Privacy Policy – How a45com Protects Your Data

1 Introduction

a45com ("we," "us," or "our") is committed to protecting the privacy and personal data of all users of the a45com platform, including its website, mobile interface, games, and related services (collectively, the "Platform"). This Privacy Policy describes how a45com collects, uses, stores, shares, and protects your personal information when you access or use the Platform.

This Policy applies to all registered players, visitors, and any other individuals who interact with the a45com Platform in any capacity. By registering on or using a45com, 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.

This Privacy Policy should be read together with the a45com Terms & Conditions, which govern your use of the Platform. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

2 Personal Data We Collect

a45com collects the following categories of personal data from users of the Platform:

2.1 Identity & Contact Information

Full legal name
Date of birth (for age verification purposes — players must be 21 years of age or older)
Nationality and country of residence
Email address
Mobile phone number
Residential address

2.2 Identity Verification Documents

Government-issued photo identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, PRC ID)
Proof of address documents (e.g., utility bill, bank statement)
Proof of payment method ownership (e.g., screenshot of GCash or Maya account)

2.3 Financial Information

Deposit and withdrawal transaction records
Payment method details (GCash mobile number, Maya account reference, bank account details — stored in tokenized or reference form only)
Account balance history

2.4 Gaming Activity Data

Game session history, bet amounts, and outcomes
Bonus and promotion usage records
Responsible gaming settings and self-exclusion records

2.5 Technical & Usage Data

IP address and approximate geolocation
Device type, operating system, and browser information
Pages visited, features used, and time spent on the Platform
Login timestamps and session duration

2.6 Communications Data

Records of communications with a45com support (live chat transcripts, email correspondence)
Feedback and survey responses

3 How We Collect Your Data

a45com collects personal data through the following means:

Directly from you: When you register an account, complete KYC verification, make deposits or withdrawals, contact support, or participate in promotions.
Automatically: When you use the Platform, we automatically collect technical and usage data through cookies, log files, and similar tracking technologies. See Section 9 for more details on cookies.
From third parties: We may receive data about you from third-party KYC verification providers, payment processors (such as GCash and Maya), fraud prevention services, and regulatory authorities where required by law.
From your device: With your permission, we may collect device-level information such as your approximate location to assist with fraud detection and regulatory compliance.

4 How We Use Your Personal Data

a45com uses the personal data we collect for the following purposes:

4.1 Account Management & Service Delivery

To create, maintain, and manage your a45com account.
To verify your identity and age (21+ requirement) in compliance with PAGCOR responsible gaming guidelines.
To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card.
To provide access to games, promotions, and other Platform features.
To deliver customer support and respond to your inquiries.

4.2 Legal & Regulatory Compliance

To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations under Republic Act No. 9160 (Anti-Money Laundering Act) and its amendments.
To fulfill KYC obligations and report suspicious transactions to relevant authorities where required by law.
To maintain records as required by PAGCOR and other regulatory bodies.

4.3 Security & Fraud Prevention

To detect, investigate, and prevent fraudulent activity, cheating, collusion, and other prohibited conduct.
To monitor for unauthorized access to your account and protect the integrity of the Platform.
To enforce the a45com Terms & Conditions.

4.4 Responsible Gaming

To administer responsible gaming tools including deposit limits, session time limits, and self-exclusion requests.
To identify players who may be exhibiting signs of problem gambling and to take appropriate action in accordance with our Responsible Gaming Policy.

4.5 Platform Improvement & Analytics

To analyze usage patterns and improve the functionality, performance, and user experience of the a45com Platform.
To conduct internal research and develop new features and services.

4.6 Marketing Communications

To send you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications.
You may opt out of marketing communications at any time by updating your account preferences or contacting a45com support.

5 Legal Basis for Processing

a45com processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations:

Contractual necessity: Processing is necessary to perform our obligations under the a45com Terms & Conditions, including account management, payment processing, and service delivery.
Legal obligation: Processing is required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and PAGCOR regulatory directives.
Legitimate interests: Processing is necessary for the legitimate interests of a45com, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
Consent: For certain processing activities, such as marketing communications and the use of non-essential cookies, we rely on your explicit consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing & Disclosure

a45com does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

Payment processors: GCash, Maya, and banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) receive transaction data necessary to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable data protection obligations.
KYC and identity verification providers: Third-party services that assist a45com in verifying your identity and age in compliance with regulatory requirements.
Fraud prevention and security services: Providers that help a45com detect and prevent fraudulent activity, money laundering, and other prohibited conduct on the Platform.
Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government bodies where disclosure is required by law or court order.
Professional advisors: Legal counsel, auditors, and other professional advisors engaged by a45com, subject to strict confidentiality obligations.
Business transfers: In the event of a merger, acquisition, or sale of all or part of a45com's business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third parties with whom a45com shares personal data are required to handle that data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than those specified by a45com.

