Your Privacy Matters at ace45

1Introduction

This Privacy Policy ("Policy") describes how ace45 ("ace45," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "Player," or "User") who access or use the ace45 online casino platform available at ace45.net (the "Platform").

ace45 is committed to protecting the privacy of all players, particularly those based in the Philippines. This Policy is drafted in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

By registering an account on the ace45 Platform or by continuing to use our services, 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 any part of this Policy, you should discontinue use of the Platform and contact us to request deletion of your data.

This Policy should be read together with the ace45 Terms & Conditions, which govern your use of the Platform.

2Personal Data We Collect

ace45 collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

ace45 does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive information is collected (such as a copy of your government-issued ID), it is handled with the highest level of security and access controls.

3How We Use Your Personal Data

ace45 uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your ace45 player account, including processing your registration, verifying your identity, and enabling you to log in securely.
• Service Delivery: To provide you with access to all ace45 games, features, promotions, and services available on the Platform.
• Payment Processing: To process your deposits and withdrawals via GCash, PayMaya/Maya, bank transfer, and debit card, and to maintain accurate financial records of all transactions.
• Regulatory Compliance: To comply with our obligations under Philippine law, including PAGCOR licensing requirements, anti-money laundering (AML) regulations, and the Data Privacy Act of 2012.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal conduct on the Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 support team.
• Responsible Gaming: To monitor gaming behavior and identify players who may be at risk of problem gambling, and to administer responsible gaming tools such as deposit limits, session timers, and self-exclusion.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the ace45 Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may opt out at any time.

4Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform our obligations under the ace45 Terms & Conditions, including account management, payment processing, and service delivery.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR requirements and anti-money laundering obligations.
• Legitimate Interests: Processing is necessary for ace45's legitimate interests in operating a secure, fair, and compliant gaming platform, including fraud prevention and platform security.
• Consent: For marketing communications and non-essential cookies, processing is based on your explicit consent, which you may withdraw at any time without affecting the lawfulness of prior processing.

5Sharing Your Personal Data

ace45 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, PayMaya/Maya, and partner Philippine banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC service providers who assist ace45 in verifying player identities and documents in compliance with regulatory requirements.
• Game Software Providers: Licensed game studios and software providers whose games are available on the ace45 Platform, to the extent necessary to deliver game services.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where required by law or regulatory obligation.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and technical infrastructure providers who support the operation of the ace45 Platform under strict data processing agreements.
• Legal and Professional Advisors: Lawyers, auditors, and compliance consultants engaged by ace45, subject to professional confidentiality obligations.

All third parties with whom ace45 shares personal data are required to handle such data in accordance with applicable Philippine data privacy laws and are prohibited from using your data for any purpose other than the specific service they provide to ace45.

6Cookies and Tracking Technologies

ace45 uses cookies and similar tracking technologies to enhance your experience on the Platform. The types of cookies we use include:

• Essential Cookies: Required for the Platform to function correctly, including maintaining your login session and remembering your preferences. These cannot be disabled without affecting Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform, helping us identify areas for improvement. These are only set with your consent.
• Functional Cookies: Used to remember your language preferences, display settings, and other personalization choices to improve your experience.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and other security threats.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may prevent certain features of the ace45 Platform from functioning correctly. For more information on managing cookies in popular Philippine mobile browsers, please contact our support team.

7Data Security

ace45 implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• TLS/SSL encryption for all data transmitted between your device and ace45 servers.
• AES-256 encryption for sensitive data stored in our databases, including financial information and identity documents.
• Multi-factor authentication options for player accounts.
• Regular security audits and penetration testing by independent cybersecurity firms.
• Strict access controls limiting employee access to personal data on a need-to-know basis.
• 24/7 security monitoring and automated threat detection systems.
• Secure data centers with physical access controls and redundant infrastructure.

While ace45 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. In the event of a personal data breach that is likely to result in harm to affected players, ace45 will notify the National Privacy Commission and affected individuals within the timeframes required under the Data Privacy Act of 2012.

8Data Retention

ace45 retains your personal data for as long as necessary to fulfill the purposes described in this Policy, or as required by applicable Philippine law. The following general retention periods apply:

• Account Data: Retained for the duration of your active account, plus five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine anti-money laundering regulations.
• KYC Documents: Retained for five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Support Communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for dispute resolution.
• Technical and Usage Data: Retained for up to twelve (12) months in identifiable form, after which it is anonymized or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with ace45's data disposal procedures.

9Your Data Privacy Rights

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: The right to be informed of how your personal data is being collected and processed — which this Policy fulfills.
• Right of Access: The right to request a copy of the personal data ace45 holds about you, along with information about how it is being used.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal 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, machine-readable format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact the ace45 Data Privacy Officer via our support team. We will respond to all verified requests within fifteen (15) business days, as required under the Data Privacy Act of 2012.

10Children's Privacy

The ace45 Platform is strictly intended for individuals aged 21 years and above, in accordance with PAGCOR regulations governing online casino gaming in the Philippines. ace45 does not knowingly collect personal data from individuals under the age of 21.

If ace45 becomes aware that personal data has been collected from an individual under 21 years of age, we will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered on the ace45 Platform, please contact our support team immediately.

11International Data Transfers

ace45 primarily stores and processes your personal data within the Philippines. Where it is necessary to transfer personal data to service providers or partners located outside the Philippines (for example, cloud infrastructure providers or game software studios), ace45 ensures that such transfers are conducted in compliance with the Data Privacy Act of 2012 and that appropriate safeguards are in place, including contractual data processing agreements that require the recipient to provide a level of data protection equivalent to that required under Philippine law.

12Changes to This Privacy Policy

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 regulatory requirements. Where changes are material, ace45 will notify registered players via email or in-platform notification at least fourteen (14) days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the ace45 Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

13Contact Our Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way ace45 handles your personal data, please contact our Data Privacy Officer:

• Email: [email protected]
• Support Channel: 24/7 Live Chat on the ace45 Platform
• Response Time: Within 72 hours for privacy inquiries; within 15 business days for formal data subject requests
• Languages: English and Filipino

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with ace45's response to your privacy concern.