vipph45 Privacy Policy

This Privacy Policy ("Policy") describes how vipph45 ("vipph45", "we", "us", "our") collects, uses, stores, shares, and protects the personal information of players and visitors ("you", "your", "Data Subject") who access and use the vipph45 online gaming platform at https://vipph45.net and any associated mobile interfaces or applications (collectively, the "Platform").

vipph45 is committed to safeguarding your privacy and ensuring that your personal data is handled responsibly, transparently, and in full compliance with the Republic of the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC). As a PAGCOR-regulated gaming platform, vipph45 also fulfils its data processing obligations under Philippine gaming and anti-money laundering laws.

By registering an account on vipph45, making a deposit, or otherwise using the Platform, you acknowledge that you have read and understood this Privacy 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 must discontinue use of the Platform.

For the purposes of the Philippine Data Privacy Act of 2012 and this Privacy Policy, vipph45 acts as the Personal Information Controller (PIC) in respect of the personal data collected from players and platform visitors. As PIC, vipph45 determines the purposes and means by which your personal data is processed.

vipph45 operates under a licence issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to all applicable Philippine laws governing online gaming, data privacy, and anti-money laundering compliance.

Our designated Data Protection Officer (DPO) can be contacted at: [email protected] — please include "Data Privacy / DPO" in your subject line.

vipph45 collects only the personal data that is necessary, adequate, and relevant to the purposes described in this Policy. The categories of personal data we collect are as follows:

• Full legal name (first name, middle name, last name)
• Date of birth (to verify you are 21 years of age or older)
• Email address and mobile phone number
• Residential address (city/municipality, province, country)
• Preferred username and encrypted password
• Nationality and country of residence

• Government-issued photo ID document (e.g., PhilSys National ID, SSS UMID, Passport, LTO Driver's Licence, COMELEC Voter's ID)
• Selfie or live photo submitted for facial verification purposes
• Proof of address documents where required by PAGCOR or AMLC regulations
• Source of funds documentation for high-value accounts as required by anti-money laundering regulations

• Payment method details (e.g., GCash mobile number, Maya account reference, BPI/BDO/UnionBank account identifiers — note: vipph45 does not store full bank account numbers or card numbers)
• Deposit and withdrawal history, amounts, timestamps, and statuses
• Transaction reference numbers issued by payment processors
• Cryptocurrency wallet addresses used for USDT TRC20 transactions

• Game session history, bet amounts, game outcomes, and session durations
• Bonus credits claimed, wagering progress, and promotional participation records
• Responsible gaming limit settings you have configured on your account
• Self-exclusion records and Player Welfare interaction history

• IP address and geolocation data (country/region level) at time of login and key transactions
• Device type, operating system, and browser type/version
• Session identifiers, access timestamps, and platform navigation logs
• Cookie identifiers and similar tracking technology data (see Section 8)

• Support chat transcripts, email correspondence, and any written complaints or feedback you submit to vipph45
• Survey responses and player satisfaction feedback where voluntarily provided
• Marketing communication preferences (opt-in / opt-out records)

vipph45 collects your personal data through the following channels:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal request, contact customer support, respond to a survey, or update your account profile.
• Automatically during platform use — through cookies, server logs, and analytics tools when you browse the vipph45 website or use the platform's features (see Section 8 for details on cookies).
• From payment processors — when you initiate a deposit or withdrawal, the relevant payment service provider (e.g., GCash, Maya, BPI, BDO) shares transaction confirmation and reference data with vipph45 to credit or process your account.
• From identity verification services — vipph45 may use third-party KYC verification providers to assist with document authenticity checks and facial verification. These providers act as Personal Information Processors (PIPs) under our instruction.
• From regulatory authorities — PAGCOR or AMLC may provide or request data about players in the exercise of their regulatory functions, which vipph45 is legally obligated to cooperate with.

vipph45 uses your personal data only for legitimate, specified purposes. The table below summarises each primary use of your data alongside the corresponding legal basis:

vipph45 does not use your personal data for automated decision-making that produces significant legal effects on you without human review. Where automated screening flags an account (e.g., for fraud or AML risk), a trained member of our compliance team reviews the flag before any action is taken.

Under the Philippine Data Privacy Act of 2012, vipph45 processes your personal data on one or more of the following lawful bases:

• Consent (Section 12[a] RA 10173) — For optional data uses such as marketing communications, promotional emails, and optional platform surveys. You may withdraw your consent at any time without penalty by contacting [email protected] or updating your communication preferences in your account settings.
• Contract Performance (Section 12[b]) — For processing necessary to create and manage your account, process transactions, and deliver the gaming services you requested when you registered with vipph45.
• Legal Obligation (Section 12[c]) — For data processing required under PAGCOR's licensing conditions, the Anti-Money Laundering Act (RA 9160, as amended), the Philippine Data Privacy Act itself, and any other applicable Philippine law or regulation.
• Legitimate Interests (Section 12[f]) — For fraud prevention, platform security, responsible gaming monitoring, and anonymised analytics — provided these interests are not overridden by your fundamental rights and freedoms as a data subject.

For Sensitive Personal Information (such as government ID documents), vipph45 additionally relies on the exemption applicable to processing necessary to comply with legal obligations under Sections 13(b) and 13(e) of RA 10173.

vipph45 does not sell, rent, or trade your personal data to any third party. We share your personal data only in the limited circumstances described below, and only to the extent strictly necessary for the stated purpose.

To process your deposits and withdrawals, vipph45 shares necessary transaction data with the relevant payment service providers — including GCash, Maya, BPI, BDO, UnionBank, 7-Eleven, Coins.ph, and USDT TRC20 network processors. These providers act as Personal Information Processors under data processing agreements with vipph45.

Certain game providers whose titles are available on the vipph45 platform may receive session-level gameplay data (such as a pseudonymised player ID, bet amount, and game outcome) to facilitate game rounds and resolve disputes. These providers do not receive your full identity data.

vipph45 may use regulated third-party identity verification service providers to assist with document verification and facial matching during the KYC process. These providers process your KYC data solely under vipph45's instruction and are contractually prohibited from using it for any other purpose.

vipph45 is legally required to disclose player data to PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities when required by law, court order, or regulatory directive. We do not have discretion to withhold data lawfully requested by such authorities.

In the event of a merger, acquisition, restructuring, or sale of all or part of vipph45's business assets, your personal data may be transferred to the acquiring entity as part of the transaction, subject to the same privacy protections described in this Policy. You will be notified of any such transfer via email.

vipph45 uses cookies and similar technologies (such as local storage tokens and session identifiers) to operate the platform securely, remember your preferences, and improve your overall experience. We do not use third-party advertising cookies or cross-site tracking technologies.

• Strictly Necessary Cookies — Essential for the platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. They cannot be disabled without affecting platform functionality.
• Functional Cookies — Remember your preferences such as language settings, game display options, and responsible gaming limit configurations. These persist across sessions for your convenience.
• Analytics Cookies — Collect anonymised and aggregated data on how players navigate the platform (e.g., which pages are visited most, where players encounter errors). Used solely to improve platform performance. No individual player is identified through analytics data.

You can manage or disable non-essential cookies through your browser settings at any time. However, please note that disabling strictly necessary cookies will prevent you from logging in and using the platform. Most browsers allow you to refuse cookies, delete existing cookies, or set preferences for specific websites — refer to your browser's help documentation for instructions.

vipph45 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, whichever period is longer.

Upon expiry of the applicable retention period, vipph45 securely deletes or anonymises your personal data so that it can no longer be attributed to you as an individual. Anonymised data retained for aggregate analytics purposes is no longer considered personal data under RA 10173.

vipph45 implements comprehensive technical, organisational, and physical security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure.

• Encryption in Transit — All data transmitted between your device and the vipph45 platform is protected by TLS 1.3 (Transport Layer Security) encryption. Our platform enforces HTTPS across all pages and API endpoints with no fallback to unencrypted HTTP.
• Encryption at Rest — Sensitive data stored in vipph45 databases — including identity documents, financial records, and passwords — is encrypted at rest using AES-256 encryption standards.
• Password Security — Player passwords are never stored in plain text. vipph45 uses industry-standard one-way hashing with salting (bcrypt) so that passwords cannot be recovered even by vipph45 staff.
• Access Controls — Access to personal data within vipph45 systems is restricted on a strict need-to-know basis. Staff access is role-based, logged, and regularly reviewed. Access to KYC and financial data is limited to compliance and payment operations personnel only.
• Two-Factor Authentication (2FA) — vipph45 offers 2FA for player accounts and mandates it for all internal staff accessing production systems and sensitive data.
• Penetration Testing & Vulnerability Scanning — vipph45 conducts regular security assessments, including third-party penetration tests and automated vulnerability scans, to identify and remediate security weaknesses proactively.
• Incident Response — In the event of a personal data breach that poses a real risk to data subjects, vipph45 is committed to notifying the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and affected players will be notified without undue delay as required by the NPC's Circular on Personal Data Breach Management.

Under the Philippine Data Privacy Act of 2012, you — as a data subject — have the following rights with respect to your personal data held by vipph45. These rights may be exercised by contacting our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request."

