646lol Privacy Policy

About This Privacy Policy

This Privacy Policy describes how 646lol collects, uses, stores, shares, and protects the personal data of players and visitors who access the 646lol platform. It applies to all interactions with 646lol, including account registration, gameplay, financial transactions, customer support communications, and browsing of the 646lol website.

By registering an account on 646lol 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 to this Privacy Policy, you must not use the 646lol platform.

This Privacy Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, which together govern your use of the 646lol platform.

Personal Data We Collect

646lol collects personal data that is necessary to provide you with a safe, secure, and compliant gaming experience. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name, date of birth, and gender
• Email address and mobile phone number
• Residential address (including barangay, city/municipality, province, and postal code)
• Government-issued ID details (e.g., driver's licence number, passport number, PhilSys National ID number, SSS/UMID number) collected during KYC verification
• Selfie or photograph submitted for identity verification purposes

2.2 Financial Data

• GCash mobile number or PayMaya / Maya account details used for deposits and withdrawals
• Bank account details (account name, account number, bank name) for bank transfer transactions
• Debit card details (card number, expiry date) where applicable
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method references

2.3 Gaming & Activity Data

• Game history, including games played, wager amounts, outcomes, and session durations
• Bonus and promotion usage history
• Responsible gaming tool settings (e.g., deposit limits, self-exclusion status)
• Customer support interaction records, including chat transcripts and email correspondence

2.4 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser type and version
• Cookie identifiers and session tokens
• Pages visited, time spent on pages, and clickstream data

How We Use Your Personal Data

646lol uses the personal data we collect for the following purposes:

• Account Management: To create, verify, maintain, and administer your 646lol account, including processing your registration and KYC verification.
• Service Delivery: To provide you with access to the 646lol platform, including all games, promotions, and features available to registered players.
• Financial Transactions: To process your deposits and withdrawals via GCash, PayMaya, bank transfer, and debit card, and to maintain accurate financial records.
• Regulatory Compliance: To comply with our obligations under Philippine law, including the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and PAGCOR regulatory requirements — including mandatory transaction reporting and KYC obligations.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, account takeover, and other security threats.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion.
• Customer Support: To respond to your enquiries, complaints, and support requests in a timely and effective manner.
• Platform Improvement: To analyse usage patterns and player behaviour (in aggregated, anonymised form) to improve the 646lol platform, fix bugs, and develop new features.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your consent to receive such communications. You may opt out at any time.

Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 646lol processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — i.e., to provide you with the 646lol gaming service as described in our Terms & Conditions.
• Legal Obligation: Processing is necessary to comply with our legal obligations under Philippine law, including AMLA reporting requirements, PAGCOR regulatory obligations, and tax reporting requirements.
• Legitimate Interests: Processing is necessary for our legitimate interests in operating a secure, fair, and commercially viable gaming platform — including fraud prevention, security monitoring, and platform analytics — provided those interests are not overridden by your rights and interests.
• Consent: For marketing communications and non-essential cookies, we rely on your freely given, specific, and informed consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Data Sharing & Disclosure

646lol does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash (GXI), PayMaya / Maya, and participating Philippine banks, to the extent necessary to process your deposits and withdrawals.
• Game Providers: Third-party game software providers who supply the games available on the 646lol platform, to the extent necessary to deliver those games and maintain game integrity.
• Identity Verification Services: KYC and identity verification service providers who assist us in verifying your identity and government-issued documents in compliance with PAGCOR and AMLA requirements.
• Regulatory Authorities: The Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where we are required by law to disclose your information.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other lawful process.
• Professional Advisers: Our lawyers, auditors, and accountants, where necessary for the provision of professional services to 646lol, subject to strict confidentiality obligations.
• IT & Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who process data on our behalf under binding data processing agreements.

Cookies & Tracking Technologies

The 646lol platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and analyse platform usage. The types of cookies we use include:

• Strictly Necessary Cookies: These cookies are essential for the platform to function. They enable core features such as account login, session management, and security. These cookies cannot be disabled.
• Functional Cookies: These cookies remember your preferences — such as your preferred language and display settings — to provide a more personalised experience.
• Analytics Cookies: These cookies collect anonymised information about how players use the 646lol platform, helping us understand which features are most popular and where improvements can be made. We use this data in aggregated form only.
• Marketing Cookies: These cookies are used to deliver relevant promotional content to you based on your interests and activity on the platform. They are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 646lol platform. For strictly necessary cookies, no opt-out is available as they are required for the platform to operate.

Data Retention

646lol retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

• 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 AMLA record-keeping requirements.
• KYC & Identity Documents: Retained for a minimum of five (5) years from the date of submission or from the date of the last transaction, whichever is later, as required by PAGCOR and AMLA regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA and Bureau of Internal Revenue (BIR) requirements.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer retention period is required for ongoing dispute resolution or legal proceedings.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years, to demonstrate compliance with consent requirements.

When your personal data is no longer required, 646lol will securely delete or anonymise it in accordance with our data disposal procedures.

Data Security

646lol implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 646lol platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls ensuring that only authorised 646lol personnel can access personal data, and only to the extent necessary for their role.
• Regular security assessments, penetration testing, and vulnerability scanning of the 646lol platform and infrastructure.
• Multi-factor authentication (MFA) for access to systems that store or process personal data.
• Incident response procedures to detect, contain, and report data breaches in accordance with the National Privacy Commission's breach notification requirements.

Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 646lol:

• 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 646lol 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 we hold 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 our legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that 646lol has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 13 of this Policy. We will respond to all verified requests within thirty (30) days of receipt, in accordance with the Data Privacy Act.

Children & Minors

The 646lol platform is strictly intended for persons who are 21 years of age or older. 646lol does not knowingly collect personal data from individuals under the age of 21.

Parents and guardians are encouraged to use parental control tools and to monitor their children's online activity to prevent underage access to online gaming platforms.

Cross-Border Data Transfers

In some cases, your personal data may be transferred to, stored in, or processed in countries outside the Philippines — for example, where our cloud infrastructure providers or game software partners operate servers in other jurisdictions.

Where such transfers occur, 646lol ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Philippine Data Privacy Act. These safeguards may include:

• Binding data processing agreements incorporating standard contractual clauses approved by the National Privacy Commission.
• Transfers to countries or organisations that the NPC has determined provide an adequate level of data protection.
• Other legally recognised transfer mechanisms under the Data Privacy Act and its Implementing Rules and Regulations.

You may request further information about the specific safeguards applicable to any cross-border transfer of your personal data by contacting our Data Protection Officer.

Updates to This Privacy Policy

646lol may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When we make material changes to this Policy, we will notify registered players by email or via an in-platform notification, and we will update the "Last Updated" date at the top of this page.

We encourage you to review this Privacy Policy periodically to stay informed about how 646lol protects your personal data. Your continued use of the 646lol platform after any update to this Policy constitutes your acceptance of the revised terms.

Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 646lol handles your personal data, please contact our Data Protection Officer (DPO):

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the 646lol platform

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated:

• National Privacy Commission (NPC): [email protected] — 3rd Floor, Core G, GSIS Headquarters, Financial Center, Roxas Boulevard, Pasay City, Metro Manila

We aim to resolve all data privacy enquiries within thirty (30) days of receipt. For complex requests, we may require up to sixty (60) days, in which case we will notify you of the extended timeline.