1. Who We Are
45PHWin ("we," "us," or "our") is an online gaming platform operating under the domain 45phwin.app, serving registered players in the Philippines. For the purposes of the Data Privacy Act of 2012, 45PHWin acts as the Personal Information Controller (PIC) for all data collected through this platform.
Any questions, concerns, or requests related to your personal data should be directed to our Data Privacy Officer (DPO) at privacy@45phwin.app.
2. Data We Collect
We collect the following categories of personal information to provide and improve the 45PHWin service:
| Category |
Examples |
Purpose |
| Identity Data |
Full name, date of birth, government ID number |
KYC verification, age check |
| Contact Data |
Email address, mobile number |
Account setup, notifications |
| Financial Data |
GCash/bank account (last 4 digits), transaction history |
Deposits, withdrawals, AML checks |
| Technical Data |
IP address, device type, browser, session logs |
Security, fraud detection |
| Usage Data |
Games played, bet history, session duration |
Responsible gaming, personalisation |
| Communications |
Support chat transcripts, email threads |
Dispute resolution, quality assurance |
We do not collect sensitive personal information such as racial origin, political opinions, religious beliefs, or health data unless specifically required by law.
3. How We Collect Your Data
45PHWin collects your personal data through the following channels:
- Direct submission: When you fill out the registration form, complete KYC verification, make a deposit, or contact our support team.
- Automated collection: Through cookies, log files, and analytics tools when you browse or use the platform.
- Payment processors: When you transact via GCash, Maya, BDO, BPI, UnionBank, or card networks, your payment provider may share transaction metadata with us.
- Third-party KYC providers: Identity verification partners may return confirmed data points from government database lookups.
- Referral programme: If a friend refers you, we receive the referring player's account ID to attribute the reward.
4. How We Use Your Data
Your personal data is used strictly for the following purposes:
- Creating and managing your 45PHWin account
- Verifying your identity and age in compliance with PAGCOR requirements
- Processing deposits, withdrawals, and bonus credits
- Detecting and preventing fraud, money laundering, and cheating
- Providing customer support and resolving disputes
- Sending transactional notifications (e.g., deposit confirmations, withdrawal updates)
- Sending promotional communications — only if you have opted in
- Analysing platform usage to improve our games and features
- Complying with legal and regulatory reporting obligations
- Enforcing our Terms and Conditions and Responsible Gaming policies
We do not use your data for automated decision-making that produces legal or similarly significant effects without human review.
5. Legal Basis for Processing
Under the Data Privacy Act of 2012, we process your personal information on the following legal grounds:
- Contractual necessity: Processing required to provide the services you signed up for (account management, payments, gameplay).
- Legal obligation: Processing required to comply with PAGCOR licensing conditions, AMLC reporting, NPC regulations, and tax laws.
- Legitimate interests: Fraud prevention, platform security, and business analytics — always balanced against your privacy rights.
- Consent: Marketing communications and non-essential cookies — you may withdraw consent at any time.
6. Sharing Your Data
45PHWin does not sell your personal data. We may share it with the following categories of recipients, strictly on a need-to-know basis:
- Payment processors (GCash, Maya, BDO, BPI, UnionBank, Visa/Mastercard) to execute transactions
- KYC/AML service providers for identity verification and anti-fraud checks
- Game content providers (e.g., JILI Games) who operate the game servers — only session tokens, no full personal profiles
- IT and cloud infrastructure providers who host and maintain the platform under strict data processing agreements
- Regulatory authorities (PAGCOR, AMLC, NPC, BIR) when legally required
- Law enforcement agencies when we receive a valid legal order
All third-party processors are bound by data processing agreements that prohibit them from using your data for any purpose other than the service they provide to 45PHWin.
7. Cookies & Tracking Technologies
45PHWin uses cookies and similar tracking technologies to enhance your experience. Here's what we use and why:
- Essential cookies: Required for login sessions, account security, and core platform functionality. Cannot be disabled.
- Performance cookies: Collect anonymised data on page load times and error rates to help us fix issues faster.
- Analytics cookies: Track aggregate usage patterns (pages visited, game categories browsed) to guide platform improvements.
- Preference cookies: Remember your language setting, display preferences, and notification choices.
You can manage non-essential cookie preferences through your browser settings or by contacting our support team. Note that disabling certain cookies may affect platform functionality.
8. Data Retention
We keep your personal data only for as long as necessary to fulfil the purposes outlined in this policy, or as required by law:
- Active account data: Retained for the lifetime of your account plus 5 years after closure (PAGCOR and AMLC requirement).
- Transaction records: Retained for 10 years in compliance with Anti-Money Laundering Act (AMLA) regulations.
- Support communications: Retained for 3 years for dispute resolution purposes.
- Marketing consent records: Retained until you withdraw consent, plus 1 year for compliance documentation.
- Inactive accounts: If your account has been dormant for 12 months, we may anonymise non-essential data while retaining financial records as required by law.
After the applicable retention period, your data is securely deleted or irreversibly anonymised.
9. Your Privacy Rights
Under RA 10173, you have the following rights regarding your personal data held by 45PHWin:
Right to Access
Request a copy of the personal data we hold about you and information on how it's being used.
Right to Correction
Ask us to update inaccurate or incomplete personal information in your account.
Right to Erasure
Request deletion of your personal data when it's no longer needed, subject to legal retention requirements.
Right to Object
Object to processing based on legitimate interests, including direct marketing communications.
Right to Portability
Receive your personal data in a structured, commonly used format to transfer to another service.
Right to Complain
Lodge a complaint with the National Privacy Commission (NPC) if you believe your rights have been violated.
To exercise any of these rights, contact our Data Privacy Officer at privacy@45phwin.app. We will respond within 15 business days. Identity verification may be required before processing your request.
10. Children's Privacy
45PHWin is strictly for adults. We do not knowingly collect or process personal data from individuals under the age of 21 years, as required by Philippine gaming regulations. If we discover that a minor has submitted personal data to us, the account will be closed immediately and all data permanently deleted. If you are a parent or guardian and believe your child has registered on the platform, please contact us immediately at support@45phwin.app.
11. Security Measures
We implement technical and organisational measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction:
- TLS 1.3 encryption for all data in transit between your device and our servers
- AES-256 encryption for sensitive data at rest, including financial records
- Multi-factor authentication (MFA) available for all player accounts
- Role-based access controls ensuring only authorised staff can access personal data
- Regular penetration testing and vulnerability assessments by independent security firms
- 24/7 fraud monitoring with automated flagging of unusual account activity
- Data breach response plan — in the event of a confirmed breach affecting your data, we will notify you and the NPC within 72 hours as required by law
While we take every reasonable precaution, no internet transmission is 100% secure. We recommend using a strong, unique password for your 45PHWin account and enabling MFA in your account settings.
12. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our data practices, technology, or legal requirements. When we make material changes, we will:
- Update the "Last Updated" date at the top of this page
- Display a notice on the 45PHWin homepage or your account dashboard
- Send an email notification to your registered address for significant changes
Your continued use of 45PHWin after the effective date of any revision constitutes acceptance of the updated Privacy Policy. We encourage you to revisit this page periodically to stay informed of how we handle your data.