• Right to be Informed — You have the right to be informed of how your personal data is being collected and processed. This Privacy Policy fulfils that right.
• Right of Access — You have the right to request a copy of the personal data vipph45 holds about you, along with information on how it is processed. We will respond to access requests within 15 business days.
• Right to Rectification — You have the right to have inaccurate or incomplete personal data corrected. You can update basic profile information directly in your account settings, or contact our support team for corrections to sensitive data.
• Right to Erasure (Right to be Forgotten) — You have the right to request deletion of your personal data where it is no longer necessary for the purposes it was collected, where you have withdrawn consent, or where processing is unlawful. Note that this right is subject to vipph45's legal retention obligations under PAGCOR and AMLA requirements — data required by law cannot be deleted before the mandatory retention period expires.
• Right to Object — You have the right to object to the processing of your personal data for direct marketing purposes, profiling, or where processing is based on legitimate interests. Upon receipt of a valid objection to marketing, we will cease sending you promotional communications immediately.
• Right to Data Portability — You have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format (such as CSV or JSON), and to request that we transmit this data to another controller where technically feasible.
• Right to Lodge a Complaint — If you believe vipph45 has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Details on how to file a complaint are available on the NPC's official website.
• Right to Damages — You have the right to seek compensation for any damage suffered as a result of inaccurate, incomplete, outdated, false, or unlawfully obtained personal data, in accordance with Section 16(f) and Section 34 of RA 10173.

vipph45 will verify your identity before processing any data subject rights request to ensure the security of your personal data. We will not charge a fee for exercising your rights unless requests are manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.

vipph45 is an online gaming platform strictly intended for adults who are 21 years of age or older, in accordance with Philippine gaming laws and PAGCOR licensing requirements. vipph45 does not knowingly collect, use, or store personal data from individuals below the age of 21.

Age verification is a mandatory step in the vipph45 registration and KYC process. Players who cannot provide valid proof that they are 21 years of age or older will have their accounts suspended pending verification, and any funds deposited will be returned through the original payment method following an investigation.

vipph45 primarily stores and processes your personal data within the Philippines and on servers located in jurisdictions that provide an adequate level of data protection. However, in the ordinary course of operating the platform, some of your personal data may be transferred to and processed by third-party partners — such as international game providers, cloud infrastructure providers, and KYC service providers — whose systems may be located outside the Philippines.

Where personal data is transferred outside the Philippines, vipph45 ensures that appropriate safeguards are in place in compliance with the NPC's rules on cross-border data transfers. These safeguards include:

• Requiring recipient organisations to adhere to data protection standards equivalent to those required under RA 10173.
• Entering into data processing agreements with all international Personal Information Processors that contain standard contractual clauses approved by the NPC or equivalent data protection authority.
• Transferring only the minimum data necessary for the specific processing purpose to any international recipient.

By using the vipph45 platform and accepting this Privacy Policy, you consent to the cross-border transfer of your personal data under the safeguards described above.

The vipph45 platform does not contain links to third-party websites for commercial or advertising purposes. However, where references are made to regulatory bodies such as PAGCOR or the National Privacy Commission in informational content, those organisations operate their own websites and privacy policies independently of vipph45.

vipph45 is not responsible for the privacy practices, content, or data security of any third-party organisation, including payment processors whose interfaces you may be redirected to when completing a deposit or withdrawal transaction. We encourage you to review the privacy policy of any third-party service you interact with as part of the payment process.

vipph45 reviews and updates this Privacy Policy periodically to reflect changes in our data processing practices, platform features, applicable Philippine law, or NPC regulatory guidance. The "Last Updated" date displayed at the top of this page indicates when the most recent revision was made.

Where changes to this Privacy Policy are material — meaning they significantly affect how we collect, use, or share your personal data, or alter your rights as a data subject — vipph45 will notify registered players via email to the address associated with their account at least seven (7) days before the changes take effect.

Your continued use of the vipph45 platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the revised Policy, you must stop using the platform and may request account closure with withdrawal of your remaining balance.

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by vipph45, please contact our Data Protection Officer (DPO). We are committed to responding to all privacy-related inquiries promptly and transparently.

For complaints that have not been resolved through vipph45's internal process, you have the right to escalate your concern to the National Privacy Commission (NPC) of the Philippines. The NPC is the independent government body responsible for administering and implementing RA 10173 and protecting the data privacy rights of Filipino citizens.

For responsible gaming concerns, account self-exclusion, or deposit limit assistance, please visit our Responsible Gaming page or mention your concern in your support message so it is routed to our dedicated Player Welfare team.