Privacy Policy – 45jl Casino Philippines

1Introduction
2Data Controller
3Data We Collect
4How We Collect Data
5Purposes of Processing
6Legal Basis
7Data Sharing
8Data Retention
9Data Security
10Cookies & Tracking
11Your Rights
12Children & Minors
13Cross-Border Transfers
14Policy Changes
15Contact & DPO

Your data matters. 45jl processes personal information only as required to operate a PAGCOR-regulated platform and to comply with Philippine law.

Last Updated: 1 January 2026. This Privacy Policy supersedes all prior versions. Material changes are communicated to registered players via SMS to their registered Philippine mobile number before taking effect.

45jl Casino ("45jl," "we," "us," or "our") is committed to protecting the privacy and personal data of every Filipino player who uses our platform. This Privacy Policy explains in plain, specific terms what personal information 45jl collects, why we collect it, how we use it, who we share it with, how long we keep it, and what rights you have under Philippine law regarding your own data.

This policy is written to comply with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC). It also reflects 45jl's obligations under PAGCOR's licensing conditions, which include specific data handling requirements for player records, anti-money laundering audit trails, and responsible gaming data.

By registering a 45jl account or using any part of the Platform, you acknowledge that you have read this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not consent, please do not create an account or use the 45jl platform.

Section 1

Introduction

The 45jl Casino platform is accessible at 45jl.club and provides online casino games, sports betting, bingo, and related services to eligible Filipino players who are 21 years of age and above. Operating under a PAGCOR license, 45jl is subject to the data governance standards applicable to Philippine-regulated gaming operators — which include strict requirements around player identity verification, transaction records, responsible gaming data, and audit reporting.

This Privacy Policy applies to all personal data collected from players and site visitors through: the 45jl.club website, the account registration and KYC process, the gaming and betting platform, the customer support system, the payment processing interface, and any 45jl promotional communications. It does not apply to third-party websites, payment processors, or game providers that operate under their own privacy frameworks, even where those services are integrated into the 45jl platform.

Section 2

Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, the Data Controller responsible for your personal information is 45jl Casino, the licensed operator of the 45jl.club platform, regulated by the Philippine Amusement and Gaming Corporation (PAGCOR).

45jl has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with RA 10173 and serving as the primary point of contact for data subject rights requests and privacy complaints. Contact details for the DPO are provided in Section 15 of this Policy.

Registered with the NPC: 45jl Casino's data processing systems and DPO registration are filed with the Philippine National Privacy Commission as required under RA 10173 for personal information controllers processing sensitive personal information.

Section 3

Personal Data We Collect

45jl collects the following categories of personal data from players and platform visitors. We collect only what is necessary for the specific purposes outlined in this Policy.

Data Category	Specific Data Points	Collection Trigger
Identity Data	Full legal name, date of birth, nationality, government ID number and type (PhilSys, SSS UMID, passport, driver's license)	Account registration & KYC
Contact Data	Philippine mobile number, email address	Account registration
Biometric / Verification Data	ID document image, selfie photograph for identity matching	KYC verification
Financial Data	GCash account reference, Maya account reference, bank account details for BPI / BDO / Metrobank withdrawals, deposit and withdrawal transaction history	Deposits & withdrawals
Gaming Activity Data	Game history, bet amounts, win/loss records, session durations, bonus usage	Platform use
Technical Data	IP address, device type, operating system, browser type, login timestamps, session identifiers	Platform access
Communications Data	Live chat transcripts, support ticket content, SMS OTP logs	Customer support use
Responsible Gaming Data	Self-imposed limits, cooling-off periods, self-exclusion status, PAGCOR responsible gaming registry records	Responsible gaming tools use

Under RA 10173, identity data, government ID numbers, biometric data, and financial account details are classified as sensitive personal information and are subject to the highest tier of data protection obligations under Philippine law.

Section 4

How We Collect Your Data

45jl collects your personal data through the following methods:

Directly from you: Information you provide during account registration, KYC document submission, deposit and withdrawal requests, customer support interactions, and when updating your account profile.

Automatically through platform use: Technical data including IP addresses, device identifiers, login timestamps, browser characteristics, and gaming session logs are collected automatically when you access and use the 45jl platform.

