45phspin Privacy Policy

This Privacy Policy describes how 45phspin collects, uses, stores, shares, and protects the personal data of players and visitors who access the 45phspin platform, including our website and mobile application. It applies to all personal data processed by 45phspin in connection with the provision of our gaming services to players in the Philippines.

This policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy should be read together with the 45phspin Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. Where there is any conflict between this Privacy Policy and the Terms & Conditions on matters of data privacy, this Privacy Policy shall prevail.

45phspin collects only the personal data that is necessary for the purposes described in this Privacy Policy. The categories of personal data we collect include the following:

2.1 Registration & Identity Data

• Full legal name as it appears on your government-issued ID
• Date of birth (used to verify the 21+ age requirement)
• Residential address in the Philippines
• Email address and mobile number
• Username and encrypted password

2.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine passport, UMID, SSS ID, driver's license, PhilSys National ID)
• Proof of residential address (e.g., utility bill, bank statement)
• Selfie or facial image for liveness verification, where required
• Source of funds documentation, where required by anti-money laundering regulations

2.3 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts in Philippine Peso (PHP)
• Payment method details (e.g., GCash account reference, PayMaya reference, BPI, BDO, or Metrobank account details — stored in tokenized or masked form only)
• Transaction history and account balance records

2.4 Gaming Activity Data

• Game session records, including games played, bet amounts, wins, and losses
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)

2.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps and login history
• Cookie identifiers and similar tracking data (see Section 8)

2.6 Communications Data

• Records of your communications with 45phspin customer support
• Survey responses and feedback you voluntarily provide
• Marketing communication preferences

45phspin collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey.
• Automatically — when you access and use the 45phspin platform, through cookies, server logs, and similar tracking technologies that record your device and session information.
• From third-party service providers — including identity verification providers, payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), and fraud prevention services, who may share data with us as part of their service delivery.
• From regulatory and law enforcement authorities — where we are legally required to receive or verify information about a player.

45phspin does not collect personal data from social media platforms or third-party data brokers for the purpose of targeting players with advertising.

45phspin uses the personal data it collects for the following purposes:

45phspin will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

Under the Data Privacy Act of 2012, 45phspin processes your personal data on the following legal bases:

• Contractual necessity — processing is necessary to perform our obligations under the Terms & Conditions you have agreed to, including account management, payment processing, and game provision.
• Legal obligation — processing is required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR licensing requirements, and the Data Privacy Act of 2012.
• Legitimate interests — processing is necessary for 45phspin's legitimate interests in fraud prevention, platform security, and responsible gaming monitoring, provided those interests are not overridden by your rights and interests.
• Consent — for marketing communications and certain non-essential cookies, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

45phspin does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

• Payment processors — GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity verification providers — third-party KYC and anti-fraud service providers who assist 45phspin in verifying player identities and preventing fraudulent activity.
• Game content providers — licensed game studios and live dealer operators whose games are available on the 45phspin platform, to the extent necessary for game delivery and dispute resolution.
• IT and infrastructure providers — cloud hosting, data storage, and cybersecurity service providers who process data on 45phspin's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities — including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and Philippine law enforcement agencies, where disclosure is required by law or court order.
• Professional advisers — lawyers, auditors, and accountants, where necessary for legal, compliance, or financial purposes, subject to professional confidentiality obligations.

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

• Account and identity data — retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements.
• Transaction and financial data — retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• KYC documents — retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Gaming activity data — retained for the duration of your account and for up to three (3) years following account closure for dispute resolution and responsible gaming purposes.
• Customer support communications — retained for up to three (3) years from the date of the communication.
• Marketing preferences and consent records — retained until you withdraw consent, plus a reasonable period thereafter for compliance documentation purposes.

Upon expiry of the applicable retention period, 45phspin will securely delete or anonymize your personal data in accordance with its data disposal procedures. Anonymized data that can no longer identify you may be retained indefinitely for statistical and analytical purposes.

45phspin uses cookies and similar tracking technologies on its website and mobile application. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and improve your experience on the platform.

