Privacy Policy

This Privacy Policy ("Policy") governs the collection, use, storage, and disclosure of personal information by 45ph ("45ph," "we," "us," "our") in connection with the 45ph online casino platform accessible at 45ph.club.

This Policy is issued in compliance with Republic Act 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the regulations and circulars issued by the National Privacy Commission ("NPC"). As an online gambling operator subject to PAGCOR oversight, 45ph is also bound by data handling requirements under Philippine gambling regulations and the Anti-Money Laundering Act (Republic Act 9160, as amended).

By registering a 45ph account or using the 45ph platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree to this Policy, you should not create a 45ph account or use the platform.

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for the personal information processed in connection with the 45ph platform is the legal entity operating the 45ph.club platform under PAGCOR regulatory authorization.

Questions, requests, and complaints relating to this Privacy Policy and the processing of your personal data may be directed to 45ph's designated Data Protection Officer (DPO) using the contact details set out in Section 16 of this Policy.

45ph collects the following categories of personal data in the course of operating the platform and fulfilling our regulatory obligations:

• Full legal name as it appears on government-issued identification
• Date of birth (used to verify you are 21 years of age or older)
• Nationality and country of residence
• Government-issued ID type and number (Philippine passport, national ID, SSS, PhilHealth, driver's license)
• Username and encrypted account password
• Profile photo (where submitted for KYC purposes)

• Email address (primary communication channel)
• Mobile phone number (used for account verification, 2FA, and SMS communications)
• Residential address (for KYC and regulatory purposes)

• GCash account mobile number and registered name
• Maya (PayMaya) account details
• Philippine bank account name and account number (BPI, BDO, UnionBank, Metrobank, and others)
• Deposit and withdrawal transaction records, amounts, timestamps, and reference numbers
• Cryptocurrency wallet addresses used for USDT TRC20 transactions
• Transaction history and balance records retained for regulatory compliance

• Complete game history including all bets placed, outcomes, session durations, and game titles
• Sports betting selections, stakes, and results
• Responsible gaming settings including deposit limits, session limits, and self-exclusion history
• Bonus claim history and wagering requirement progress
• VIP tier status and loyalty point accumulation

• IP address at the time of account registration and at each login
• Device type, operating system, and browser type and version
• Mobile device identifiers (where applicable)
• Geolocation data derived from IP address (country and region level)
• Session logs, login timestamps, and access records

• Records of all customer support interactions via live chat, email, and other channels
• Feedback, complaints, and dispute correspondence
• Marketing communication preferences and opt-in/opt-out records

45ph collects personal data through the following means:

• Account Registration: You directly provide identity, contact, and age verification data when creating your 45ph account.
• KYC Verification: You submit identity documents and proof of address during the mandatory verification process required by PAGCOR and Philippine law.
• Payment Processing: Financial data is collected when you make deposits or request withdrawals via GCash, Maya, bank transfer, or other accepted payment methods.
• Platform Usage: Technical data, gaming activity data, and device data are collected automatically as you use the 45ph platform through cookies, server logs, and analytics tools.
• Customer Support: Communications data is collected when you contact 45ph support via live chat or email.
• Third-Party Verification Services: 45ph may receive identity verification results from third-party KYC service providers engaged to assist with document authentication.

45ph processes your personal data for the following purposes:

Under the Philippine Data Privacy Act of 2012, 45ph relies on the following legal bases for processing your personal data:

• Contractual Necessity: Processing required to create and manage your 45ph account, process payments, and deliver the services described in our Terms & Conditions. Without this processing, 45ph cannot provide the platform services to you.
• Legal Obligation: Processing required to comply with PAGCOR regulatory obligations, the Anti-Money Laundering Act, the Philippine Data Privacy Act, and other applicable Philippine laws. This processing is mandatory and cannot be opted out of.
• Legitimate Interests: Processing for fraud prevention, security monitoring, platform improvement, and responsible gaming enforcement, where such processing does not override your data protection rights.
• Consent: Processing for optional purposes such as marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

45ph does not sell your personal data. We share personal data only in the following circumstances and only to the extent necessary for the stated purpose:

45ph is legally required to disclose certain personal and financial data to PAGCOR as part of our regulatory reporting obligations. We are also required to file suspicious transaction reports and covered transaction reports with the Anti-Money Laundering Council (AMLC) as mandated under Philippine law. Law enforcement agencies may receive data pursuant to a valid court order, subpoena, or other legal process.

45ph engages third-party service providers who process personal data on our behalf under strict contractual obligations. These include:

• KYC and identity verification service providers
• Payment processors and e-wallet integrations (GCash, Maya, banks)
• Customer support platform providers
• Platform analytics and fraud detection services
• Cloud infrastructure and data storage providers

All service providers are contractually bound to process data only for the specified purposes, implement appropriate security measures, and comply with applicable data protection law. 45ph remains responsible for how these providers handle data processed on our behalf.

Certain technical data (such as session identifiers and bet amounts) may be processed by licensed game software providers to deliver game results. These providers do not receive your full identity or contact data and are bound by data processing agreements with 45ph.

45ph uses cookies and similar tracking technologies on the 45ph.club platform. A cookie is a small text file stored on your device by your web browser when you visit the site.

