ph646a Privacy Policy —
How We Handle Your Personal Data

01 Scope & Application

This Policy applies to all personal data collected and processed by ph646a in connection with your use of the ph646a Platform, including the website at ph646a.cam, all gaming products (sports betting, casino, slots, bingo), customer support interactions, promotional communications, and KYC/AML verification processes.

This Policy applies to all Players who are residents of the Republic of the Philippines or who access the ph646a Platform from within the Philippines. It supplements, and should be read in conjunction with, ph646a's Terms & Conditions.

02 Data We Collect

ph646a collects the following categories of personal data, depending on how you interact with the Platform:

03 How We Collect Data

ph646a collects personal data through the following channels:

• Direct submission: Information you provide during account registration, KYC verification, deposit/withdrawal requests, support interactions, and promotional opt-ins.
• Automated technical collection: Data automatically recorded when you access the Platform, including IP addresses, device identifiers, browser type, pages visited, and session duration via server logs and analytics tools.
• Payment processors: Transaction confirmation data received from GCash, Maya, BPI, BDO, Metrobank, and other integrated payment providers when you deposit or withdraw funds.
• Identity verification providers: Where ph646a uses third-party KYC providers to validate submitted identity documents, those providers may return verification results (pass/fail and document metadata) to ph646a.
• PAGCOR and regulatory sources: In limited circumstances, ph646a may receive or be required to cross-reference data with PAGCOR or other government databases to comply with licensing obligations, including the PAGCOR Exclusion List.

04 Legal Basis for Processing

Under the Data Privacy Act of 2012 and its IRR, ph646a processes personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the ph646a Terms & Conditions, including account management, game provision, and financial transactions.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act (Republic Act No. 9160, as amended), the Data Privacy Act, and other applicable Philippine laws and regulations.
• Legitimate interests: Processing necessary for ph646a's legitimate business interests including fraud prevention, platform security, responsible gaming enforcement, and business analytics — where these interests do not override your fundamental rights.
• Consent: Where required by law and not covered by the above bases — for example, for direct marketing communications — ph646a will obtain your explicit prior consent before processing. You may withdraw consent at any time without affecting lawfulness of prior processing.

05 How We Use Your Data

ph646a uses your personal data for the following specific purposes:

• Creating, managing, and verifying your ph646a Account
• Processing deposits and withdrawals via GCash, Maya, and other payment methods
• Conducting identity verification (KYC) and anti-money laundering checks as required by law
• Providing customer support through live chat and email
• Enforcing ph646a's responsible gaming obligations, including deposit limits, self-exclusion, and underage player detection
• Detecting, investigating, and preventing fraud, collusion, cheating, and other prohibited activities
• Complying with PAGCOR licensing requirements and responding to regulatory inquiries
• Sending you account-related notifications (transaction confirmations, security alerts, KYC status updates) — these are non-marketing and cannot be opted out of while your Account is active
• Sending promotional communications and bonus offers, where you have opted in to receive them
• Improving Platform performance, user experience, and game offerings through aggregated analytics
• Maintaining audit trails and records as required by PAGCOR and the Anti-Money Laundering Council (AMLC)

06 Data Sharing & Disclosure

6.1 Third-Party Service Providers

ph646a shares personal data with licensed third-party service providers strictly necessary to operate the Platform. All such providers are bound by data processing agreements that prohibit them from using your data for any purpose other than providing the specified service to ph646a. Categories of service providers include: payment processors (GCash/Maya/banks), KYC identity verification providers, game content providers, cloud hosting and infrastructure providers, fraud detection systems, and customer support platform providers.

6.2 Regulatory and Law Enforcement Disclosure

ph646a will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities when required by law, court order, or valid regulatory demand. ph646a will not notify you of such disclosure where doing so would be unlawful (for example, where prohibited by a court order or AMLC freeze order).

6.3 PAGCOR Exclusion List

In compliance with PAGCOR's responsible gaming framework, ph646a checks new registrations against the PAGCOR Exclusion List. If your name appears on this list, ph646a is legally obligated to deny your registration and report the attempted access to PAGCOR without prior notice to you.

07 Cookies & Tracking Technologies

ph646a uses cookies and similar tracking technologies on the Platform to ensure functionality, maintain session security, and gather analytics data that helps us improve the Platform experience.

7.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to function — including maintaining your logged-in session, security tokens, and language preferences. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your preferences such as game display settings, deposit method preferences, and notification settings across sessions.
• Analytics Cookies: Collect aggregated, anonymized data about how Players navigate the Platform, which pages are visited most frequently, and where errors occur — used to improve Platform performance.
• Security Cookies: Support fraud detection, login anomaly detection, and session integrity verification.

ph646a does not use third-party advertising or behavioral tracking cookies. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will impair your ability to log in and use the Platform.

