a45jl Casino Privacy Policy

01 About This Policy

1.1 This Privacy Policy applies to all personal data collected by a45jl through the a45jl website (https://a45jl.net), any associated mobile-optimised web interface, and all interactions you have with a45jl's customer support team, whether via live chat, email, or any other communication channel operated by a45jl.

1.2 This Policy should be read alongside the a45jl Terms & Conditions and the Responsible Gaming Policy, both of which form part of the overall agreement between you and a45jl. In the event of a conflict between this Privacy Policy and the Terms & Conditions regarding data matters, this Privacy Policy shall prevail.

1.3 This Policy is written in plain English to make it as clear and accessible as possible for Filipino players. Where legal terminology is unavoidable, we have provided explanations. If you have any questions about anything in this Policy, please reach out to our support team before registering.

02 Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, a45jl Casino is the Personal Information Controller (PIC) in respect of the personal data described in this Policy. As PIC, a45jl determines the purposes and means of processing your personal information and bears responsibility for ensuring that such processing is lawful, fair, and proportionate.

2.2 a45jl has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with the Data Privacy Act and this Privacy Policy. You may contact the a45jl DPO directly at: [email protected]

2.3 Where a45jl engages third-party service providers to process personal data on its behalf (for example, KYC verification providers or payment processors), those providers act as Personal Information Processors (PIPs) under the Data Privacy Act and are contractually bound to process data only on a45jl's instructions and in accordance with applicable data protection law.

03 Personal Data We Collect

3.1 a45jl collects personal data from you directly (when you register, make a deposit, or contact support), automatically (through your use of the platform), and from third parties (such as identity verification providers and payment processors). The categories of personal data we collect are set out in the table below.

3.2 a45jl does not intentionally collect sensitive personal information as defined under the Data Privacy Act (such as health data, religious beliefs, or political affiliations) unless specifically required by applicable law or regulation. If you voluntarily disclose such information to our support team, we will handle it with the heightened protections required under the Act.

3.3 Where you choose not to provide certain personal data that a45jl requires in order to verify your identity, process payments, or comply with legal obligations, a45jl may be unable to provide some or all of its services to you.

04 How We Use Your Personal Data

4.1 a45jl processes your personal data only for specific, legitimate purposes. The primary purposes for which we use your data are set out below:

Account Registration & Management

To create and maintain your a45jl account, verify your identity and age (21+), authenticate your login sessions, and manage your account preferences and communication settings.

Payment Processing

To process deposits and withdrawals via Philippine payment methods (GCash, PayMaya, BPI, BDO, Metrobank, InstaPay, PESONet), verify payment ownership, and maintain transaction records as required by Philippine financial regulations.

KYC & Regulatory Compliance

To comply with PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) obligations, and other applicable Philippine laws that require us to verify player identities, monitor transactions for suspicious activity, and report to relevant authorities where legally required.

Responsible Gaming

To monitor gaming patterns, identify potential problem gambling behaviour, apply player-requested deposit or session limits, enforce self-exclusion requests, and support PAGCOR's consumer protection framework for Philippine players.

Customer Support

To respond to your inquiries, resolve disputes, process complaints, and maintain records of support interactions for quality assurance and training purposes.

Platform Improvement & Security

To analyse usage patterns in aggregate, detect and prevent fraud and cheating, investigate security incidents, test new features, and improve the overall performance and user experience of the a45jl platform.

Marketing Communications

To send you promotional offers, bonus announcements, and updates about a45jl products and features — but only where you have given your explicit consent or where we have a legitimate interest in contacting you as an existing player. You may opt out at any time. See Section 12 for details.

05 Legal Bases for Processing

5.1 Under the Data Privacy Act of 2012, a45jl must have a valid legal basis for each category of personal data processing. The legal bases we rely on are as follows:

• Contractual Necessity: Processing required to perform the contract between you and a45jl (i.e., to operate your account and deliver gaming services);
• Legal Obligation: Processing required to comply with Philippine law, PAGCOR regulations, AMLA reporting obligations, and NPC registration requirements;
• Legitimate Interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and aggregate analytics, where a45jl's interests do not override your fundamental rights;
• Consent: Processing for direct marketing communications and non-essential cookies, where you have given us your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of processing before withdrawal.

5.2 Where a45jl relies on legitimate interests as a legal basis, we conduct a balancing test to ensure that our interests do not override your rights and freedoms. You may request details of any legitimate interests assessment by contacting our DPO.

06 Data Sharing & Disclosure

6.1 a45jl does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We share your personal data only in the following circumstances and only to the extent necessary for each purpose:

Service Providers (Personal Information Processors)

a45jl engages carefully selected third-party service providers to perform specific functions on our behalf, including identity verification and KYC processing, payment gateway operations, fraud detection and anti-money laundering screening, cloud infrastructure and data hosting, and customer support tools. All such providers are bound by Data Processing Agreements (DPAs) that prohibit them from using your data for any purpose other than the one specified by a45jl.

Regulatory & Law Enforcement Authorities

a45jl will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or any other government authority in the Philippines where we are required to do so by applicable law, court order, or regulatory direction. a45jl will, where legally permitted, notify you of such disclosure.

Business Transfers

In the event of a merger, acquisition, sale of assets, or restructuring involving a45jl, your personal data may be transferred to the successor entity. a45jl will notify you of any such transfer and the successor entity will be bound by terms no less protective than this Privacy Policy.

07 Cookies & Tracking Technologies

7.1 a45jl uses cookies, web beacons, and similar tracking technologies to operate the platform, remember your preferences, maintain your login session, detect fraud, and gather aggregate analytics about how players use the site. The types of cookies we use are described below:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies and security tokens. You cannot opt out of these cookies while using the platform.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and responsible gaming limits you have set.
• Analytics Cookies: Collect anonymous, aggregate data about how visitors use the a45jl platform (e.g., pages visited, time on site, error reports). This data does not identify you personally.
• Marketing Cookies: Used only with your explicit consent to track the effectiveness of a45jl promotional campaigns. These cookies are not enabled by default.

7.2 You may manage or withdraw your consent to non-essential cookies at any time through the cookie preference centre accessible from the a45jl platform footer, or by adjusting your browser settings to refuse or delete cookies. Please note that disabling strictly necessary cookies may affect the functionality of the platform.

7.3 a45jl does not use any cross-site tracking technologies to follow your browsing activity outside of the a45jl platform.

08 Data Retention

8.1 a45jl retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, taking into account applicable legal and regulatory retention obligations. The general retention periods applied by a45jl are as follows:

8.2 Upon expiry of the applicable retention period, a45jl will securely delete or irreversibly anonymise the relevant personal data. Anonymised data (which can no longer identify you) may be retained for statistical analysis and platform improvement purposes indefinitely.

8.3 Where a45jl is required to retain data beyond the standard retention periods due to an ongoing legal proceeding, regulatory investigation, or unresolved dispute, the data will be held in a restricted-access archive until the matter is resolved.

09 Data Security

9.1 a45jl implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Encryption: AES-256 encryption for data at rest and TLS 1.3 for all data in transit between your device and a45jl servers;
• Access Controls: Role-based access controls ensuring that only authorised a45jl personnel with a legitimate need can access personal data;
• Two-Factor Authentication (2FA): Available to all players and mandatory for all a45jl administrative accounts;
• Firewalls & Intrusion Detection: Multi-layer firewall protection and real-time intrusion detection and prevention systems;
• Regular Security Audits: Periodic independent security assessments and penetration testing of the a45jl platform and infrastructure;
• Staff Training: All a45jl employees with access to personal data receive regular data protection and cybersecurity training.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, a45jl will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular No. 16-03. Affected players will be notified without undue delay where required by the Data Privacy Act.

9.3 While a45jl takes all reasonable precautions to protect your personal data, no internet-based system is entirely immune from security risks. You are encouraged to use a strong, unique password for your a45jl account and to enable two-factor authentication to maximise your personal account security.