From payment processors: When you transact via GCash, Maya, BPI, BDO, or Metrobank, 45jl receives transaction confirmation data from those processors — specifically transaction reference numbers, amounts, timestamps, and account identifiers. 45jl does not store your full e-wallet credentials or banking passwords.

From identity verification services: During KYC processing, 45jl may use third-party identity verification services to cross-reference government ID data with issuing authority databases. These services operate under their own privacy frameworks and are contractually bound to handle data in compliance with RA 10173.

From cookies and similar technologies: The 45jl platform uses cookies and similar tracking technologies as described in Section 10 of this Policy.

Section 5

Purposes of Processing

45jl processes your personal data only for the following specified, legitimate purposes:

Account creation and management: Registering your account, verifying your identity, maintaining your account profile, and authenticating your login sessions.
KYC and age verification compliance: Verifying that you are 21 years of age or older and confirming your identity in compliance with PAGCOR's mandatory KYC requirements for licensed Philippine online casino operators.
Payment processing: Processing your GCash, Maya, and bank transfer deposits and withdrawals in Philippine Peso, including transaction record keeping and reconciliation.
Game and platform service delivery: Enabling access to games, maintaining game session state, recording game outcomes, and calculating and crediting winnings.
Anti-money laundering (AML) compliance: Monitoring transactions for suspicious activity patterns in compliance with the Philippine Anti-Money Laundering Act (AMLA) and PAGCOR's AML reporting obligations.
Responsible gaming program administration: Recording and enforcing self-imposed deposit limits, loss limits, session limits, cooling-off periods, and self-exclusion requests. Reporting self-exclusions to PAGCOR's responsible gaming registry as required.
PAGCOR regulatory reporting: Providing player activity, transaction, and compliance data to PAGCOR as required under the terms of 45jl's operating license.
Customer support: Responding to your inquiries, resolving account issues, and maintaining support interaction records for quality and compliance purposes.
Platform security: Detecting and preventing unauthorized access, fraud, cheating, collusion, and other prohibited conduct as defined in the Terms and Conditions.
Promotional communications: Sending you relevant bonus offers, promotional updates, and platform news via SMS or email, where you have not opted out of such communications.
Legal compliance: Complying with any other applicable Philippine laws, regulations, court orders, or lawful requests from government authorities.

Section 6

Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 45jl's processing of your personal data is grounded in the following legal bases:

Contractual necessity: Processing of identity, contact, financial, and gaming activity data is necessary for the performance of the contract between you and 45jl — specifically, providing the platform services you have registered to use.

Legal obligation: Processing for KYC, AML, PAGCOR regulatory reporting, and age verification purposes is required by law — specifically AMLA, PAGCOR licensing conditions, and RA 10173 itself.

Consent: Where processing is not strictly required for contract performance or legal compliance — such as promotional communications and certain analytical uses — 45jl relies on your consent, which you provide by completing registration. You may withdraw consent for promotional communications at any time via your Account Settings.

Legitimate interests: Processing of technical and security data for fraud prevention, platform security, and the detection of prohibited conduct is based on 45jl's legitimate interest in operating a secure and fair gaming environment for all Filipino players on the platform.

Section 7

Data Sharing & Disclosure

45jl does not sell, rent, or trade your personal data to third parties. We share your data only in the following limited and necessary circumstances:

7.1 PAGCOR and Philippine Government Authorities: 45jl is legally required to disclose player identity, transaction, and gaming activity data to PAGCOR as part of its licensing obligations. 45jl will also comply with lawful requests from other Philippine government agencies — including the AMLC (Anti-Money Laundering Council), the Bureau of Internal Revenue, and law enforcement — where compelled by law, court order, or regulatory direction.

7.2 Payment Processors: 45jl shares the minimum necessary transaction and identity data with GCash, Maya, BPI, BDO, and Metrobank to process your deposits and withdrawals. These processors are independent data controllers governed by their own privacy policies and are bound by Philippine financial services regulations.

7.3 Game Providers: 45jl shares a session token and anonymized account identifier with game providers (such as JILI, Pragmatic Play, PG Soft, and others) to authenticate your game sessions. Your full name, mobile number, and financial data are not shared with game providers.