7 Data Security

a45com implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

SSL/TLS encryption: All data transmitted between your device and the a45com Platform is encrypted using industry-standard SSL/TLS protocols.
Data encryption at rest: Sensitive personal data stored on a45com servers is encrypted using strong encryption algorithms.
Access controls: Access to personal data is restricted to authorized a45com personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
Two-factor authentication: a45com supports two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
Regular security audits: a45com conducts regular security assessments and penetration testing to identify and address potential vulnerabilities in the Platform.
Incident response: In the event of a personal data breach, a45com will notify affected users and the National Privacy Commission (NPC) in accordance with the requirements of the Data Privacy Act of 2012.

While a45com takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the security of your a45com account credentials and for notifying us immediately of any suspected unauthorized access.

8 Data Retention

a45com retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

Account data: Retained for the duration of your active account and for a period of five (5) years following account closure, in compliance with AML record-keeping requirements.
KYC and identity verification documents: Retained for a minimum of five (5) years from the date of verification, as required by the Anti-Money Laundering Act.
Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction.
Gaming activity data: Retained for a period of three (3) years from the date of the relevant gaming session.
Support communications: Retained for a period of two (2) years from the date of the communication.
Marketing consent records: Retained until you withdraw your consent or for a period of three (3) years from the date of consent, whichever is earlier.

Upon expiry of the applicable retention period, a45com will securely delete or anonymize your personal data in accordance with its data disposal procedures.

9 Cookies & Tracking Technologies

a45com uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The following types of cookies are used:

Essential cookies: These cookies are strictly necessary for the Platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled without affecting Platform functionality.
Analytics cookies: These cookies help a45com understand how users interact with the Platform by collecting aggregated, anonymized usage data. This information is used to improve Platform performance and user experience.
Functional cookies: These cookies remember your preferences and settings (such as language and display preferences) to provide a more personalized experience.
Security cookies: These cookies assist in detecting and preventing fraudulent activity and unauthorized access to your account.

Non-essential cookies (analytics and functional) are only placed on your device with your consent. You may manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the a45com Platform.

a45com does not use cookies to serve third-party advertising or to track your activity across unrelated websites.

10 Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by a45com:

Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
Right of access: You have the right to request a copy of the personal data that a45com holds about you, along with information about how it is being processed.
Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data that a45com holds about you.
Right to erasure: You have 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 applicable legal retention requirements.
Right to object: You have 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: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that a45com has violated your data privacy rights.

To exercise any of the above rights, please contact the a45com Data Privacy Officer at the contact details provided in Section 13 of this Policy. a45com will respond to all verified data privacy requests within thirty (30) days of receipt.

11 Children's Privacy

The a45com Platform is strictly intended for adults aged 21 years and older, in accordance with Philippine regulations governing casino-style gambling. a45com does not knowingly collect personal data from individuals under the age of 21.

If a45com becomes aware that it has inadvertently collected personal data from a person under the age of 21, it will take immediate steps to delete that data and close the associated account. Any winnings accrued by an underage user will be forfeited.

If you are a parent or guardian and believe that your child has registered on a45com or provided personal data to the Platform, please contact a45com support immediately so that appropriate action can be taken.

Gambling is addictive. Know when to stop. For players 21 years and older only.

12 Updates to This Privacy Policy

a45com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, a45com will notify registered users via the email address associated with their account and/or by displaying a prominent notice on the Platform.

The effective date of the most recent version of this Privacy Policy is displayed at the top of this page. Your continued use of the a45com Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the changes.

We encourage you to review this Privacy Policy periodically to stay informed about how a45com is protecting your personal data.

13 Contact & Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by a45com, please contact our Data Privacy Officer using the details below. Our team is available 24 hours a day, 7 days a week.

Email: [email protected]
General Support Email: [email protected]
Live Chat: Available directly through the a45com Platform after logging in to your account.

When submitting a data privacy request, please include your registered username, a clear description of your request, and any relevant supporting information. a45com will acknowledge all data privacy requests within five (5) business days and provide a full response within thirty (30) days.

If you are not satisfied with a45com's response to your data privacy request, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.

a45com Privacy Policy

How a45com Protects Your Privacy

SSL Encryption

No Data Selling

Minimal Data Collection

Your Data Rights

Defined Retention Periods

DPA Compliance

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