• Essential Cookies: Required for the platform to function correctly — including maintaining your login session, remembering your game lobby position, and processing transactions. These cannot be disabled without breaking core platform functionality.
• Security Cookies: Used to detect fraudulent activity, support security features such as CSRF protection, and identify unusual login patterns. These are essential for platform security.
• Analytics Cookies: Used to understand how players use the 45ph platform — which game categories are most popular, where players encounter difficulties, and how to improve the experience. Data is aggregated and anonymised where possible.
• Preference Cookies: Store your platform preferences such as language settings and responsible gaming tool configurations.

You may manage non-essential cookies through your browser settings. Most browsers allow you to block or delete cookies. Please note that disabling essential cookies will impair your ability to use the 45ph platform, including logging into your account. 45ph's cookie consent banner, displayed on first visit, allows you to accept or decline non-essential cookie categories.

45ph retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by law. The following retention guidelines apply:

• Active Account Data: Retained for the duration of your account's active status and for a period of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and Philippine tax law.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• Financial Transaction Records: Retained for five (5) years from the date of each transaction in compliance with AMLA and tax reporting obligations.
• Gaming Activity Logs: Retained for five (5) years for regulatory compliance and responsible gaming record-keeping.
• Customer Support Records: Retained for three (3) years from the date of the last interaction.
• Marketing Consent Records: Retained for the duration of your account and for three (3) years following account closure to demonstrate consent history.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be linked to any individual player.

45ph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS Encryption in Transit: All data transmitted between your device and the 45ph platform is encrypted using current industry-standard SSL/TLS protocols.
• Encryption at Rest: Sensitive personal and financial data stored in 45ph databases is encrypted using AES-256 or equivalent encryption standards.
• Password Security: Account passwords are processed through a one-way cryptographic hashing function before storage. 45ph staff cannot see your plaintext password.
• Access Controls: Access to personal data is restricted on a need-to-know basis. 45ph staff who do not require access to personal data for their role cannot access it.
• Intrusion Detection: The 45ph platform monitors for unauthorised access attempts, unusual login patterns, and other indicators of security threats.
• Regular Security Reviews: 45ph conducts periodic reviews of its security infrastructure, data handling procedures, and vendor security practices.

As a data subject 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 45ph holds personal data about you and to receive information about how that data is being processed — as provided in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data that 45ph holds about you and information about how it is being used. 45ph will respond to access requests within 30 days.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your 45ph account settings. Changes to KYC-linked data require supporting documentation.
• Right to Erasure (Right to be Forgotten): The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected. This right is subject to 45ph's legal retention obligations — data we are required by law to retain (KYC records, transaction records) cannot be deleted on request during the mandatory retention period.
• Right to Object: The right to object to processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time through your account notification settings or by contacting support.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format where technically feasible and where the processing is based on consent or contract.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe 45ph has violated your data protection rights. Contact information for the NPC is available on the NPC's official website.

To exercise any of these rights, contact 45ph's Data Protection Officer using the details in Section 16. Requests will be acknowledged within 5 business days and processed within 30 calendar days, or we will inform you of an extension where more time is required.

If 45ph discovers that personal data has been collected from a person under 21 years of age without appropriate parental or guardian consent, that account will be immediately suspended, the data will be deleted (subject to any legal reporting obligations arising from underage access), and any deposits will be returned to the original payment source where technically feasible.

If you are a parent or guardian and believe your minor child has created a 45ph account, contact our support team immediately at [email protected]. We will investigate and take appropriate action within 48 hours.

Where you have provided consent during account registration or subsequently through your account communication preferences, 45ph may send you marketing communications about 45ph promotions, new games, bonus offers, and platform updates via:

• Email to your registered 45ph email address
• SMS to your registered mobile number
• In-platform notifications within your 45ph account dashboard

You may withdraw your consent to marketing communications at any time by:

• Updating your communication preferences in the Notifications section of your 45ph account settings
• Clicking the unsubscribe link in any 45ph marketing email
• Contacting 45ph support via live chat and requesting removal from marketing communications

Withdrawal of marketing consent does not affect your ability to receive transactional and account-essential communications — such as deposit confirmations, withdrawal notifications, security alerts, KYC requests, and account status updates — which are sent regardless of marketing preferences as they are necessary for account management.

The 45ph platform may engage service providers and use infrastructure located outside the Philippines — including cloud computing providers and game software studios based in other jurisdictions. Where personal data is transferred outside the Philippines, 45ph takes steps to ensure that such transfers comply with the Philippine Data Privacy Act, including:

• Entering into data processing agreements with recipient parties that impose data protection obligations equivalent to those required under Philippine law.
• Using service providers that maintain recognised data security certifications (such as ISO 27001) or operate under equivalent legal frameworks.
• Limiting data transfers to only the data categories necessary for the specific service being provided.

Details of the countries to which data may be transferred and the safeguards in place are available upon request by contacting 45ph's Data Protection Officer.

45ph reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. When material changes are made, we will:

• Update the "Last Updated" date at the top of this Policy.
• Notify registered players of material changes via email to the address on file, at least 14 days before the updated Policy takes effect, except where an immediate change is required by a legal obligation.
• Where required by the Philippine Data Privacy Act, seek fresh consent for any new purposes of processing that were not covered by your original consent.

We encourage you to review this Privacy Policy periodically. The version currently published at 45ph.club/privacy-policy is always the controlling version. Continued use of the 45ph platform after the effective date of changes constitutes acceptance of the updated Policy.

For all privacy-related inquiries, requests to exercise your data subject rights, or concerns about 45ph's data handling practices, please contact our designated Data Protection Officer: