Privacy Policy

ace45 ("ace45," "we," "us," or "our") operates the online gaming platform at ace45.club ("Platform"). This Privacy Policy ("Policy") describes how ace45 collects, uses, discloses, stores, and protects the personal information of registered players and visitors ("you" or "User") in connection with the Platform.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines. It is also consistent with the data handling standards required under ace45's PAGCOR e-gaming licence.

By accessing or using the Platform — including registering an account, making a deposit, or placing a wager — you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must discontinue use of the Platform.

ace45 collects personal data from you directly (when you provide it) and automatically (through your use of the Platform). The categories of personal data we collect include:

2.1 Identity & Contact Data

• Full legal name, date of birth, and gender
• Philippine government-issued ID details (ID type, ID number, expiry date)
• Residential address (province, city/municipality, barangay, postal code)
• Mobile phone number (Philippine format, e.g., +63 9XX XXX XXXX)
• Email address

2.2 Account & Financial Data

• ace45 username and encrypted password hash
• GCash account number, PayMaya account number, bank account details (BPI, BDO, Metrobank), or card details associated with your account
• Transaction records: deposit amounts, withdrawal amounts, dates, payment methods, and transaction reference numbers
• Wallet balance and bonus credit balance history
• Source-of-funds declarations where required under AML obligations

2.3 Gaming Activity Data

• Game names and categories played (slots, live casino, bingo, etc.)
• Bet amounts, game outcomes, session duration, and win/loss records
• Bonus and promotional activity logs
• Loyalty Program point accrual and redemption history

2.4 Technical & Usage Data

• IP address and approximate geolocation (city/province level)
• Device type, operating system, and browser version
• Session start and end timestamps
• Pages visited, features used, and navigation paths on the Platform
• Cookie identifiers and similar tracking technology data (see Section 6)

2.5 Communications Data

• Content of live chat messages, support tickets, and email correspondence with ace45 customer support
• Records of promotional communications you have opted into or out of

ace45 processes your personal data for the following purposes:

• Account creation and management: Registering your account, verifying your identity (KYC), maintaining your account settings, and processing account closure requests.
• Payment processing: Processing deposits, withdrawals, and refunds via GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard. Verifying that payment instruments belong to the account holder.
• Gaming service delivery: Enabling you to play all games on the Platform, recording game outcomes, managing your wallet balance, and crediting bonuses and Loyalty Points.
• Regulatory compliance: Fulfilling our obligations under PAGCOR's e-gaming licence terms, including player verification, AML monitoring, responsible gaming tool administration, and regulatory reporting.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, unauthorised account access, cheating, and money laundering on the Platform.
• Customer support: Responding to your queries, resolving disputes, and providing assistance with account, payment, and game-related issues.
• Marketing communications (with consent): Sending you promotional offers, bonus notifications, and Platform updates by SMS or email where you have opted in. You may withdraw consent at any time via account settings or by contacting support.
• Platform improvement: Analysing anonymised usage patterns to improve Platform performance, game selection, mobile experience, and user interface design.
• Legal compliance: Complying with applicable Philippine laws, court orders, and regulatory instructions, including the Philippine Data Privacy Act, Anti-Money Laundering Act (AMLA), and PAGCOR directives.

Under the Philippine Data Privacy Act of 2012, ace45 processes your personal data on one or more of the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and ace45 (your account Terms and Conditions), including operating your account, processing payments, and delivering gaming services.
• Legal obligation: Processing required for ace45 to comply with applicable Philippine laws and PAGCOR regulatory requirements, including KYC verification, AML reporting, and responsible gaming obligations.
• Legitimate interests: Processing for ace45's legitimate interests in preventing fraud, maintaining Platform security, and improving our services — where these interests do not override your privacy rights.
• Consent: Processing for marketing communications, where we rely on your freely given, specific, and informed consent. You may withdraw this consent at any time.

ace45 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may disclose your personal data to the following categories of recipients for the purposes described in Section 3:

• PAGCOR and Philippine regulatory authorities: We are required by our gaming licence to share certain player data with PAGCOR for regulatory oversight, responsible gaming enforcement, and investigation of suspected illegal activity.
• Payment processors: GCash (Mynt / Globe Fintech), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, and card network processors receive the transaction data necessary to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification services that process your ID documents and, where applicable, biometric liveness data solely for the purpose of verifying your identity at account registration.
• Fraud prevention and AML services: Third-party providers that help ace45 detect, investigate, and prevent fraud, money laundering, and other financial crimes on the Platform.
• Game content providers: Game studios such as JILI Gaming and live dealer providers receive pseudonymised player and bet data necessary to deliver their game content through the ace45 Platform.
• IT and cloud infrastructure providers: Hosting, database, and security service providers that process data on behalf of ace45 under binding data processing agreements.
• Law enforcement and courts: Where required by a valid court order, subpoena, or legal process under Philippine law, or where disclosure is necessary to protect the rights, property, or safety of ace45, its players, or the public.

ace45 uses cookies and similar tracking technologies to operate the Platform, maintain your login session, prevent fraud, and improve your user experience. The categories of cookies we use are:

• Essential cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without breaking core Platform functionality.
• Functional cookies: Store your preferences such as language, display settings, and game lobby filters to provide a personalised experience.
• Analytics cookies: Collect anonymised data about how you navigate the Platform, which pages you visit, and how long you spend in each section. This data is used in aggregate to improve Platform performance and usability.
• Security cookies: Used to detect and prevent fraudulent activity, multiple account creation, and other security threats.