The types of cookies used by 45phspin include:

• Strictly necessary cookies — essential for the operation of the 45phspin platform, including session management, login authentication, and security functions. These cannot be disabled without affecting platform functionality.
• Functional cookies — used to remember your preferences, such as language settings and game display options, to provide a more personalized experience.
• Analytics cookies — used to collect aggregated, anonymized data about how players use the 45phspin platform, helping us identify areas for improvement. These are only set with your consent.
• Security cookies — used to detect and prevent fraudulent activity, unauthorized access, and other security threats.

45phspin does not use third-party advertising cookies or permit third-party advertisers to place cookies on the 45phspin platform.

45phspin implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 45phspin platform.
• Encryption at rest for sensitive personal data stored on 45phspin's servers, including KYC documents and financial data.
• Access controls limiting access to personal data to authorized 45phspin personnel and service providers on a strict need-to-know basis.
• Multi-factor authentication for internal systems that process personal data.
• Regular security audits and vulnerability assessments of the 45phspin platform and infrastructure.
• Incident response procedures for detecting, reporting, and responding to personal data breaches in accordance with the Data Privacy Act of 2012.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 45phspin will notify the National Privacy Commission (NPC) and affected players in accordance with the timelines and requirements prescribed by Philippine data privacy regulations.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 45phspin:

• Right to be informed — you have the right to be informed about how your personal data is collected, used, and processed, which is the purpose of this Privacy Policy.
• Right of access — you have the right to request a copy of the personal data that 45phspin holds about you, along with information about how it is being processed.
• Right to rectification — you have the right to request correction of any inaccurate or incomplete personal data that 45phspin holds about you.
• Right to erasure — you have 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 45phspin's legal retention obligations.
• Right to object — you have 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 — you have the right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to withdraw consent — where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint — you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 45phspin has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact the 45phspin support team. We will respond to all verified data subject requests within thirty (30) days of receipt, in accordance with the Data Privacy Act of 2012. In complex cases, this period may be extended by a further thirty (30) days, and you will be notified accordingly.

The 45phspin platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. 45phspin does not knowingly collect personal data from individuals under the age of 21.

If 45phspin becomes aware that it has inadvertently collected personal data from a person under the age of 21, it will immediately close the associated account, cancel any pending transactions, and securely delete the personal data in question. Any funds deposited by an underage user will be returned to the source payment method after deducting any winnings generated during the period of underage use.

If you believe that a minor has registered an account on 45phspin, please contact our support team immediately so that we can take appropriate action.

In the course of providing its services, 45phspin may transfer your personal data to service providers or infrastructure located outside the Philippines, including game content providers and cloud infrastructure operators. Any such cross-border transfer of personal data will only be carried out where:

• The recipient country provides an adequate level of data protection as determined by the National Privacy Commission of the Philippines; or
• Appropriate safeguards are in place, such as contractual clauses approved by the NPC, to ensure that your personal data receives a level of protection equivalent to that provided under the Data Privacy Act of 2012; or
• The transfer is necessary for the performance of a contract between you and 45phspin, or for the implementation of pre-contractual measures taken at your request.

45phspin will not transfer your personal data to any jurisdiction that does not provide adequate data protection safeguards without first obtaining your explicit consent, except where required by Philippine law.

45phspin 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. The date of the most recent revision is displayed at the top of this page.

Where changes to this Privacy Policy are material — meaning they significantly affect your rights or how we process your personal data — 45phspin will notify registered players via the email address associated with their account at least fourteen (14) days before the changes take effect.

Your continued use of the 45phspin platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the updated policy, you should cease using 45phspin and may request account closure by contacting our support team.

We encourage you to review this Privacy Policy periodically to stay informed about how 45phspin protects your personal data.

If you have any questions, concerns, or complaints about this Privacy Policy or the way 45phspin handles your personal data, please contact our Data Privacy Officer through the following channels:

If you are not satisfied with 45phspin's response to your privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory body responsible for administering and enforcing the Data Privacy Act of 2012 in the Philippines.

This Privacy Policy was last reviewed and updated on January 1, 2026. It supersedes all previous versions of the 45phspin Privacy Policy.