Privacy Policy

Introduction

a45t ("a45t," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses our online gaming platform at a45t.net (the "Platform"). This Privacy Policy describes how a45t collects, uses, stores, shares, and protects your personal information when you access or use the Platform, including all games, features, promotions, and support services.

This Privacy Policy is issued in compliance 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). By registering an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy should be read together with our Terms & Conditions, which govern your use of the a45t Platform.

Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, a45t acts as the Personal Information Controller (PIC) in respect of the personal data you provide when using the Platform. This means a45t determines the purposes and means of processing your personal information.

Where a45t engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, and analytics platforms — those parties act as Personal Information Processors (PIPs) and are contractually bound to process your data only on a45t's instructions and in accordance with applicable data protection law.

Data We Collect

a45t collects personal data from you in the following categories:

a45t does not intentionally collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for regulatory compliance, such as identity verification for anti-money laundering (AML) purposes.

How We Use Your Data

a45t processes your personal data for the following purposes:

• Account Management: To create, maintain, and administer your a45t player account, including identity verification and age verification (21+ requirement).
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver the full range of Platform features.
• Regulatory Compliance: To comply with PAGCOR licensing requirements, anti-money laundering (AML) obligations, and Know Your Customer (KYC) regulations applicable to online gaming operators in the Philippines.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Responsible Gaming: To monitor gaming behavior and identify players who may be at risk of problem gambling, and to facilitate responsible gaming tools such as deposit limits and self-exclusion.
• Customer Support: To respond to your inquiries, complaints, and support requests in a timely and effective manner.
• Marketing Communications: To send you promotional offers, bonuses, and platform updates — but only where you have provided your consent or where we have a legitimate interest to do so. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the performance, security, and user experience of the a45t Platform.
• Legal Claims: To establish, exercise, or defend legal claims in connection with your use of the Platform.

Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, a45t processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your a45t account and deliver the services you have requested.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AML/KYC obligations, and NPC directives.
• Legitimate Interests: Processing is necessary for a45t's legitimate interests, including fraud prevention, platform security, and improving our services, provided those interests are not overridden by your data protection rights.
• Consent: For marketing communications and non-essential cookies, a45t relies on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Data Sharing & Disclosure

a45t does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and AML compliance service providers engaged to verify your identity and comply with regulatory requirements.
• Game Software Providers: Licensed game studios and live dealer operators whose games are available on the a45t Platform, to the extent necessary to deliver those games.
• Analytics & Security Providers: Technology partners who assist a45t in monitoring Platform performance, detecting fraud, and improving user experience.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where disclosure is required by law or regulatory directive.
• Legal & Professional Advisors: Lawyers, auditors, and other professional advisors engaged by a45t in connection with legal proceedings or compliance reviews.

All third-party processors engaged by a45t are required to implement appropriate technical and organizational security measures and to process personal data only in accordance with a45t's instructions and applicable Philippine data protection law.

Cookies & Tracking Technologies

a45t uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use are:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Remember your preferences (such as language and display settings) to provide a more personalized experience.
• Analytics Cookies: Help us understand how players use the Platform — which pages are visited most, where players encounter errors, and how we can improve navigation and performance.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your interests and Platform activity. These are only set with your consent.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform.

Data Retention

a45t retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting requirements. Specifically:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years after account closure, in compliance with PAGCOR record-keeping requirements and Philippine AML regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of 2001 (as amended).
• Support Communications: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required for legal proceedings.
• Marketing Data: Retained until you withdraw your consent or opt out of marketing communications, after which it is deleted or anonymized within thirty (30) days.
• Technical & Analytics Data: Retained in aggregated, anonymized form for up to two (2) years for platform improvement purposes.

When personal data is no longer required, a45t will securely delete or anonymize it in accordance with our internal data disposal procedures.

Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by a45t:

• Right to Be Informed: The right to be told how your personal data is being collected and processed — which this Privacy Policy fulfills.
• Right of Access: The right to request a copy of the personal data a45t holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to a45t's legal and regulatory retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days, as required by the Data Privacy Act.

Data Security

a45t implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including financial information and government ID details.
• Role-based access controls ensuring that only authorized a45t personnel can access personal data, and only to the extent required for their job function.
• Regular security audits, penetration testing, and vulnerability assessments conducted by independent security specialists.
• Multi-factor authentication (MFA) for internal systems that process personal data.
• Incident response procedures to detect, contain, and notify affected players and the NPC of any personal data breach within the timeframes required by law.

While a45t takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your a45t account credentials.

Children's Privacy

The a45t Platform is strictly intended for individuals who are 21 years of age or older, in compliance with PAGCOR regulations governing casino-style gaming in the Philippines. a45t does not knowingly collect personal data from individuals under the age of 21.

If a45t becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the associated personal data, and report the matter to the appropriate regulatory authorities where required. If you believe a minor has registered on the Platform, please contact us immediately at [email protected].

International Data Transfers

a45t's primary operations and data storage are based in the Philippines. In certain circumstances, your personal data may be transferred to, stored in, or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or game software studios operating in other jurisdictions.

Where such transfers occur, a45t ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to apply data protection standards equivalent to those required under Philippine law. a45t will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without your explicit consent or without implementing appropriate safeguards.

Updates to This Privacy Policy

a45t reserves the right to update or revise 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 by email or by posting a prominent notice on the Platform. The date of the most recent revision is displayed at the top of this page.

Your continued use of the Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised policy. We encourage you to review this page periodically to stay informed about how a45t protects your personal data.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by a45t, please contact our Data Protection Officer:

• Privacy Inquiries: [email protected]
• General Support: [email protected]
• Response Time: Within 15 business days for data rights requests; within 24 hours for general support inquiries.

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. For more information, visit the NPC's official channels.