10 Your Data Subject Rights

10.1 Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in respect of your personal data held by a45jl:

• Right to be Informed: You have the right to be informed of how your personal data is collected, used, and processed — which is the primary purpose of this Privacy Policy;
• Right of Access: You have the right to obtain a copy of the personal data a45jl holds about you and information about how it is processed;
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data a45jl holds about you;
• Right to Erasure or Blocking: You have the right to request deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, subject to a45jl's legal retention obligations;
• Right to Object: You have 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: You have the right to receive a structured, commonly used, and machine-readable copy of personal data you have provided to a45jl, where processing is based on consent or contract;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that a45jl has processed your personal data in violation of the Data Privacy Act.

10.2 To exercise any of your data subject rights, please contact the a45jl Data Protection Officer by email at [email protected] with the subject line "Data Subject Rights Request". a45jl will acknowledge your request within five (5) business days and respond substantively within thirty (30) calendar days, in accordance with NPC requirements.

10.3 a45jl may need to verify your identity before processing a data subject rights request to ensure that personal data is not disclosed to or altered by unauthorised parties. We may ask you to provide a copy of a government-issued ID for this purpose.

11 Children & Minors

11.1 If a45jl becomes aware that personal data has been collected from an individual under the age of 21, a45jl will immediately close the relevant account, delete the associated personal data (subject to any legal obligation to retain records of the underage registration), and refund any deposits made to the payment method from which they originated.

11.2 If you are a parent or guardian and believe that your child or a minor in your care has registered an a45jl account, please contact our support team immediately at [email protected] so that we can take appropriate action without delay.

12 Marketing Communications

12.1 a45jl may send you marketing communications about promotions, bonuses, new game launches, and other a45jl offerings via email or in-platform notifications. We will only send you marketing communications where you have:

• Opted in to marketing communications during or after the registration process; or
• Previously engaged with a45jl as a registered player and have not opted out of marketing (soft opt-in, permitted under applicable Philippine regulations).

12.2 You may opt out of a45jl marketing communications at any time by:

• Clicking the "Unsubscribe" link included in every marketing email;
• Updating your communication preferences from within your a45jl account settings; or
• Contacting a45jl support at [email protected] with the subject line "Marketing Opt-Out".

12.3 Opting out of marketing communications does not affect transactional communications such as deposit confirmations, withdrawal notifications, account security alerts, and responsible gaming notices, which a45jl will continue to send as necessary for the operation of your account.

13 Third-Party Links

13.1 The a45jl platform may contain links to third-party websites or resources for informational purposes (for example, links to PAGCOR's official website or the NPC's website). a45jl is not responsible for the privacy practices or content of any third-party websites, and this Privacy Policy does not apply to those sites.

13.2 a45jl encourages you to review the privacy policies of any third-party websites you visit. The inclusion of a link on the a45jl platform does not constitute an endorsement by a45jl of the linked site's privacy practices or content.

14 Updates to This Privacy Policy

14.1 a45jl may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory guidance from the NPC. When we make material changes to this Policy, we will update the "Effective Date" at the top of this page and, where the changes significantly affect your rights, we will notify you by email to the address registered to your a45jl account.

14.2 Your continued use of the a45jl platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not accept the updated Policy, you must cease using the a45jl platform and may request account closure by contacting our support team.

14.3 a45jl recommends that you review this Privacy Policy periodically to stay informed of how we protect your personal data.

15 Contact & Complaints

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or a45jl's handling of your personal data, please contact our Data Protection Officer using the following details:

• Email: [email protected]
• Subject Line: "Privacy Inquiry" or "Data Subject Rights Request"
• Live Chat: Available 24/7 from within your a45jl account dashboard
• Response Time: Acknowledgement within 5 business days; full response within 30 calendar days

15.2 If you are not satisfied with how a45jl has handled your privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Republic of the Philippines. The NPC is the independent government body responsible for administering the Data Privacy Act of 2012.

15.3 For data subject rights requests, please include your full name, registered email address, and a clear description of the right you wish to exercise. a45jl may ask for identity verification before processing your request to protect the security of your personal data.