a45com Privacy
Policy

Welcome to the a45com Privacy Policy. a45com ("we," "us," "our") is committed to protecting the personal data of every player who uses our platform. This Privacy Policy describes how a45com collects, processes, stores, shares, and protects your personal information when you visit our website, register an account, or use any of our gaming services.

This policy applies to all a45com products and services, including our live casino, slot games, bingo rooms, dice games, mega fishing titles, and sportsbook. It covers data collected through our website, mobile platform, customer support channels, and any other touchpoint where you interact with a45com.

a45com operates in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. We are registered with the National Privacy Commission (NPC) of the Philippines as a personal information controller.

This Privacy Policy is written in English. In the event of any inconsistency between this English version and any translated version, the English version shall prevail. All official a45com communications with Filipino players are conducted in English.

a45com collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. We collect data in three primary ways: information you provide directly, information generated by your use of the platform, and information received from third parties.

Information you provide directly:

• Registration data: Full legal name, date of birth, residential address (including city — e.g., Manila, Cebu, Davao, Quezon City, Makati), email address, and Philippine mobile number.
• Identity verification (KYC) documents: Government-issued Philippine ID (e.g., PhilSys ID, passport, driver's license, UMID), selfie photographs, and proof of address documents.
• Payment information: GCash account details, PayMaya account details, BPI, BDO, or Metrobank account numbers used for deposits and withdrawals. Note: full card or bank account numbers are never stored on a45com servers.
• Communications: Messages sent to a45com via live chat, email, or any other support channel, including the content of your queries and our responses.
• Responsible gaming preferences: Deposit limits, session time limits, self-exclusion requests, and any other responsible gaming settings you configure on your account.

Information generated by your use of the platform:

• Technical data: IP address, device type, operating system, browser type and version, screen resolution, and time zone.
• Usage data: Pages visited, games played, session duration, bet history, transaction history, and feature interactions.
• Cookie and tracking data: As described in Section 6 of this policy.

Information received from third parties:

• Identity verification providers: Results of automated KYC checks performed by our third-party identity verification partners.
• Payment processors: Transaction confirmation data from GCash, PayMaya, and banking partners.
• Fraud prevention services: Risk scores and fraud indicators from our anti-fraud and AML compliance partners.

a45com uses your personal data only for legitimate, clearly defined purposes. We do not process your data in ways that are incompatible with the purposes for which it was originally collected. The following table outlines the primary purposes for which a45com processes your personal data.

• Account creation and management: To register your a45com account, verify your identity, and maintain your player profile throughout your relationship with us.
• Service delivery: To provide access to a45com games, process deposits and withdrawals in Philippine Peso, and deliver the full range of platform features.
• KYC and age verification: To verify that you are at least 21 years of age and to comply with our Know Your Customer obligations under Philippine gaming regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other prohibited conduct on the a45com platform.
• Customer support: To respond to your queries, resolve disputes, and provide technical assistance through our 24/7 support channels.
• Responsible gaming: To monitor gaming patterns, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of problem gambling.
• Legal and regulatory compliance: To meet our obligations under Philippine law, including anti-money laundering (AML) reporting, tax compliance, and regulatory audits.
• Platform improvement: To analyze usage patterns, identify technical issues, and improve the overall a45com gaming experience for Filipino players.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your consent or where we have a legitimate interest to do so. You may opt out at any time.

Under the Philippine Data Privacy Act of 2012, a45com must have a lawful basis for processing your personal data. The following legal bases apply to our processing activities:

• Contractual necessity: Processing required to fulfill our obligations under the a45com Terms & Conditions, including account management, game delivery, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and regulatory reporting.
• Legitimate interests: Processing carried out for a45com's legitimate business interests, such as fraud prevention, platform security, and service improvement — provided these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Where a45com relies on legitimate interests as the legal basis for processing, we conduct a balancing test to ensure that our interests do not override your fundamental rights. The results of these assessments are documented and available to our Data Protection Officer upon request.

a45com does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your data only in the limited circumstances described below, and only to the extent necessary for the stated purpose.

• Service providers and processors: Third-party companies that provide services on our behalf, including KYC verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), cloud hosting providers, fraud detection services, and customer support platform providers. All processors are bound by data processing agreements that require them to protect your data to the same standard as a45com.
• Game providers: Where technically necessary, limited technical data (such as session tokens) may be shared with a45com's game providers to facilitate gameplay. Game providers do not receive your full personal profile.
• Regulatory and law enforcement authorities: a45com may disclose your personal data to Philippine government agencies, regulatory bodies, or law enforcement authorities where required by law or where we have a good-faith belief that disclosure is necessary to prevent fraud, money laundering, or other criminal activity.
• Responsible gaming bodies: In cases of confirmed problem gambling or self-exclusion, limited data may be shared with recognized responsible gaming organizations in the Philippines to support player protection programs.
• 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. You will be notified of any such transfer and your rights will be preserved.

a45com uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze usage patterns, and deliver a personalized gaming experience. A cookie is a small text file placed on your device when you visit the a45com website.

We use the following categories of cookies:

You can manage your cookie preferences at any time through the a45com cookie preference center, accessible from the footer of any page on the platform. You may also control cookies through your browser settings; however, disabling strictly necessary cookies may affect your ability to use the platform.

a45com does not use cookies to track your activity on third-party websites or to build advertising profiles for sale to external parties.

