45jl Privacy Policy

This Privacy Policy ("Policy") describes how 45jl ("we," "us," "our," or "the Platform"), operating the online gaming platform at 45jl.asia, collects, processes, uses, stores, protects, and discloses personal information about individuals who register for, access, or use the 45jl platform and related services ("Players," "you," or "your").

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and applicable issuances of the National Privacy Commission (NPC) of the Republic of the Philippines. 45jl is committed to responsible personal data processing and to upholding the rights of data subjects under Philippine law.

By creating a 45jl account, making a deposit, or otherwise using the platform, you acknowledge that you have read, understood, and consented to the data practices described in this Policy. If you do not consent to these practices, please do not create an account or use the 45jl platform.

For the purposes of the Data Privacy Act of 2012 and this Policy, the data controller responsible for the personal information collected through the 45jl platform is:

45jl
Platform: 45jl.asia
Contact: [email protected]

All requests relating to personal data — including access requests, correction requests, deletion requests, and complaints — should be directed to our designated Data Protection Officer (DPO), whose contact details are provided in Section 16 of this Policy.

45jl collects personal data across several categories, depending on how you interact with the platform. The categories and specific data points collected are described below.

45jl collects personal data through the following means:

• Directly from you: Information you provide during account registration, KYC verification, deposit or withdrawal requests, support interactions, and promotional opt-ins.
• Automatically from your device: Technical and usage data collected via server logs, cookies, session tracking, and platform analytics tools when you access 45jl.asia.
• From payment providers: Transaction confirmation data from GCash, PayMaya, BPI, BDO, and Metrobank when you make deposits or receive withdrawals.
• From identity verification services: Verification outcomes from third-party KYC service providers used to confirm identity documents submitted by players.
• From fraud prevention systems: Risk signals from third-party fraud detection tools that flag potentially suspicious account activity patterns.

45jl processes your personal data only where a lawful basis under the Data Privacy Act of 2012 applies. The following table sets out our primary processing activities, their purposes, and the applicable lawful basis.

45jl does not sell, rent, or trade your personal information to any third party for their independent commercial purposes. We share personal data only in the following limited circumstances, and only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank receive the minimum data necessary to process your deposit or withdrawal transactions.
• KYC and identity verification providers: Authorized third-party services that verify government-issued ID documents on behalf of 45jl in compliance with PAGCOR requirements.
• Fraud prevention and security services: Third-party tools that analyze technical signals to detect unauthorized account access, payment fraud, and bonus abuse.
• Game software providers: Game providers integrated into the 45jl platform receive anonymized session and wager data necessary to deliver and audit game outcomes.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government bodies, where disclosure is required by law, court order, or regulatory direction.
• Professional advisors: Legal, financial, and compliance advisors retained by 45jl, who are bound by confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or asset sale involving 45jl, personal data may be transferred to the successor entity, with players notified in advance.

45jl retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law or regulatory guidance. The following general retention periods apply:

• Active account data: Retained for the duration of your active 45jl account relationship.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with PAGCOR record-keeping requirements and Philippine AML regulations.
• KYC and identity verification documents: Retained for a minimum of five (5) years from the date of account closure or last transaction, whichever is later.
• Support communications: Retained for three (3) years from the date of the interaction.
• Marketing data (where consent-based): Retained until you withdraw your marketing consent or for two (2) years of account inactivity, whichever occurs first.
• Fraud investigation records: Retained for the duration of any active investigation and for a minimum of five (5) years from the resolution of the investigation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures. Anonymized data (from which you can no longer be identified) may be retained indefinitely for analytical and platform improvement purposes.

45jl implements a layered security framework to protect personal data against unauthorized access, disclosure, alteration, or destruction. Our technical and organizational security measures include:

• Encryption in transit: All data exchanged between your device and 45jl servers is encrypted using TLS 1.3, providing bank-grade protection against interception.
• Encryption at rest: Sensitive personal data stored on 45jl servers is encrypted using AES-256 encryption.
• Access controls: Personal data is accessible only to authorized 45jl personnel on a strict need-to-know basis. Access rights are reviewed quarterly and revoked immediately upon role change or employment termination.
• Password security: Player passwords are stored using industry-standard cryptographic hashing with unique salts — plaintext passwords are never stored or accessible.
• Two-factor authentication: SMS OTP-based two-factor authentication is available to all players and is encouraged as an additional account protection measure.
• Regular security audits: 45jl's security infrastructure is reviewed through periodic internal and external security assessments, including penetration testing.
• Incident response: A documented data breach response plan is in place, consistent with NPC notification requirements under the DPA.

45jl uses cookies and similar tracking technologies on 45jl.asia to operate the platform, remember your preferences, maintain your authenticated session, analyze platform usage, and — with your consent — deliver relevant promotional content.

• Strictly necessary cookies: Required for the platform to function. These include session authentication cookies that keep you logged into your 45jl account. They cannot be disabled without breaking core platform functionality.
• Functional cookies: Remember your preferences — such as language settings, display preferences, and recently played games — to personalize your experience on return visits.
• Analytical cookies: Collect anonymized usage data (pages visited, session duration, feature interactions) to help us understand how players use the platform and where improvements can be made. No personally identifiable information is used in this analysis.
• Marketing cookies (consent-based): Track whether you arrived at 45jl via a marketing campaign, to measure campaign effectiveness. These are only active if you have consented to marketing communications.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to log into and use the 45jl platform.

The 45jl platform is strictly intended for persons aged 21 years and above, consistent with PAGCOR's age requirements for online gaming in the Philippines. 45jl does not knowingly collect, process, or store personal data from individuals under the age of 21.

If 45jl becomes aware or has reasonable grounds to suspect that personal data has been collected from a person under 21 years of age, the relevant account will be immediately suspended pending investigation, any deposits will be returned to the verified payment method, all collected personal data will be permanently deleted from our systems, and the matter may be referred to the appropriate regulatory authority.

Under Republic Act No. 10173 (Data Privacy Act of 2012), you hold the following rights with respect to your personal data processed by 45jl. These rights may be exercised by contacting our Data Protection Officer using the details in Section 16.