Privacy Policy

1. Data Controller

aa45ph is the data controller responsible for your personal data as processed through the aa45ph.app platform. As data controller, aa45ph determines the purposes and means by which your personal data is processed and is accountable for its lawful, fair, and transparent handling in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission of the Philippines.

For all privacy-related enquiries, requests, or complaints, you may contact aa45ph's designated Data Protection Officer at: [email protected]. Please include "Privacy / DPO" in the subject line of your message.

2. Personal Data We Collect

aa45ph collects personal data that is necessary, adequate, and not excessive relative to the purposes for which it is collected. The categories of personal data we collect include:

We do not collect special categories of sensitive personal data (such as racial or ethnic origin, religious beliefs, or health data) unless specifically required by PAGCOR regulatory obligations or applicable law.

3. How We Use Your Personal Data

aa45ph uses your personal data for the following purposes:

• Account management: Creating, maintaining, and managing your aa45ph player account, including processing your registration, verifying your identity, and enabling aa45ph login access.
• Service delivery: Providing access to games, sports betting markets, promotions, and all other platform features you use.
• Financial processing: Processing GCash, Maya, and bank deposits and withdrawals; reconciling transactions; issuing winnings; and maintaining accurate financial records.
• KYC & AML compliance: Verifying your identity and age (21+ as required by PAGCOR), screening against PAGCOR and AMLC (Anti-Money Laundering Council) watch lists, and complying with Republic Act No. 9160 (AMLA) obligations.
• Responsible gaming: Monitoring gaming behaviour for indicators of problem gambling; administering self-exclusion and deposit limit requests; and communicating responsible gaming support resources.
• Security & fraud prevention: Detecting, investigating, and preventing fraudulent activity, unauthorised account access, multi-accounting, and platform abuse.
• Customer support: Responding to queries, complaints, and account issues submitted via live chat or email.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to registered players who have opted in. You may opt out at any time via your account settings.
• Legal & regulatory compliance: Meeting aa45ph's obligations under its PAGCOR licence, Philippine gaming law, the Data Privacy Act, and any applicable court or regulatory order.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act and its Implementing Rules, aa45ph processes your personal data on the following lawful bases:

• Contractual necessity: Processing required to enter into and perform the Player Agreement (aa45ph's Terms & Conditions), including account creation, game access, and financial transactions.
• Legal obligation: Processing required to comply with PAGCOR licence conditions, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine law.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your rights and freedoms.
• Consent: Processing for direct marketing communications and any non-essential cookies, where aa45ph relies on your consent as the lawful basis. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

aa45ph does not sell your personal data to third parties. We may disclose your personal data to the following categories of recipients where necessary and proportionate:

• PAGCOR: As required under our gaming licence conditions, including mandatory reporting of suspicious transactions and regulatory enquiries.
• AMLC (Anti-Money Laundering Council): As required under Republic Act No. 9160 for covered transaction and suspicious transaction reports.
• Payment processors: GCash (GXI), Maya (PayMaya Philippines Inc.), and partner banks (BPI, BDO, Metrobank) solely for processing your deposits and withdrawals.
• Game content providers: Certified third-party game studios (e.g., Pragmatic Play, PG Soft, Evolution) receive the minimum technical data necessary to deliver game functionality. These providers operate under data processing agreements with aa45ph.
• KYC verification providers: Third-party identity verification services that assist aa45ph in validating government-issued IDs and conducting age verification checks.
• Legal and regulatory authorities: Courts, law enforcement agencies, and regulatory bodies where disclosure is required by applicable Philippine law or a valid court order.

All third-party service providers that process personal data on behalf of aa45ph are bound by data processing agreements that require them to process data only as instructed, to maintain appropriate security measures, and to comply with the Data Privacy Act.