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

• Active account data: Retained for the duration of your a45com account and for a minimum of five (5) years following account closure, in accordance with Philippine AML and gaming regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine financial regulations.
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the business relationship.
• Customer support communications: Retained for three (3) years from the date of the last interaction, unless the communication relates to an ongoing dispute or legal matter.
• Marketing consent records: Retained for the duration of your consent and for three (3) years following withdrawal of consent, as evidence of compliance.
• Analytics and usage data: Retained in aggregated, anonymized form indefinitely for platform improvement purposes. Identifiable usage data is retained for a maximum of two (2) years.

When your personal data is no longer required, a45com will securely delete or anonymize it in accordance with our data disposal procedures. Anonymized data that can no longer be linked to you may be retained indefinitely for statistical and research purposes.

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

• Encryption: All data transmitted between your device and a45com servers is protected using TLS 1.3 encryption. Data stored on our servers is encrypted using AES-256.
• Access controls: Access to personal data is restricted to a45com employees and contractors who require it to perform their job functions. All access is logged and subject to regular audit.
• Two-factor authentication: a45com supports OTP-based 2FA for all player accounts, delivered to your registered Philippine mobile number via SMS.
• Penetration testing: a45com's platform undergoes regular security assessments and penetration testing by independent cybersecurity professionals.
• Incident response: a45com maintains a documented data breach response plan. In the event of a breach affecting your personal data, we will notify you and the National Privacy Commission within the timeframes required by Philippine law.
• Staff training: All a45com employees who handle personal data receive regular data privacy and security training.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by a45com. We are committed to honoring these rights promptly and without undue burden to you.

• Right to be informed: You have the right to know what personal data a45com holds about you, how it is being used, and with whom it is shared. This Privacy Policy fulfills our primary obligation under this right.
• Right of access: You may request a copy of the personal data a45com holds about you. We will provide this within thirty (30) days of a verified request.
• Right to rectification: If any personal data a45com holds about you is inaccurate or incomplete, you have the right to request correction. You may update most account details directly through your a45com account settings, or contact our support team for assistance.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent, or where processing is unlawful. Note that certain data must be retained to comply with Philippine legal and regulatory obligations and cannot be deleted on request.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, though a45com may continue processing where we can demonstrate compelling legitimate grounds.
• Right to data portability: Where processing is based on your consent or on a contract, you may request that a45com provide your personal data in a structured, commonly used, machine-readable format so that you can transfer it to another service provider.
• Right to lodge a complaint: If you believe a45com has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. We encourage you to contact us first so we can attempt to resolve the matter directly.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 13 of this policy. We may need to verify your identity before processing your request. We will respond to all verified data subject requests within thirty (30) calendar days. Where a request is complex or involves a large volume of data, we may extend this period by a further thirty (30) days, and will notify you accordingly.

a45com is an online gaming platform intended exclusively for adults. In the Philippines, the minimum legal age to participate in casino-style gambling is 21 years old. a45com strictly enforces this age restriction and does not knowingly collect personal data from individuals under the age of 21.

All a45com account registrations require date of birth verification, and our KYC process includes mandatory age verification using government-issued Philippine identification documents. Any account found to belong to a person under 21 years of age will be immediately suspended, all funds will be returned, and the account will be permanently closed.

a45com supports the responsible gaming initiatives of PAGCOR and encourages all Filipino parents and guardians to use parental control tools to prevent underage access to online gaming platforms.

The a45com platform may contain references to third-party services, such as payment processors and game providers, that operate under their own privacy policies. a45com is not responsible for the privacy practices of these third parties, and this Privacy Policy does not apply to their data processing activities.

When you use a third-party payment service such as GCash or PayMaya to fund your a45com account, your transaction data is processed by that provider in accordance with their own privacy policy. a45com only receives confirmation of the transaction outcome and does not have access to your full payment credentials.

We encourage you to review the privacy policies of any third-party services you use in connection with your a45com account. If you have concerns about how a third-party provider handles your data, please contact that provider directly.

a45com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When material changes are made, we will notify registered players via email or an in-platform notification at least seven (7) days before the changes take effect.

The effective date at the top of this policy will always reflect the date of the most recent update. We encourage you to review this Privacy Policy periodically to stay informed about how a45com protects your personal data.

Your continued use of the a45com platform after any update to this Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you must stop using the platform and may request account closure by contacting our support team.

a45com has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data, please contact our DPO through any of the following channels:

• Email: [email protected] — For all data subject requests, privacy complaints, and DPO inquiries. We aim to acknowledge all emails within two (2) business days.
• General Support Email: [email protected] — For general account and platform queries that do not relate specifically to data privacy.
• Live Chat: Available 24/7 directly from the a45com platform. Our Filipino support agents can assist with general privacy queries and escalate formal data subject requests to the DPO.
• Formal written requests: Please use the subject line "Data Subject Request — [Your Account Username]" when submitting formal requests by email to ensure priority handling by our compliance team.

If you are not satisfied with a45com's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. The NPC is the independent government body responsible for enforcing the Data Privacy Act of 2012 and protecting the data privacy rights of all Filipinos.

Our support team is staffed by Filipino agents who are fluent in English and Filipino. We are committed to resolving all privacy concerns fairly, transparently, and in accordance with Philippine law.