Privacy Policy
a45.com Data Protection

This Privacy Policy ("Policy") describes how a45.com ("the Platform," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "Player," or "User") who access or use the a45.com website, mobile platform, games, and all associated services (collectively, the "Services").

a45.com is committed to protecting the privacy and personal data of all players in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. We take our obligations as a personal information controller seriously and have implemented appropriate technical and organizational measures to safeguard your data.

By registering an account on a45.com, accessing the Platform, or using any of our Services, 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. If you do not agree with this Policy, please do not use the Platform.

For the purposes of the Philippine Data Privacy Act of 2012 and applicable data protection legislation, the personal information controller responsible for your data is a45.com. As the personal information controller, a45.com determines the purposes and means of processing your personal data collected through the Platform and its Services.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy.

a45.com collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include the following:

Identity & Contact Information

• Full legal name as it appears on a valid government-issued identification document;
• Date of birth and age verification data;
• Residential address in the Philippines (barangay, city/municipality, province);
• Valid email address;
• Philippine mobile number.

Account & Authentication Data

• Username and encrypted password;
• Security questions and answers (where applicable);
• Account preferences and settings;
• Login timestamps and session data.

Identity Verification (KYC) Documents

• Copies of government-issued identification documents (e.g., Philippine passport, SSS ID, UMID, driver's license, PhilSys National ID, Voter's ID);
• Proof of address documents (e.g., utility bills, bank statements issued within the last three months);
• Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account showing your registered name);
• Selfie or liveness verification images where required for enhanced KYC.

Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method references;
• GCash, PayMaya, BPI, BDO, and Metrobank account reference identifiers (we do not store full bank account numbers or card numbers);
• Account balance history and bonus transaction records;
• Wagering history and game transaction logs.

Technical & Usage Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser information;
• Pages visited, features used, and time spent on the Platform;
• Clickstream data and navigation patterns;
• Error logs and crash reports.

Communications Data

• Records of live chat conversations with our support team;
• Email correspondence with a45.com;
• Feedback, survey responses, and complaint records.

a45.com collects personal data through the following channels:

Directly From You

The majority of personal data we hold is provided directly by you when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions. You are in control of what you share with us at each of these touchpoints.

Automatically Through Platform Use

When you access and use the a45.com Platform, certain technical data is collected automatically through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, device identifiers, browser type, and behavioral data such as pages visited and games played. See Section 9 for full details on our use of cookies.

From Third-Party Service Providers

We may receive personal data about you from trusted third-party service providers who assist us in operating the Platform, including:

• Payment processors (GCash, PayMaya, BPI, BDO, Metrobank) — transaction confirmation and reference data;
• Identity verification service providers — KYC verification results and document authentication outcomes;
• Fraud detection and anti-money laundering screening providers — risk scores and watchlist screening results;
• Analytics providers — aggregated and anonymized usage statistics.

a45.com processes your personal data only for specific, legitimate purposes and only where we have a valid legal basis to do so under the Data Privacy Act of 2012. The table below summarizes the key purposes for which we process your data and the corresponding legal basis:

a45.com does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. We share your personal data only in the limited circumstances described below, and only to the extent necessary for the stated purpose.

Service Providers Acting on Our Behalf

We engage trusted third-party service providers to assist in operating the Platform. These providers act as personal information processors under our instruction and are contractually bound to process your data only for the purposes we specify and to maintain appropriate security standards. Categories of service providers include:

• Payment processing partners (GCash, PayMaya, BPI, BDO, Metrobank);
• KYC and identity verification providers;
• Fraud detection and AML screening services;
• Cloud hosting and infrastructure providers;
• Customer support platform providers;
• Email and SMS communication service providers;
• Analytics and platform performance monitoring tools.

Regulatory and Law Enforcement Authorities

a45.com is required by Philippine law to disclose certain personal data to regulatory and law enforcement authorities in specific circumstances, including:

• The Anti-Money Laundering Council (AMLC) — for suspicious transaction reporting under the Anti-Money Laundering Act (Republic Act No. 9160, as amended);
• PAGCOR — in connection with regulatory audits, licensing compliance, and player protection investigations;
• Philippine law enforcement agencies — where required by a valid court order, subpoena, or other lawful process;
• The National Privacy Commission (NPC) — in connection with data breach notifications or privacy investigations.

Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of a45.com's business, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer and the privacy implications before it takes effect, where practicable.

a45.com retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following retention periods apply:

After the applicable retention period expires, your personal data is securely deleted or anonymized so that it can no longer be associated with you. Where data is anonymized rather than deleted, the anonymized data may be retained indefinitely for statistical and analytical purposes.

a45.com implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security framework includes:

Technical Safeguards

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the a45.com Platform is encrypted using industry-standard 256-bit SSL/TLS protocols;
• Encryption at Rest: Sensitive personal data stored in our databases is encrypted at rest using AES-256 encryption;
• Password Hashing: Account passwords are never stored in plain text — they are hashed using a strong, salted cryptographic algorithm;
• Two-Factor Authentication (2FA): Players are encouraged to enable 2FA on their accounts for an additional layer of login security;
• Firewalls and Intrusion Detection: Our infrastructure is protected by enterprise-grade firewalls and real-time intrusion detection systems;
• Regular Security Audits: We conduct periodic penetration testing and vulnerability assessments of our Platform and infrastructure.

Organizational Safeguards

• Access to personal data is restricted to authorized a45.com personnel and service providers on a strict need-to-know basis;
• All staff with access to personal data undergo data privacy training and are bound by confidentiality obligations;
• We maintain a documented data breach response plan and are prepared to notify affected players and the National Privacy Commission within 72 hours of discovering a notifiable breach.

a45.com uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and improve the overall player experience. This section explains what cookies we use and how you can manage them.

What Are Cookies?

Cookies are small text files placed on your device by a website when you visit it. They allow the website to recognize your device on subsequent visits and remember certain information about your session or preferences. Cookies do not contain executable code and cannot access other files on your device.

Types of Cookies We Use

Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, and set preferences for specific websites. Please note that disabling strictly necessary cookies will prevent you from logging in and using the Platform. Disabling functional cookies may affect your experience by resetting your preferences on each visit.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by a45.com. We are committed to honoring these rights promptly and without unnecessary barriers.

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and shared. This Privacy Policy fulfills that obligation.
• Right to Access: You have the right to request a copy of the personal data we hold about you, including information about how it is being processed. Submit your request via live chat or email and we will respond within fifteen (15) business days.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You can update most account information directly from your account dashboard.
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and there is no other legal basis for processing. Note that certain data must be retained for the mandatory periods described in Section 7.
• 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 we may be able to demonstrate compelling grounds that override your objection.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: If you believe your privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.

a45.com is strictly an adult gaming platform. The minimum age to register and use the Services is 21 years old, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21.

During registration, all players are required to confirm that they are at least 21 years of age. Age verification is further enforced through our KYC process, which requires submission of a valid government-issued identification document confirming date of birth.

If a45.com discovers or has reason to believe that personal data has been collected from an individual under the age of 21, we will immediately suspend the associated account, delete the personal data collected, and return any deposited funds to the payment source, subject to verification.

a45.com primarily processes and stores personal data within the Philippines. However, some of our third-party service providers — including cloud infrastructure providers, KYC verification services, and analytics platforms — may process data in other jurisdictions.

Where personal data is transferred outside the Philippines, a45.com ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Philippine Data Privacy Act. These safeguards may include:

• Contractual clauses requiring the recipient to maintain data protection standards equivalent to Philippine law;
• Transfers to jurisdictions that have been assessed as providing an adequate level of data protection;
• Binding corporate rules where applicable.

a45.com 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, we will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect, where practicable.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how a45.com protects your personal data.

Your continued use of the Platform after the effective date of any amendment constitutes your acknowledgment of the updated Policy. If you do not agree with the revised Policy, you must stop using the Platform and may request account closure as described in our Terms and Conditions.

If you have any questions about this Privacy Policy, wish to exercise your data privacy rights, or want to raise a concern about how a45.com handles your personal data, please contact us through any of the following channels:

• Live Chat: Available 24/7 directly from the a45.com Platform — the fastest way to reach our support team
• Email (Data Protection Officer): [email protected] — use subject line "DPO — Privacy Inquiry" or "Privacy Rights Request"

We aim to acknowledge all privacy-related inquiries within three (3) business days and to provide a full response within fifteen (15) business days. For complex requests, we may require additional time and will keep you informed of the expected timeline.

If you are not satisfied with our response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the independent regulatory authority responsible for enforcing the Data Privacy Act of 2012.