ace45 Privacy Policy

ace45 recognises that the privacy of its Players is a fundamental right and a core operational responsibility. When you create an account, make a deposit via GCash or Maya, place a wager, or simply browse the Platform, certain personal and technical data is generated or provided. This Policy explains clearly what data we collect, why we collect it, how long we keep it, who we share it with, and what rights you hold over that data.

We have written this Policy to be as plain and straightforward as possible while maintaining the legal rigour required by Philippine data protection law. If you have any questions that this Policy does not answer, you are welcome to contact our Data Protection Officer using the details in Section 14.

This Privacy Policy applies to:

• All registered Players and unregistered visitors who access ace45.vip through any device, browser, or connection.
• Personal data collected through the Platform's registration forms, KYC processes, payment flows, live chat, and support channels.
• Technical data automatically generated by your device and browser when you interact with the Platform.
• Data received from authorised third parties such as payment processors and identity verification partners in connection with your account.

This Policy does not apply to third-party websites, payment platforms (such as the GCash or Maya apps), or game provider interfaces that operate under their own independent privacy policies. ace45 is not responsible for the privacy practices of third parties, even where links to or integrations with those third-party services are accessible from the Platform.

ace45 collects personal data across the following categories, depending on how you interact with the Platform:

ace45 does not collect special categories of sensitive personal data (such as racial or ethnic origin, religious beliefs, health data, or biometric data for identification purposes) beyond what is strictly required for mandatory identity verification under applicable Philippine gaming regulations.

ace45 processes personal data for the following purposes:

• Account Management: Creating, maintaining, verifying, and closing your Player Account; authenticating your identity at login and during sensitive transactions.
• Transaction Processing: Processing deposits and withdrawals through GCash, Maya, BPI, BDO, Metrobank, and other supported Philippine payment channels; maintaining accurate financial records.
• KYC and Anti-Money Laundering Compliance: Verifying your identity, age, and source of funds to satisfy obligations under applicable Philippine gaming regulations and anti-money laundering frameworks.
• Regulatory Reporting: Fulfilling mandatory reporting obligations to Philippine gaming authorities and financial intelligence units as required by applicable law.
• Responsible Gaming: Monitoring account activity to identify patterns indicative of problem gambling; enabling and enforcing self-exclusion, deposit limits, and cooling-off periods.
• Fraud Prevention and Platform Security: Detecting, investigating, and preventing fraudulent activity, unauthorised account access, bonus abuse, and other security threats.
• Customer Support: Responding to your queries, complaints, and support requests through live chat and email.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve Platform performance, game availability, and user experience.
• Service Communications: Sending you important account notifications, security alerts, and changes to terms or policies. These communications are not optional as they are necessary for Platform operation.
• Marketing (with consent): Where you have explicitly consented, sending promotional offers, bonus notifications, and news about new games on ace45. You may withdraw marketing consent at any time through your account settings.

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, ace45 processes personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between ace45 and the Player — including account creation, transaction processing, game delivery, and support services.
• Legal Obligation: Processing required to comply with legal obligations under Philippine gaming regulations, anti-money laundering laws, and data retention requirements mandated by Philippine gaming authorities.
• Legitimate Interests: Processing necessary for ace45's legitimate business interests, including fraud prevention, Platform security, and Platform improvement — where those interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing communications, which requires your explicit opt-in consent and may be withdrawn at any time without affecting the lawfulness of prior processing.

ace45 does not sell, rent, or trade your personal information to any third party for marketing or commercial purposes. Personal data is shared with third parties only in the following circumstances and to the minimum extent necessary:

• Payment Service Providers: GCash (G-Xchange Inc.), Maya (PayMaya Philippines Inc.), BPI, BDO, Metrobank, and other payment channels receive transaction data necessary to process your deposits and withdrawals. Each provider operates under its own privacy policy and applicable Philippine financial regulations.
• Game Providers: Third-party game providers such as JILI Gaming, PG Soft, and Pragmatic Play may receive anonymised session and technical data to deliver game content and calculate RTPs. Providers do not receive your full identity or financial data beyond what is required for game session management.
• KYC and Identity Verification Partners: Certified identity verification service providers may process your government ID data and selfie photographs solely for the purpose of age and identity verification required by applicable Philippine gaming regulations.
• Regulatory and Law Enforcement Authorities: Philippine gaming regulatory bodies, financial intelligence units, and law enforcement agencies may receive data where disclosure is required by law, court order, or a binding regulatory direction.
• IT and Infrastructure Service Providers: Cloud hosting providers, database management services, and cybersecurity partners who process data solely on ace45's instruction under binding data processing agreements with equivalent data protection obligations.

ace45 retains personal data only for as long as is necessary for the purposes described in this Policy, or for as long as required by applicable law, whichever is longer. The following general retention periods apply:

• Active Account Data: Retained for the duration of your Account's active status plus a minimum of five (5) years following Account closure, in compliance with applicable Philippine gaming and anti-money laundering regulations.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of each transaction in accordance with Philippine financial record-keeping obligations.
• KYC Documents: Government ID and identity verification records are retained for a minimum of five (5) years following Account closure or the last transaction, whichever is later.
• Support Communications: Live chat logs and support emails are retained for two (2) years from the date of the interaction, unless the matter relates to an ongoing dispute or regulatory inquiry.
• Technical and Analytics Data: Anonymised aggregated analytics data may be retained indefinitely. Identifiable technical logs are retained for no more than twelve (12) months unless required for an ongoing investigation.