7.4 KYC and Identity Verification Services: Where third-party identity verification services are used during KYC, your government ID data and verification photographs may be shared with those services under strict data processing agreements requiring compliance with RA 10173.

7.5 Professional Advisers: 45jl may share relevant data with its lawyers, auditors, accountants, and insurers where strictly necessary for the provision of professional services, under confidentiality obligations.

No marketing data sales: 45jl does not share your personal data with advertising networks, data brokers, or any third parties for marketing purposes. Your data is used only for the purposes described in this Policy.

Section 8

Data Retention

45jl retains your personal data for the periods specified below, after which data is securely deleted or anonymized in accordance with RA 10173 and PAGCOR requirements:

Data Category	Retention Period	Basis
Account and identity data (active accounts)	Duration of account + 5 years	PAGCOR / AMLA legal obligation
KYC documents	Duration of account + 5 years	PAGCOR / AMLA legal obligation
Transaction records (deposits / withdrawals)	7 years from transaction date	AMLA / BIR / PAGCOR obligation
Gaming session and bet history	Duration of account + 3 years	PAGCOR regulatory requirement
Self-exclusion and responsible gaming records	Duration of exclusion + 5 years	PAGCOR responsible gaming obligation
Customer support communications	3 years from interaction date	Legitimate interest / legal claims
Technical / access logs	12 months	Security and fraud detection

Where 45jl is involved in legal proceedings or a regulatory investigation, relevant data will be retained beyond the above standard periods until the matter is fully resolved, as permitted under RA 10173.

Section 9

Data Security

45jl implements technical and organizational security measures appropriate to the sensitivity of the personal data processed on the platform. These measures include, but are not limited to:

SSL/TLS 256-bit encryption for all data transmitted between your device and the 45jl platform.
Encryption at rest for sensitive personal data, including KYC documents and financial account identifiers stored on 45jl servers.
Access controls limiting staff access to personal data on a strict need-to-know basis, with all access logged and monitored.
Two-factor authentication for all internal staff accounts with access to personal data systems.
Regular security assessments and penetration testing of the 45jl platform infrastructure.
Data breach response procedures aligned with RA 10173's 72-hour breach notification requirement to the National Privacy Commission.

Notwithstanding these measures, no online platform can guarantee absolute security. You are responsible for maintaining the security of your own Account credentials. 45jl will notify you and the NPC promptly in the event of a personal data breach affecting your information, as required by RA 10173.

Data breach notification: In the event of a security incident involving your personal data, 45jl will notify affected players via their registered Philippine mobile number within 72 hours of breach discovery, and will file the required breach notification with the National Privacy Commission (NPC).

Section 10

Cookies & Tracking Technologies

45jl uses cookies and similar technologies to operate and improve the platform. The following types of cookies are used:

Strictly Necessary Cookies: Required for the platform to function — these include session authentication tokens, CSRF protection tokens, and load-balancing identifiers. The platform cannot operate without these cookies. No consent is required for strictly necessary cookies under RA 10173.

Functional Cookies: Remember your preferences such as language settings, game display preferences, and recently visited sections. These improve your experience but are not essential to platform operation.

Analytics Cookies: First-party analytics cookies collect aggregated, anonymized data about how players navigate the 45jl platform — which game categories are most visited, where players encounter friction, and general usage patterns. This data is used to improve the platform experience. Analytics cookies do not identify you personally.

Security Cookies: Used to detect and prevent fraudulent activity, including bot detection, unusual login pattern identification, and session integrity verification.

45jl does not use third-party advertising or behavioral tracking cookies. No cookies are placed by external advertising networks on the 45jl platform. You may disable non-essential cookies through your browser settings; however, disabling functional or security cookies may affect your ability to use certain platform features.

Section 11

Your Rights Under Philippine Law

The Philippine Data Privacy Act of 2012 grants you the following rights with respect to your personal data held by 45jl. To exercise any of these rights, contact 45jl's Data Protection Officer using the contact details in Section 15. Requests will be processed within thirty (30) days in accordance with RA 10173.

Right to Access

Request a copy of all personal data we hold about you.

