aa45ph Privacy Policy

1.1 This Privacy Policy ("Policy") describes how aa45ph ("the Platform", "We", "Us", "Our") collects, processes, stores, shares, and protects the personal data of individuals ("Players", "Users", "You") who register for or use the aa45ph online gaming platform, accessible at aa45ph.org.

1.2 This Policy applies to all personal data collected through the aa45ph website, any mobile web interface, account management portal, customer support channels, and any other interaction between aa45ph and a registered or prospective player.

1.3 This Policy should be read alongside the aa45ph Terms and Conditions, available at aa45ph.org/terms-conditions, which govern the overall legal relationship between aa45ph and its players. Together, these two documents form the complete framework governing your use of the platform.

1.4 By registering an account with aa45ph, or by continuing to use the platform after this Policy has been updated, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

1.5 If you have questions about any aspect of this Policy, or if you wish to exercise any of your data subject rights, please contact our Data Protection Officer using the details provided in Section 15 of this document.

2.1 For the purposes of the Philippine Data Privacy Act of 2012, aa45ph acts as the personal information controller ("PIC") with respect to the personal data of its registered players and website visitors.

2.2 As the personal information controller, aa45ph determines the purposes for which personal data is collected and the means by which it is processed. aa45ph is responsible for ensuring that personal data processing activities are lawful, proportionate, and consistent with the purposes disclosed in this Policy.

2.3 aa45ph has designated a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act. The DPO is responsible for overseeing data protection compliance, responding to data subject requests, and liaising with the National Privacy Commission where required. DPO contact details are provided in Section 15.

3.1 aa45ph collects the following categories of personal data from players:

• Full legal name as it appears on your government-issued identification
• Date of birth (for age verification purposes — players must be 21 or older)
• Philippine mobile number (09xxxxxxxxx format)
• Email address
• Username and hashed account password

• Copies of government-issued identification documents (Passport, Driver's License, UMID, SSS ID, PhilSys National ID, or PRC ID)
• Selfie photographs submitted for facial verification
• Proof of address documentation where required

• GCash or Maya account number (used for deposits and withdrawals)
• Bank account details where bank transfer is used (BPI, BDO, Metrobank, UnionBank)
• Transaction history including deposit amounts, withdrawal requests, and timestamps
• Partial card details where Visa or Mastercard is used (full card numbers are not stored by aa45ph)

• Device type, operating system, browser type, and version
• IP address and approximate geolocation (province/city level)
• Login and session timestamps
• Game play records including games played, wager amounts, outcomes, and session duration
• Interaction with bonus and promotion features
• Customer support chat and email records

• Deposit limit settings and modification history
• Self-exclusion records, cooling-off period activations, and session alert preferences
• Responsible gaming flags raised by the platform's monitoring systems

3.2 Data You Provide Voluntarily. In addition to the above, aa45ph may collect additional information you choose to provide through support interactions, feedback forms, or promotional participation, subject to the terms of specific data collection activities.

4.1 aa45ph uses the personal data described in Section 3 for the following specific purposes:

4.2 Marketing Communications. Where you have provided consent to receive promotional communications from aa45ph, we may use your email address or mobile number to send information about bonuses, promotions, new game launches, and other aa45ph platform updates. You may withdraw your consent to marketing communications at any time by contacting support at [email protected] or by following the unsubscribe instructions included in each communication.

4.3 No Automated Decision-Making with Legal Effect. aa45ph does not make decisions that produce legal or similarly significant effects on individual players solely through automated processing, without human review. Fraud detection flags and responsible gaming alerts generated by automated systems are reviewed by aa45ph compliance staff before action is taken on an individual account.