Upon expiry of the applicable retention period, personal data will be securely deleted, anonymised, or archived in a manner that prevents re-identification, in accordance with ace45's data destruction procedures.

ace45 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include, but are not limited to:

• Encryption in Transit: All data transmitted between your device and the ace45 Platform is encrypted using TLS 1.2 or higher, ensuring that sensitive information including login credentials and financial data cannot be intercepted in transit.
• Encryption at Rest: Sensitive personal data stored in ace45 databases — including KYC documents and financial records — is encrypted at rest using industry-standard encryption protocols.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. Staff access is governed by role-based permissions, and all access to sensitive records is logged and audited.
• Two-Factor Authentication: Two-factor authentication is available to all Players and is enforced for all internal staff accounts with access to personal data systems.
• Penetration Testing and Security Audits: The Platform undergoes regular security assessments, including penetration testing by qualified third-party security professionals.
• Incident Response: ace45 maintains a documented data breach response procedure. In the event of a personal data breach that is likely to result in harm to affected individuals, ace45 will notify the National Privacy Commission and affected Players in accordance with the requirements of the Philippine Data Privacy Act.

ace45 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file stored on your device when you access a website. The following categories of cookies are used on ace45.vip:

• Strictly Necessary Cookies: Required for the Platform to function. These cookies manage your login session, maintain your authenticated state, and process transactions. They cannot be disabled without breaking core Platform functionality.
• Functional Cookies: Enable the Platform to remember your preferences — such as language settings and preferred game categories — to provide a more personalised experience. Disabling these cookies may reduce your experience quality but will not prevent access.
• Analytics Cookies: Collect anonymised data about how Players navigate and use the Platform, including pages visited, session duration, and feature usage. This data helps ace45 identify and resolve usability issues. ace45 uses self-hosted or privacy-respecting analytics tools — no data is shared with advertising networks.
• Security Cookies: Support fraud detection and security verification processes, including CSRF protection tokens and bot-detection mechanisms.

ace45 does not deploy third-party advertising cookies, social media tracking pixels, or cross-site behavioural profiling tools on the Platform. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your ace45 account.

Under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by ace45:

• Right to be Informed: The right to know how your personal data is being collected, processed, and used — which this Privacy Policy fulfils.
• Right to Access: The right to request a copy of the personal data ace45 holds about you, along with information about how it has been used. We will respond to verified access requests within thirty (30) days.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update basic account details directly in your account settings. For KYC document corrections, contact support.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to ace45's ability to demonstrate compelling grounds for continuing such processing.
• Right to Erasure or Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, where consent has been withdrawn, or where processing is unlawful. This right is subject to ace45's legal retention obligations under Philippine gaming and anti-money laundering regulations, which may require retention of certain data for a minimum period.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) if you believe ace45 has violated your data privacy rights.

To exercise any of these rights, please submit a written request to the ace45 Data Protection Officer using the contact details in Section 14. We may require identity verification before processing your request to ensure personal data is not disclosed to an unauthorised party.

ace45 is strictly prohibited from being accessed or used by individuals under the age of twenty-one (21). The Platform is designed for adult users only, in accordance with the minimum gambling age prescribed by applicable Philippine gaming regulations.

ace45 does not knowingly collect, retain, or process personal data belonging to individuals under 21 years of age. Age verification is conducted during the registration process, and additional KYC verification is performed prior to processing withdrawals to confirm the Account holder's age and identity.

As ace45 operates within the Philippine gaming market and uses service providers operating in the Asia-Pacific region, some personal data may be transferred to and processed in jurisdictions outside the Philippines. This may occur in connection with cloud infrastructure, KYC verification partners, or game provider servers located outside the Philippines.

Where personal data is transferred outside the Philippines, ace45 ensures that such transfers comply with the requirements of the Philippine Data Privacy Act. Transfers to foreign countries occur only:

• To countries that have been recognised as providing adequate data protection levels, or
• Where appropriate safeguards are in place, including binding contractual agreements with the receiving party that impose data protection obligations equivalent to those required under Philippine law, or
• Where the transfer is necessary to fulfil the contractual obligations of your Account — such as routing a GCash transaction through an international payment gateway.

ace45 will not transfer your personal data internationally in a manner that would deprive you of the rights afforded under the Philippine Data Privacy Act of 2012.

ace45 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, or regulatory requirements. The revised Policy will be published on the Platform with an updated effective date and last updated date at the top of the document.

Where changes are material — meaning they substantially affect how your personal data is processed or your rights in relation to that data — ace45 will provide advance notice to registered Players through their account contact details or a prominent notice on the Platform, at least fourteen (14) calendar days before the changes take effect.

ace45 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Policy, please contact us through the following channels:

• Live Chat: Available directly on the Platform, 24 hours a day, 7 days a week. Our support team can handle general data enquiries and escalate formal data rights requests to the DPO.
• Email (Data Privacy Requests): [email protected] — please use the subject line "Data Privacy Request" for formal data rights submissions. This is a plain text contact address and is not a clickable link.

ace45 will acknowledge receipt of formal data privacy requests within three (3) business days and will endeavour to resolve all requests within thirty (30) calendar days. Complex requests may require additional time, in which case you will be notified of the revised timeline.

If you believe that ace45 has not adequately addressed your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at their official channels. ace45 will cooperate fully with any NPC investigation.