08 Data Security

ph646a implements appropriate technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and ph646a servers
• AES-256 encryption for sensitive data stored at rest, including identity documents and financial records
• Access controls limiting employee access to personal data on a strict need-to-know basis
• Multi-factor authentication for administrative access to systems containing personal data
• Regular penetration testing and security audits conducted by independent cybersecurity professionals
• Intrusion detection systems and real-time monitoring for unauthorized access attempts
• Secure data backup procedures with off-site storage and regular restore testing

While ph646a takes these measures seriously, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your login credentials and for notifying ph646a immediately at [email protected] if you suspect unauthorized access to your Account.

09 Data Retention

ph646a retains personal data for the following periods, after which data is securely deleted, anonymized, or archived in accordance with applicable law:

• Account and identity data: Retained for the duration of your active Account plus five (5) years following Account closure, as required by PAGCOR and AMLC regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as mandated by the Anti-Money Laundering Act.
• Gaming and betting records: Retained for five (5) years from the date of each transaction, in accordance with PAGCOR record-keeping requirements.
• Customer support communications: Retained for two (2) years from the date of the last interaction.
• Marketing opt-in/opt-out records: Retained for the duration of your Account and for three (3) years thereafter as evidence of consent status.
• Technical and session logs: Retained for twelve (12) months on active servers, then archived for a further twelve (12) months for security investigation purposes.

10 Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph646a:

• Right to be Informed: You have the right to know that ph646a is collecting your personal data, the purposes for which it is processed, and how it will be shared — which this Policy provides.
• Right to Access: You may request a copy of the personal data ph646a holds about you, including the purposes of processing and any third parties to whom it has been disclosed.
• Right to Correction: If any personal data ph646a holds about you is inaccurate, incomplete, or outdated, you have the right to request correction.
• Right to Erasure (Right to be Forgotten): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected — subject to ph646a's legal obligations to retain data under PAGCOR, AML, and tax regulations, which may override this right.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to other processing based on legitimate interests, subject to ph646a's ability to demonstrate compelling legitimate grounds.
• Right to Data Portability: You may request your personal data in a structured, commonly used, and machine-readable format for transfer to another service provider, where technically feasible.
• Right to File a Complaint: If you believe ph646a has violated your data privacy rights, you have the right to file a complaint with the National Privacy Commission (privacy.gov.ph).

11 Minors

The ph646a Platform is strictly restricted to persons who are at least 21 years of age. ph646a does not knowingly collect personal data from individuals under 21. If ph646a becomes aware that personal data has been collected from a person under 21, that Account will be immediately suspended, the data will be deleted (subject to any regulatory retention obligations relating to the detection of underage access), and the matter will be reported to PAGCOR in accordance with responsible gaming obligations.

If you have reason to believe that a person under 21 has registered on ph646a, please report this immediately to [email protected].

12 Cross-Border Data Transfers

ph646a's primary data processing infrastructure is located in data centers serving the Philippine market. In limited circumstances, personal data may be processed by third-party service providers located outside the Philippines — for example, where a licensed game provider's servers or a KYC verification provider's systems are hosted internationally.

Where such cross-border transfers occur, ph646a ensures they are conducted in compliance with Section 21 of the Data Privacy Act and the NPC's rules on cross-border data transfers, including the use of appropriate contractual safeguards such as standard data protection clauses that impose DPA-equivalent obligations on the recipient.

13 Changes to This Policy

ph646a may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or the NPC's regulatory guidance. Material changes will be communicated to registered Players by email or in-platform notification at least seven (7) days before the changes take effect.

The current effective version of this Policy is always accessible at ph646a.cam/privacy-policy. Your continued use of the Platform after the effective date of any amendment constitutes your acknowledgment of the updated Policy. If you do not accept the changes, you must cease using the Platform and may request Account closure through our support channels.

14 Contact Our Data Protection Officer

ph646a has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with the Data Privacy Act and this Policy. If you have any questions, concerns, or requests relating to your personal data, please contact the ph646a DPO through the following channels:

• Email: [email protected] — Subject line: "Data Privacy Request" or "DPO Inquiry"
• Live Chat: Available 24/7 through the ph646a Platform — request to be connected to the Data Privacy team
• Coverage: Serving all Philippine regions including Metro Manila, Cebu, Davao, Quezon City, Makati, Iloilo, Cagayan de Oro, and nationwide

For complaints that cannot be resolved directly with ph646a, you have the right to escalate to the National Privacy Commission of the Philippines, which administers the Data Privacy Act and handles complaints from data subjects. Details on filing a complaint with the NPC are available on the NPC's official government website.