ph45 Casino – Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how ph45 Casino ("ph45," "we," "us," "our"), the operator of the online gambling platform at ph45.club, collects, uses, stores, processes, and discloses personal data about individuals ("you," "your," "User") who access or use the ph45 website, mobile web application, and associated services.

This Policy applies to all personal data collected through your use of ph45, including data collected during registration, gameplay, deposits and withdrawals, customer support interactions, and promotional participation. By using the ph45 platform, you acknowledge that you have read, understood, and agree to the data practices described herein.

This Policy should be read in conjunction with ph45's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Data Controller Identity

ph45 Casino is the data controller responsible for your personal data as processed through the ph45 platform. ph45 operates under a licence issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and complies with all applicable data protection obligations under Philippine law, including Republic Act No. 10173 (the Data Privacy Act of 2012) and its implementing rules and regulations issued by the National Privacy Commission (NPC).

ph45 has registered its data processing activities with the National Privacy Commission as required under Section 46 of the Implementing Rules and Regulations of RA 10173 for personal information controllers engaged in processing personal data of at least 1,000 individuals.

3. Personal Data We Collect

ph45 collects the following categories of personal data in the course of operating the platform:

3.1 Identity and Registration Data

• Full legal name
• Date of birth (used for mandatory 21+ age verification)
• Gender
• Government-issued identification number (e.g., PhilSys ID, passport, UMID, driver's licence)
• Username and account credentials (password stored in hashed form only)

3.2 Contact Data

• Email address
• Philippine mobile number
• Residential address (province, city/municipality)

3.3 Financial and Transaction Data

• GCash account number or PayMaya account linked to your ph45 wallet
• Bank account details for BPI, BDO, or Metrobank transfers
• Deposit and withdrawal transaction records
• Account balance history

3.4 Gameplay and Behavioural Data

• Game activity logs, bet amounts, game outcomes, and session duration
• Bonus and promotion participation records
• Responsible gaming self-exclusion and limit-setting records

3.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Session tokens and login timestamps
• Cookies and similar tracking technologies (see Section 7)

3.6 Communications Data

• Records of your correspondence with ph45 customer support
• Feedback, survey responses, and complaint records

4. How We Collect Personal Data

ph45 collects personal data through the following means:

• Directly from you — when you register an account, complete identity verification, make deposits or withdrawals, participate in promotions, or contact customer support
• Automatically through the platform — through cookies, server logs, and tracking technologies that record your device and usage information when you access ph45
• From third-party payment processors — GCash, PayMaya, and banking partners may transmit transaction-related data to ph45 to facilitate deposits and withdrawals
• From identity verification partners — in connection with KYC (Know Your Customer) procedures, ph45 may use authorised third-party identity verification services to cross-reference government-issued identification data

5. Purposes and Legal Bases for Processing

ph45 processes your personal data only for the following purposes and on the following legal bases under RA 10173:

• Account creation and management — necessary for the performance of the contract between you and ph45
• Age and identity verification (KYC/AML) — compliance with a legal obligation under Philippine gaming and anti-money laundering laws
• Processing financial transactions — necessary for the performance of the contract
• Game provision and platform operation — necessary for the performance of the contract
• Customer support — necessary for the performance of the contract and ph45's legitimate interests
• Fraud prevention and security monitoring — compliance with legal obligations and ph45's legitimate interests in protecting the platform
• Responsible gaming monitoring — compliance with PAGCOR regulatory obligations
• Service improvement and analytics — ph45's legitimate interests in developing and improving the platform
• Direct marketing communications — with your explicit consent, which may be withdrawn at any time
• Legal and regulatory reporting — compliance with obligations under Philippine law, including mandatory reporting to PAGCOR, the AMLC, and the NPC

6. Disclosure of Personal Data

ph45 does not sell, rent, or trade your personal data. We disclose personal data only in the following circumstances:

• Service providers and processors — third-party entities that provide services to ph45 on a data processing basis, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting providers, and customer support platforms. All such providers are bound by data processing agreements consistent with RA 10173.
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government agencies where disclosure is required by law or regulation
• Law enforcement — where ph45 is required or permitted to disclose data in response to a valid court order, subpoena, or law enforcement request under Philippine law
• Business transfers — in the event of a merger, acquisition, or sale of ph45's business operations, personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations
• With your consent — in any other circumstance where you have provided explicit prior consent to the specific disclosure