6. Cookies & Tracking Technologies

The aa45ph platform uses cookies and similar tracking technologies to operate and improve platform functionality, maintain your login session, remember preferences, and analyse platform usage patterns. The categories of cookies we use are:

• Strictly necessary cookies: Essential for the platform to function — including maintaining your authenticated aa45ph login session, security tokens, and load-balancing cookies. These cannot be disabled without breaking core functionality.
• Analytics cookies: Collect aggregated, anonymised data about how players interact with the platform, which pages are visited, and session duration. This data is used to improve the platform experience.
• Preference cookies: Store your platform preferences such as language settings and responsible gaming limits display.

You may manage non-essential cookies via the Cookie Settings option in your account or through your browser's privacy controls. Note that disabling strictly necessary cookies will prevent you from accessing the platform.

7. Data Retention

aa45ph retains your personal data only for as long as necessary to fulfil the purposes set out in this Policy, subject to the following minimum retention periods mandated by applicable law and our PAGCOR licence:

• Account and identity data: Retained for a minimum of 5 years after account closure, as required by PAGCOR and applicable Philippine gaming regulations.
• Financial transaction records: Retained for a minimum of 5 years after the transaction date, as required under Philippine AMLA obligations.
• Gaming activity records: Retained for a minimum of 3 years after the last gaming activity, for regulatory audit and responsible gaming monitoring purposes.
• Customer support records: Retained for 2 years after the resolution of a support interaction.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

8. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by aa45ph:

• Right to be informed: The right to be told what personal data we hold about you and how it is used — which this Policy addresses.
• Right of access: The right to request a copy of the personal data we hold about you, along with information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of personal data where it is no longer necessary for the purpose for which it was collected — subject to overriding retention obligations under law and our PAGCOR licence.
• Right to object: The right to object to processing of your personal data for direct marketing purposes at any time, without providing a reason.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to file a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, submit a written request to [email protected] with the subject line "Data Subject Rights Request." aa45ph will respond within 15 business days of receiving a valid, complete request.

9. Data Security

aa45ph employs industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. Our security framework includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and aa45ph servers;
• Encryption of sensitive data at rest, including financial data and government ID copies;
• Role-based access controls limiting employee access to personal data to those with a legitimate operational need;
• Mandatory two-factor authentication for all aa45ph administrative system access;
• Regular third-party penetration testing and vulnerability assessments;
• Data breach response procedures aligned with the National Privacy Commission's mandatory breach notification requirements.

In the event of a personal data breach that is likely to result in risk to your rights and freedoms, aa45ph will notify you and the National Privacy Commission within 72 hours of becoming aware of the breach, in accordance with NPC Circular 16-03.

10. Children's Privacy — 21+ Requirement

The aa45ph platform is strictly for adults aged 21 years or older, as mandated by PAGCOR. aa45ph does not knowingly collect personal data from individuals under 21 years of age. Age verification is conducted as part of the mandatory KYC process before any real-money gaming is permitted.

If aa45ph becomes aware that personal data has been collected from a person under 21 years of age, such data will be immediately deleted and the relevant account terminated. Parents or guardians who believe their child has registered on the aa45ph platform should contact [email protected] immediately.

11. Third-Party Links

The aa45ph platform may contain links to third-party websites or services — including payment gateways such as GCash and Maya — that operate independently and have their own privacy policies. aa45ph is not responsible for the privacy practices, content, or security of any third-party platform, and this Policy does not extend to data collected by such platforms. We encourage you to review the privacy policy of any third-party service before providing personal data.

12. Changes to This Privacy Policy

aa45ph may update this Privacy Policy from time to time to reflect changes in our data processing practices, PAGCOR regulatory requirements, the Data Privacy Act's implementing rules, or our platform operations. Material changes will be communicated to registered players via email to their registered address and/or a prominent notice on the platform, no fewer than 7 days before the change takes effect.

The date of the most recent revision is displayed at the top of this Policy. Continued use of the aa45ph platform following the effective date of any revision constitutes acceptance of the updated Policy.