This Privacy Policy ("Policy") describes how A45com — accessible at a45com.best — collects, uses, stores, and safeguards the personal data of registered players and visitors based in the Philippines. By using A45com, you acknowledge that you have read this Policy and agree to its terms.
A45com is committed to protecting the privacy of every Kabayan who plays on our platform. We understand that trust is earned — and part of earning that trust means being completely upfront about how your personal information is handled. There are no hidden clauses here, walang palihim. Just a straightforward explanation of your data and your rights.
1. Overview and Scope
This Policy applies to all personal data processed by A45com in connection with:
- Your registration and account management on A45com.
- Your use of any games, features, or services offered through the platform.
- Any communications between you and A45com, including customer support interactions.
- Marketing communications, if you have opted in to receive them.
This Policy is governed by the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. A45com acts as the Personal Information Controller in respect of the personal data it processes about you.
2. Personal Data We Collect
A45com collects only the personal data that is reasonably necessary to provide you with a safe and compliant gaming experience. The categories of data we collect include:
Identity Data
- Full legal name as it appears on a valid government-issued ID.
- Date of birth (to verify you are at least 21 years old).
- Nationality and country of residence.
- Copy of a valid government-issued ID (e.g., PhilSys, Passport, Driver's License, UMID) when required for Know Your Customer (KYC) verification.
Contact Data
- Email address.
- Philippine mobile number.
- Residential address (province/city level).
Financial Data
- GCash, Maya, or other e-wallet account numbers registered in your name.
- Bank account details (for bank-based withdrawals via BDO, BPI, UnionBank, etc.).
- Transaction history including deposits, withdrawals, and bet records.
Technical Data
- IP address and approximate geolocation.
- Device type, operating system, and browser information.
- Session logs and login timestamps.
Usage Data
- Games played, bet amounts, win/loss records, and session duration.
- Feature usage patterns and in-app navigation behaviour.
- Customer support chat transcripts and email correspondence.
3. How We Collect Your Data
A45com collects your personal data through the following means:
- Direct submission — when you fill out the registration form, complete KYC, contact support, or update your profile.
- Automated collection — through cookies, web beacons, and analytics tools when you browse or use the platform.
- Third-party sources — payment processors (e.g., GCash, Maya) may share transaction confirmation data with us; identity verification services may return KYC results.
- Game providers — game operators may share anonymised session data for fairness monitoring and dispute resolution.
4. Why We Use Your Personal Data
A45com uses your personal data only for lawful and legitimate purposes. Here is a breakdown of why we process each category of data:
- Account creation and management — to register your account, verify your identity, and maintain your player profile.
- Financial transactions — to process deposits, withdrawals, and bonus payments in Philippine Peso (₱), and to maintain accurate financial records.
- Legal compliance — to meet anti-money laundering (AML) obligations, KYC requirements, and reporting duties under Philippine gaming regulations.
- Security and fraud prevention — to detect and prevent fraudulent accounts, unauthorised access, collusion, and abuse of bonus promotions.
- Customer support — to respond to your queries, resolve disputes, and improve service quality.
- Responsible gaming — to monitor for signs of problem gambling and to enforce self-exclusion or limit requests that you submit.
- Platform improvement — to analyse usage patterns, fix bugs, and develop new features that better serve Filipino players.
- Marketing (with consent) — to send you relevant promotions, bonus alerts, and platform updates. You may opt out at any time.
5. Sharing Your Personal Data
A45com does not sell, rent, or disclose your personal data to unauthorised third parties. We may share your data in the following limited, controlled circumstances:
- Payment processors — GCash, Maya, GrabPay, Coins.ph, BDO, BPI, UnionBank, Visa, and Mastercard receive only the transaction data required to process your deposit or withdrawal.
- Identity verification providers — accredited KYC service providers may process identity document images solely to verify your identity.
- Game providers — JILI and other integrated game studios may receive anonymised session identifiers for game integrity auditing.
- Regulatory authorities — we may be required by law to disclose personal data to Philippine government agencies, courts, or law enforcement bodies.
- Professional advisors — lawyers, auditors, and cybersecurity consultants who are bound by confidentiality obligations.
All third-party service providers engaged by A45com are required to process personal data only on our instructions, to maintain adequate security standards, and to comply with applicable Philippine privacy law.
6. Cookies and Tracking Technologies
A45com uses cookies and similar tracking technologies to enhance your experience on the platform. Here is what each type does:
- Essential cookies — required for core platform functions such as login sessions and security. These cannot be disabled.
- Performance cookies — help us understand how players navigate the platform so we can improve it. Data collected is aggregated and anonymised.
- Functional cookies — remember your preferences such as language settings and last-played game.
- Marketing cookies — used (with your consent) to deliver relevant promotions. You can withdraw this consent at any time via your account settings.
You can manage cookie preferences through your browser settings. Disabling essential cookies may prevent some parts of A45com from working correctly.
7. How Long We Keep Your Data
A45com retains personal data only for as long as it is necessary for the purposes described in this Policy, or as required by Philippine law. Our general retention schedule is:
- Account data — retained for the duration of your account plus 5 years after account closure, to meet legal and regulatory obligations.
- Financial records — retained for a minimum of 7 years in compliance with Philippine financial reporting requirements.
- Support correspondence — retained for 3 years after the matter is resolved.
- Marketing preferences — retained until you withdraw consent or request deletion.
When data is no longer needed, it is securely deleted or anonymised so that it can no longer be linked back to you.
8. How We Keep Your Data Secure
A45com takes data security seriously. We implement a combination of technical and organisational measures to protect your personal information from unauthorised access, loss, or disclosure:
- All data in transit is encrypted using TLS 1.2 or higher.
- Sensitive data at rest (e.g., payment details) is encrypted using AES-256 standard.
- Access to personal data is restricted on a strict need-to-know basis within our organisation.
- Our infrastructure undergoes regular security audits and penetration testing.
- We maintain a formal incident response plan. In the unlikely event of a data breach affecting your rights, we will notify you and the National Privacy Commission (NPC) within 72 hours of discovery.
9. Your Data Privacy Rights
Under the Philippine Data Privacy Act, you have the following rights regarding your personal data held by A45com. You can exercise any of these rights by emailing support@a45com.best: