ph45 Privacy
Policy

1. About This Policy

This Privacy Policy applies to all personal data collected by ph45 in connection with the operation of the ph45 online gaming platform, including all games, betting markets, promotional programmes, customer support interactions, payment processing, and any other services accessible at ph45.one.

By registering an account with ph45, completing the KYC (Know Your Customer) verification process, making a deposit, or simply visiting the ph45 website, 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 Policy should be read alongside the ph45 Terms & Conditions and the Responsible Gaming Policy, each of which forms part of your agreement with ph45.

2. Data Controller

ph45, operating the platform at https://ph45.one, is the data controller for all personal data processed in connection with player accounts, transactions, and platform usage. As data controller, ph45 determines the purposes and means of processing your personal data and is responsible for ensuring that processing is conducted lawfully, fairly, and transparently.

ph45 processes personal data in compliance with Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations as promulgated by the National Privacy Commission of the Philippines. ph45 maintains a registered Data Protection Officer (DPO) responsible for overseeing compliance with applicable data protection obligations.

3. Personal Data We Collect

ph45 collects the following categories of personal data from registered players and site visitors:

3.1 Identity and Contact Data

• Full legal name as it appears on a government-issued Philippine identification document
• Date of birth (for mandatory 21+ age verification)
• Registered Philippine mobile number
• Email address
• Residential address (for enhanced KYC and AML compliance)
• Copies of government-issued identification documents (PhilSys National ID, UMID, Driver's License, Passport, PRC ID, Voter's ID)
• Photographs or selfies submitted for biometric identity verification where required

3.2 Financial Data

• GCash account number linked to your registered Philippine mobile number
• PayMaya account details where provided
• Philippine bank account details (BPI, BDO, Metrobank, UnionBank) where used for deposits or withdrawals
• Transaction records including deposit amounts, withdrawal requests, and dates
• Source of funds declarations submitted for AML compliance purposes

3.3 Gaming and Account Activity Data

• Game play history including titles played, wager amounts, win/loss records, and session durations
• Bonus and promotion activity including opt-ins, usage, and wagering progress
• Account balance history and transaction ledger
• Responsible gaming tool settings including deposit limits and self-exclusion records
• Customer support interaction records including chat transcripts and email correspondence

3.4 Technical and Device Data

• IP address and geolocation data at time of login and transaction
• Device type, operating system, and browser version
• Mobile network operator (e.g., Globe, Smart, DITO, Sun)
• Session timestamps and duration logs
• Cookie identifiers and similar tracking data (see Section 12)

4. How We Collect Your Data

ph45 collects personal data through the following channels and methods:

• Account registration — information submitted when you create a ph45 account, including your name, date of birth, mobile number, and email address
• KYC verification — identity documents and additional personal information submitted in fulfilment of PAGCOR-mandated identity verification requirements
• Payment transactions — financial information captured when you make deposits or request withdrawals via GCash, PayMaya, or linked bank accounts
• Gameplay — automatically generated records of all game sessions, wagers, and outcomes recorded by the ph45 platform systems
• Customer support — information you provide when contacting ph45 via live chat, email, or any other support channel
• Automated technical means — cookies, session tokens, and server logs that capture device, network, and usage data when you access ph45
• Third-party verification services — identity and fraud screening results from KYC and AML service providers engaged by ph45

5. Legal Basis for Processing

ph45 processes your personal data on the following legal grounds under the Data Privacy Act of 2012:

6. How We Use Your Personal Data

ph45 uses the personal data we collect for the following purposes:

• Creating and maintaining your ph45 player account, including verifying your identity and age in accordance with PAGCOR's 21+ requirement
• Processing deposits and withdrawals through your nominated payment methods including GCash, PayMaya, and Philippine bank accounts
• Conducting ongoing AML transaction monitoring and filing Suspicious Transaction Reports (STRs) with the Anti-Money Laundering Council (AMLC) where legally required, without prior notification to the account holder
• Administering bonuses, promotions, and loyalty programme rewards including VIP tier management
• Providing customer support and resolving disputes related to your account, transactions, or game outcomes
• Enforcing responsible gaming tools including deposit limits, loss limits, session time controls, and self-exclusion, where these have been activated by you or imposed under PAGCOR requirements
• Detecting, investigating, and preventing fraud, cheating, collusion, and other prohibited conduct as defined in the ph45 Terms & Conditions
• Complying with all applicable PAGCOR regulations, NPC requirements, and other Philippine legal obligations
• Sending promotional communications, game updates, and personalised offers where you have provided consent to receive marketing communications
• Improving platform performance, game loading speeds, and user experience based on aggregated usage analytics

7. Disclosure to Third Parties

ph45 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, and only to the extent necessary for the stated purpose:

7.1 Regulatory and Law Enforcement Authorities

ph45 is required by Philippine law to disclose personal data and transaction records to: PAGCOR (regulatory oversight and player protection compliance), the Anti-Money Laundering Council (AMLC) (STR filings under RA 9160), the National Privacy Commission (NPC) (data breach notifications and compliance enquiries), and law enforcement agencies when served with valid legal process or court order.

7.2 Payment Processors and Financial Institutions

When you conduct a transaction on ph45, the minimum data necessary to process that transaction — including your registered mobile number or bank account details — is shared with GCash, PayMaya, and relevant Philippine banks solely for transaction processing purposes.

7.3 KYC and AML Service Providers

ph45 engages accredited third-party KYC verification and AML screening service providers to assist with identity verification and transaction monitoring. These providers process your identity data solely on behalf of ph45 and under strict data processing agreements.

7.4 Game Software Providers

Third-party game software providers whose titles are hosted on ph45 may receive technical session data (not personal identity data) necessary for game integrity logging and RNG certification purposes. No personally identifiable information is disclosed to game providers beyond what is technically required for game operation.

7.5 Professional Advisors

ph45 may share personal data with legal counsel, auditors, and compliance advisors where necessary for the defence or establishment of legal claims, or for regulatory compliance purposes. All such sharing is subject to professional confidentiality obligations.

8. International Data Transfers

ph45's primary operations are based in the Philippines, and player data is primarily processed and stored within Philippine jurisdiction. Where it is necessary to transfer personal data outside the Philippines — for example, to internationally hosted KYC verification services or game software providers — ph45 ensures that such transfers are conducted only to recipients in jurisdictions that provide adequate data protection standards comparable to those required under RA 10173, or pursuant to lawful transfer mechanisms including data processing agreements that incorporate the NPC's standard contractual clauses.

ph45 does not transfer personal data to jurisdictions that the NPC has identified as providing inadequate data protection, without implementing appropriate safeguards as required by the Data Privacy Act.

9. Data Retention

ph45 retains personal data for the minimum period necessary to fulfil the purposes for which it was collected, subject to the following retention obligations:

• Active account data — retained for the duration of your account relationship with ph45 and for a period of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AML obligations under RA 9160.
• KYC and identity documents — retained for a minimum of five (5) years from the date of account closure or the date of the last transaction, whichever is later, as required by PAGCOR and AMLC regulations.
• Transaction records — retained for a minimum of five (5) years from the date of each transaction, as required under RA 9160.
• Customer support records — retained for three (3) years from the date of the last interaction unless a longer retention period is required for active dispute or legal proceedings.
• Marketing consent records — retained for the duration of your consent and for a reasonable period thereafter to demonstrate compliance in the event of a complaint.

Upon expiry of the applicable retention period, ph45 will securely delete or anonymise your personal data in accordance with NPC-approved data disposal procedures.

10. Data Security

ph45 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ph45 platform
• Encryption at rest for all personally identifiable data stored in ph45 databases
• Multi-factor authentication for administrative access to systems holding personal data
• Role-based access controls limiting personal data access to authorised personnel on a need-to-know basis
• Regular third-party security audits and penetration testing of platform infrastructure
• Automated suspicious activity detection systems monitoring for unusual login patterns and transaction anomalies
• Formal data breach response procedures in compliance with NPC notification requirements

In the event of a personal data breach that poses a real risk of serious harm to affected data subjects, ph45 will notify the NPC within seventy-two (72) hours of becoming aware of the breach, and will notify affected players as required by the Data Privacy Act and NPC regulations.

11. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights in respect of your personal data held by ph45. To exercise any of these rights, contact ph45's Data Protection Officer at [email protected]:

• Right to be informed — the right to be notified that your personal data is being collected and processed, the purposes of processing, and the identity of the data controller.
• Right of access — the right to obtain a copy of your personal data held by ph45 and information about how it is being processed.
• Right to rectification — the right to have inaccurate or incomplete personal data corrected or updated.
• Right to erasure or blocking — the right to request the deletion or suspension of processing of your personal data where it is no longer necessary for the purpose for which it was collected, subject to ph45's legal retention obligations.
• Right to object — the right to object to the processing of your personal data, in particular for direct marketing purposes.
• Right to data portability — the right to receive a structured, commonly used, and machine-readable copy of personal data you have provided to ph45, where technically feasible.
• Right to lodge a complaint — the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe ph45 has processed your personal data in breach of the Data Privacy Act.

12. Cookies & Tracking Technologies

ph45 uses cookies and similar tracking technologies on the ph45 website and platform for the purposes described below. A cookie is a small text file placed on your device by the web server when you visit a website.

12.1 Types of Cookies Used

• Strictly necessary cookies — required for the platform to function. These include session authentication cookies that keep you logged in and security tokens that protect against cross-site request forgery. These cannot be disabled.
• Performance and analytics cookies — used to collect aggregated, anonymised data about how players use the ph45 platform, which pages are visited most, and where technical errors occur. This data helps ph45 improve platform performance and fix bugs.
• Functional cookies — used to remember your preferences such as language settings, game lobby filters, and display preferences.
• Marketing and targeting cookies — used, where you have consented, to deliver relevant promotional content and track the effectiveness of ph45 marketing campaigns. These are only placed where you have provided explicit consent.

12.2 Managing Cookies

You can manage cookie preferences through your browser settings at any time. Disabling strictly necessary cookies will prevent the ph45 platform from functioning correctly and you will be unable to log in to your account. ph45's cookie consent banner provides granular controls for non-essential cookie categories on your first visit and can be accessed again through the platform settings.

13. Marketing Communications

ph45 may send promotional communications — including bonus offers, game announcements, VIP programme updates, and ph45 platform news — to registered players via SMS, email, and in-platform notifications. Marketing communications are sent only where you have provided explicit consent at registration or subsequently updated your communication preferences.

You may withdraw your consent to receive marketing communications from ph45 at any time by updating your account notification settings or by contacting ph45 support at [email protected]. Withdrawal of marketing consent does not affect the lawfulness of processing based on consent before its withdrawal, and does not affect transactional communications related to your active account (such as deposit confirmations and withdrawal notifications).

14. Children & Minors

The ph45 platform is strictly intended for persons aged 21 years and above in accordance with PAGCOR regulations. ph45 does not knowingly collect personal data from any person under the age of 21. All registration attempts are subject to mandatory age verification through government-issued Philippine identification.

If ph45 becomes aware that personal data has been collected from a person under the age of 21, that Account will be immediately suspended, the personal data will be deleted to the extent permitted by applicable legal retention obligations, and the matter may be reported to PAGCOR. If you believe that ph45 holds personal data relating to an underage individual, please contact [email protected] immediately.

15. Amendments to This Privacy Policy

ph45 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable Philippine data protection law, NPC guidance, PAGCOR requirements, or ph45 business practices. Material changes will be communicated to registered players via the email address on file or through a prominent in-platform notification.

The "Effective Date" and "Last Reviewed" dates at the top of this Policy indicate when the current version came into effect. The most current version of this Privacy Policy is always accessible at https://ph45.one/privacy-policy. Continued use of ph45 following the posting of an updated Privacy Policy constitutes acceptance of the revised Policy.

16. Contact Us & Complaints

For any privacy-related enquiries, requests to exercise your data subject rights, or concerns about ph45's data handling practices, please contact the ph45 Data Protection Officer:

ph45 will acknowledge privacy enquiries within five (5) business days and will respond substantively within thirty (30) calendar days. If you are not satisfied with ph45's response to your privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines through the NPC's official government channels.