You may manage cookie preferences through your browser settings. Note that disabling essential cookies may impair your ability to log in to or use the ace45 Platform. ace45 does not use third-party advertising cookies or share cookie data with advertising networks.

ace45 retains your personal data for as long as your account is active and for the following minimum periods after account closure, as required by applicable Philippine law and PAGCOR regulations:

• Account identity and KYC records: 5 years from account closure, in compliance with AMLA and PAGCOR retention requirements.
• Transaction and financial records: 5 years from the date of each transaction, in compliance with the Philippine AMLA and BIR (Bureau of Internal Revenue) record-keeping requirements.
• Gaming activity logs: 2 years from the date of each gaming session, unless a longer retention period is required for an ongoing dispute or regulatory investigation.
• Customer support communications: 2 years from the date of resolution of the relevant support issue.
• Marketing consent records: Until you withdraw consent, plus 1 year thereafter to document the consent withdrawal.

After the applicable retention period, personal data is securely deleted or anonymised in accordance with ace45's data destruction procedures.

ace45 implements technical and organisational measures designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ace45 Platform
• Encryption of sensitive data fields (including passwords, which are stored as salted hashes) in the Platform database
• Multi-factor authentication for all ace45 staff with access to personal data systems
• Regular third-party security audits and penetration testing of Platform infrastructure
• Access controls limiting personal data access to ace45 staff and contractors with a legitimate operational need
• Incident response procedures aligned with the NPC's mandatory 72-hour breach notification requirement

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ace45:

• Right to be informed: You have the right to be informed of how your personal data is being processed — which this Policy fulfils.
• Right of access: You may request a copy of the personal data ace45 holds about you, along with information about how it is used.
• Right to rectification: You may request correction of inaccurate or incomplete personal data in your account. Minor corrections (name spelling, address) can be made via your account settings; major changes require KYC re-verification.
• Right to erasure or blocking: You may request deletion or blocking of your personal data where processing is no longer necessary, where consent has been withdrawn, or where processing is unlawful — subject to ace45's legal retention obligations.
• Right to data portability: You may request a copy of personal data you have provided to ace45 in a structured, commonly used, machine-readable format.
• Right to object: You may object to processing of your personal data based on ace45's legitimate interests, including profiling and direct marketing. Objection to essential processing required for regulatory compliance or contractual performance may result in account closure.
• Right to damages: You have the right to file a complaint with the National Privacy Commission and to seek damages for any injury caused by a violation of your rights under RA 10173.

To exercise any of these rights, contact ace45's Data Protection Officer at the details in Section 13. ace45 will respond to all verified data rights requests within 30 calendar days.

The ace45 Platform is strictly prohibited for persons under the age of 21 years, in compliance with PAGCOR regulations and Philippine Republic Act No. 9287. ace45 does not knowingly collect personal data from persons under 21. All accounts are subject to mandatory age verification through government-issued Philippine ID before real-money gaming access is granted.

If ace45 discovers that personal data has been collected from a person under 21, the account will be immediately closed, the data will be deleted, and any deposited funds will be returned to the verified payment source. If you believe a minor has created an ace45 account, please notify us immediately at support@ace45.club.

ace45 primarily processes and stores your personal data within the Philippines. Where personal data is transferred to service providers located outside the Philippines (for example, international cloud hosting infrastructure or game content providers with servers in other jurisdictions), ace45 ensures that such transfers are subject to appropriate safeguards, including:

• Data processing agreements that require the recipient to comply with standards equivalent to the Philippine Data Privacy Act
• Standard contractual clauses or equivalent contractual protections approved by the National Privacy Commission
• Transfers only to jurisdictions that have been assessed as providing adequate data protection standards

You may request information about specific cross-border transfer safeguards by contacting our Data Protection Officer.

ace45 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. Material changes to this Policy will be communicated to registered players via the email address or mobile number associated with their account at least 7 days before the changes take effect.

The "Last updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of the Platform after the effective date of any update constitutes acceptance of the revised Policy. We encourage you to review this Policy periodically.

ace45 has designated a Data Protection Officer (DPO) as required under the Philippine Data Privacy Act of 2012. For any questions about this Policy, to exercise your data rights, or to report a privacy concern, please contact:

If you are not satisfied with ace45's response to your data rights request, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC) through official NPC channels.