5.1 aa45ph processes personal data under one or more of the following legal bases as recognised under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform the agreement between aa45ph and the player — including account creation, game access, payment processing, and customer support.
• Legal Obligation: Processing required to comply with applicable Philippine law, including anti-money laundering obligations, age verification requirements, and tax reporting obligations.
• Legitimate Interests: Processing conducted for aa45ph's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and platform improvement, where these interests are not overridden by your rights and freedoms.
• Consent: Processing conducted on the basis of your freely given, specific, and informed consent — including marketing communications and certain non-essential data collection activities. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

6.1 aa45ph does not sell, rent, or trade personal data to third parties for marketing or commercial purposes. Data is shared with third parties only in the following circumstances:

aa45ph engages the following categories of third-party service providers who process personal data on our behalf under data processing agreements:

• Payment Processors: GCash (G-Xchange Inc.), Maya (Voyager Innovations), BPI, BDO, Metrobank, and other payment providers — to process deposits and withdrawals.
• Game Providers: Licensed game development studios (e.g., Pragmatic Play, JILI, PG Soft) — to facilitate game sessions and resolve game disputes.
• KYC and Identity Verification Providers: Third-party identity verification services used to authenticate government ID documents and facial verification photographs.
• Fraud Detection Services: Third-party risk management platforms used to detect and prevent fraudulent activity, money laundering, and account compromise.
• Cloud Infrastructure Providers: Hosting and data storage infrastructure providers who maintain the servers on which aa45ph data is stored, under strict security and confidentiality obligations.

aa45ph may disclose personal data to Philippine government authorities, law enforcement agencies, or regulatory bodies — including the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and relevant gaming regulators — where required by applicable law or valid legal process.

In the event of a merger, acquisition, asset sale, or restructuring of aa45ph's business, player personal data may be transferred to the acquiring entity as part of the transaction, subject to equivalent data protection obligations being assumed by the acquirer.

7.1 aa45ph uses cookies and similar technologies on the platform. A cookie is a small text file placed on your device when you visit a website. The following categories of cookies are used by aa45ph:

7.2 aa45ph does not use third-party advertising cookies, tracking pixels from social media platforms, or any cookies that build advertising profiles based on your platform activity.

7.3 You may manage or disable non-essential cookies through your browser's privacy settings. Note that disabling essential or security cookies will prevent you from using the aa45ph platform normally.

8.1 aa45ph retains personal data for the period necessary to fulfil the purpose for which it was collected, subject to minimum retention requirements imposed by applicable Philippine law.

8.2 The following general retention periods apply to different categories of personal data held by aa45ph:

• Account Registration Data: Retained for the duration of the active account relationship, plus five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements.
• KYC Identity Documents: Retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later, in compliance with AMLC requirements applicable to covered entities.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required under Philippine AML legislation.
• Game Play Records: Retained for three (3) years from the date of each session, to support dispute resolution and responsible gaming monitoring.
• Customer Support Records: Retained for three (3) years from the date of the interaction, to support quality assurance and dispute resolution.
• Marketing Consent Records: Retained for the duration of the marketing relationship and for two (2) years following withdrawal of consent.

8.3 Following the expiry of applicable retention periods, personal data is securely deleted or anonymised so that it can no longer be attributed to an individual player.

9.1 aa45ph implements a range of technical and organisational security measures to protect player personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• Encryption in Transit: All data transmitted between your device and aa45ph servers is encrypted using Transport Layer Security (TLS) 1.3 protocol. This applies to login sessions, payment data, KYC document uploads, and all other platform communications.
• Encryption at Rest: Sensitive personal data stored on aa45ph servers — including identity documents and financial records — is encrypted at rest using industry-standard AES-256 encryption.
• Password Security: Account passwords are never stored in plain text. Passwords are hashed using a salted cryptographic hash function. aa45ph staff cannot view your password.
• Access Controls: Internal access to player personal data is governed by role-based access controls. Only authorised personnel with a defined business need may access specific categories of player data.
• Two-Factor Authentication: aa45ph offers optional two-factor authentication (2FA) for player accounts and requires 2FA for all internal staff access to systems containing personal data.
• Regular Security Assessments: aa45ph conducts periodic security assessments of its platform and data infrastructure, including vulnerability scans and access reviews.

9.2 Player Responsibility. While aa45ph maintains robust security infrastructure, the security of your account also depends on the steps you take to protect your aa45ph Login credentials. You should use a strong, unique password for your aa45ph account, enable two-factor authentication, and never share your credentials with any other person.