Right to Rectification

Request correction of inaccurate or incomplete personal data.

Right to Erasure

Request deletion of data no longer necessary for its original purpose, subject to legal retention obligations.

Right to Object

Object to processing based on legitimate interests or for direct marketing purposes.

Right to Block

Request suspension of processing where the accuracy of data is contested.

Right to Data Portability

Receive your data in a structured, commonly used format for transfer to another controller.

Right to Complain

File a complaint with the Philippine National Privacy Commission (NPC) if your rights are infringed.

Right to Withdraw Consent

Withdraw consent for marketing communications at any time via Account Settings, without affecting prior processing.

Please note that certain rights — particularly erasure and portability — may be limited where 45jl is legally required to retain your data under AMLA, PAGCOR regulations, or RA 10173's mandatory retention requirements. In such cases, 45jl will explain the applicable limitation in its response to your request.

Section 12

Children and Minors

The 45jl Casino platform is strictly restricted to individuals who are 21 years of age or older, as required by PAGCOR regulations governing all gambling activities in the Philippines. 45jl does not knowingly collect or process personal data from any person under the age of 21.

Age verification is conducted as part of the mandatory KYC process for every registered account. If 45jl discovers — through KYC review, player report, or any other means — that an Account has been created by a person under 21 years of age, the Account will be immediately closed, all associated personal data will be deleted or anonymized to the extent permitted by legal obligations, and the matter will be reported to PAGCOR as required under 45jl's licensing conditions.

Strict 21+ Enforcement: Any parent or guardian who believes their child has registered an account on the 45jl platform should contact 45jl's Data Protection Officer immediately. Accounts found to belong to underage individuals will be closed within 24 hours of confirmed identification.

Section 13

Cross-Border Data Transfers

45jl primarily processes personal data on servers located within the Philippines. In certain cases, data may be processed by service providers — such as cloud infrastructure providers or KYC verification services — whose systems are located outside the Philippines. Any such cross-border transfer of personal data is subject to the following safeguards as required by RA 10173:

The recipient jurisdiction provides an adequate level of data protection, or contractual safeguards equivalent to RA 10173 protections are in place via data processing agreements.
Data transferred cross-border is limited to the minimum necessary for the service being provided.
All cross-border processing relationships are documented in 45jl's NPC registration and privacy management system.

45jl will notify you if a planned cross-border transfer materially changes the processing described in this Policy, and will seek fresh consent where required under RA 10173.

Section 14

Changes to This Privacy Policy

45jl may update this Privacy Policy periodically to reflect changes in our data practices, legal obligations, or platform operations. The effective date displayed at the top of this document will be updated whenever the Policy changes. For material changes — those that significantly affect how your personal data is used — 45jl will proactively notify registered players via SMS to their registered Philippine mobile number at least seven (7) days before the changes take effect.

Your continued use of the 45jl platform after a revised Policy takes effect constitutes your acknowledgment of the updated terms. If you do not agree to a material change, you may close your Account and request data handling consistent with the prior Policy version, subject to applicable retention obligations, by contacting the Data Protection Officer.

Section 15

Contact Us & Data Protection Officer

For any questions about this Privacy Policy, to exercise your data subject rights under RA 10173, or to report a privacy concern, please contact 45jl's Data Protection Officer using the following channels:

Data Protection Officer — 45jl Casino
Email: [email protected] (Subject line: "Privacy / DPO Request")
Live Chat: Available 24/7 via the 45jl platform (accessible after login) in Tagalog and English.
Response Time: Written DPO requests acknowledged within 5 business days; substantive response within 30 days as required by RA 10173.

If you are not satisfied with 45jl's response to your privacy request or complaint, you have the right to escalate your complaint to the Philippine National Privacy Commission (NPC) through its official government channels. The NPC is the regulatory authority responsible for enforcing RA 10173 across all Philippine organizations that process personal data.

Your privacy is a legal right in the Philippines. 45jl is committed to processing your personal data lawfully, transparently, and with respect for your rights under RA 10173. Our DPO team is available to answer any question about how your data is handled on the 45jl platform.

Privacy Policy — 45jl Casino

Contents