outside the Philippines — for example, when using cloud infrastructure providers or third-party game software providers whose servers are located overseas. Where such transfers occur, the Company ensures that:

• The recipient country provides an adequate level of protection for personal data, as recognized under Philippine data protection law; or
• Appropriate safeguards are in place, such as contractual clauses requiring the recipient to maintain standards of data protection equivalent to those applicable in the Philippines; and
• Such transfers comply with all applicable requirements under RA 10173 and National Privacy Commission guidelines.

13. Amendments to This Policy

The Company reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. The updated Policy will be posted on the 45ph Platform with the revised effective date clearly indicated at the top of the document.

For material changes that significantly affect how we process your personal data, the Company will provide advance notice by email to registered account holders or through a prominent notice on the Platform, at least fourteen (14) days before the changes take effect.

Your continued use of the 45ph Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree to any amendment, you must cease using the Platform and request account closure.

14. Contact & Data Protection Officer

For any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact the 45ph Data Protection Officer:

You also have the right to lodge a complaint directly with the Philippine National Privacy Commission (NPC) if you believe your data privacy rights have been violated. Information about the NPC and its complaint process is publicly available through official Philippine government channels.