9.3 Reporting Security Concerns. If you believe your aa45ph account has been compromised, or if you identify a security vulnerability on the platform, please contact us immediately at [email protected].

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by aa45ph. All requests to exercise these rights should be submitted in writing to [email protected].

10.2 aa45ph will respond to all data subject requests within fifteen (15) business days of receiving a verified request. In complex cases, this period may be extended to thirty (30) days with notice provided to the requester.

10.3 For identity verification purposes, aa45ph may require you to confirm your identity before fulfilling a data subject request. This is to protect against unauthorised disclosure of your personal data to third parties.

11.1 The aa45ph platform is strictly for use by individuals aged twenty-one (21) years and older. aa45ph does not knowingly collect personal data from individuals under the age of 21.

11.2 If aa45ph becomes aware that personal data has been collected from an individual under the age of 21 — whether through registration misrepresentation or otherwise — the account will be immediately closed, all balances will be forfeited, and the personal data will be securely deleted to the extent not required to be retained for regulatory purposes.

11.3 Parents and guardians are responsible for ensuring that persons under the age of 21 do not access the aa45ph platform using their devices, accounts, or payment methods. If you believe a minor has accessed aa45ph using your account or device, contact support immediately at [email protected].

12.1 Some of aa45ph's third-party service providers — including game providers and cloud infrastructure partners — may be located in or may operate data centres outside the Philippines. Where personal data is transferred outside the Philippines, aa45ph takes steps to ensure that such transfers are conducted in accordance with the requirements of the Data Privacy Act, including:

• Entering into data transfer agreements with receiving entities that incorporate data protection standards equivalent to those required under Philippine law;
• Ensuring that receiving entities are in jurisdictions recognised as providing an adequate level of data protection; or
• Obtaining your explicit consent to the transfer where required.

12.2 aa45ph does not transfer personal data internationally for any purpose other than those described in this Policy and the legitimate operational needs of the platform.

13.1 In the event of a personal data breach — meaning any accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to personal data — aa45ph will:

• Assess the nature, scope, and likely consequences of the breach within twenty-four (24) hours of detection;
• Notify the National Privacy Commission of the Philippines of any breach likely to result in significant harm to affected data subjects, within seventy-two (72) hours of becoming aware of the breach;
• Notify affected players directly where the breach is likely to result in a high risk to their rights or interests, without undue delay following the initial assessment.

13.2 Breach notifications to players will include: a description of the nature of the breach; the categories and approximate number of records affected; contact details of aa45ph's DPO; the likely consequences of the breach; and the measures taken or proposed to address the breach.

13.3 aa45ph maintains an internal breach register documenting all personal data breaches, whether or not they result in notifications to the NPC or affected players, in accordance with its obligations under the Data Privacy Act.

14.1 aa45ph may update this Privacy Policy from time to time to reflect changes in our data processing practices, changes in applicable Philippine law, or changes to the services we provide. The most current version of this Policy is always available at aa45ph.org/privacy-policy.

14.2 Where updates to this Policy are material — meaning they significantly affect how your personal data is processed or your rights as a data subject — aa45ph will notify registered players via their registered email address or through a prominent notice on the platform prior to the changes taking effect.

14.3 The effective date shown in the header of this Policy reflects the date of the most recent update. Your continued use of the aa45ph platform after an update to this Policy constitutes your acknowledgment of the revised terms.

15.1 For any questions, concerns, or requests related to this Privacy Policy or the handling of your personal data by aa45ph, please contact our Data Protection Officer using the details below:

• Email: [email protected]
• Subject Line: Please include "Privacy / Data Request" in the subject line for DPO-related correspondence
• Response Window: Within fifteen (15) business days for standard requests
• Support Hours: 8:00 AM – 12:00 AM Philippine Time (PHT), 7 days a week

15.2 If you are not satisfied with aa45ph's response to a privacy concern or data subject request, you have the right to file a complaint with the National Privacy Commission of the Philippines. Information on the NPC complaints process is available on the NPC's official website.