7. Cookies and Similar Technologies

ph45 uses cookies and similar tracking technologies to operate the platform effectively. The types of cookies used include:

• Essential cookies — required for platform functionality, including session management, login persistence, and security. These cannot be disabled without impairing platform use.
• Analytics cookies — used to collect aggregated, anonymised data about how Users navigate the ph45 platform. This helps us identify areas for improvement.
• Preference cookies — used to remember your platform settings and preferences across sessions.

ph45 does not use third-party advertising cookies or cross-site tracking technologies for targeted advertising. You may manage cookie preferences through your browser settings; however, disabling essential cookies may affect your ability to use certain platform features.

8. Data Retention

ph45 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and KYC records — retained for a minimum of five (5) years after account closure, as required by PAGCOR licensing conditions and AMLC regulations
• Financial transaction records — retained for a minimum of five (5) years in compliance with anti-money laundering obligations under RA 9160 as amended
• Customer support communications — retained for two (2) years following the resolution of the relevant interaction
• Marketing consent records — retained for as long as marketing communications are sent, plus one (1) year

Upon expiry of the applicable retention period, ph45 will securely delete or irreversibly anonymise your personal data.

9. Data Security

ph45 implements technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph45 servers
• Encryption of personal data at rest using AES-256 or equivalent standards
• Strict role-based access controls limiting data access to authorised personnel with a documented need
• Regular security assessments, vulnerability scanning, and penetration testing
• Multi-factor authentication for administrative access to ph45 systems
• Incident response procedures aligned with NPC breach notification requirements under RA 10173

In the event of a personal data breach that poses a real risk of serious harm to affected individuals, ph45 will notify the NPC within 72 hours of discovery and will notify affected Users without undue delay, as required by RA 10173.

10. Cross-Border Data Transfers

In connection with the operation of the ph45 platform, certain personal data may be processed by ph45's service providers in locations outside the Philippines — for example, cloud infrastructure providers or game software licensors. ph45 ensures that any such cross-border transfers are subject to appropriate safeguards, including data processing agreements that impose data protection obligations equivalent to those required under RA 10173 and consistent with NPC guidance on cross-border data transfers.

11. Your Data Subject Rights

Under Republic Act No. 10173, you have the following rights in relation to your personal data held by ph45:

• Right to be informed — the right to receive clear information about how ph45 processes your personal data (fulfilled by this Policy)
• Right of access — the right to request a copy of the personal data ph45 holds about you
• Right to rectification — the right to have inaccurate or incomplete personal data corrected
• Right to erasure — the right to request deletion of your personal data where retention is no longer legally required or justified
• Right to object — the right to object to processing of your personal data, including for direct marketing purposes
• Right to data portability — the right to receive a structured, commonly used copy of your personal data for transfer to another controller
• Right to lodge a complaint — the right to file a complaint with the National Privacy Commission if you believe your data privacy rights have been violated

To exercise any of the above rights, please contact ph45's Data Protection Officer using the contact details in Section 14. ph45 will respond to data subject requests within fifteen (15) business days of receipt.

12. Children's Privacy

ph45 is strictly intended for individuals who are at least 21 years of age. ph45 does not knowingly collect personal data from persons under 21 years old. If ph45 becomes aware that it has inadvertently collected personal data from a person under the applicable age threshold, it will immediately delete that data and close the associated account. If you believe a minor has registered on ph45, please contact us immediately at the details in Section 14.

13. Changes to This Policy

ph45 reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to active Users via email notification or a prominent notice on the ph45 platform at least seven (7) calendar days before the changes take effect. The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision. Continued use of ph45 following the effective date of any update constitutes acceptance of the revised Policy.

14. Contact and Data Protection Officer

If you have questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by ph45, please contact our Data Protection Officer at:

• Email (DPO): [email protected] — please include "Data Privacy Request" in your subject line
• Platform support: Available via the in-platform live chat after logging in to your ph45 account

ph45 targets a response time of fifteen (15) business days for all privacy-related correspondence. For unresolved complaints, you may escalate your concern to the National Privacy Commission of the Philippines (privacy.gov.ph).