p646 is committed to protecting the privacy and personal data of every player on our platform. This Privacy Policy explains what data we collect, why we collect it, how we use and protect it, and what rights you have under Philippine law.
This Privacy Policy ("Policy") describes how p646 ("p646," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "Player," or "User") who access or use the p646 online gaming platform, including the website at p646.net and all associated services (collectively, the "Platform").
p646 operates in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. We are also guided by the data protection principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity, and confidentiality.
By registering an account or using the p646 Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform and contact us to close your account.
p646 acts as the Personal Information Controller (PIC) with respect to the personal data collected through the Platform, as defined under Section 3(h) of the Data Privacy Act of 2012. As PIC, p646 determines the purposes and means of processing your personal information.
Where p646 engages third-party service providers to process personal data on its behalf (for example, payment processors, KYC verification providers, and cloud infrastructure providers), those parties act as Personal Information Processors (PIPs) and are contractually bound to process data only on p646's documented instructions and in compliance with the DPA.
p646 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and the DPA. Contact details for the DPO are provided in Section 14 of this Policy.
p646 collects personal data through several channels, including account registration, KYC verification, platform usage, customer support interactions, and automated technical means. The categories of personal data we collect include:
| Category | Examples | Collection Method |
|---|---|---|
| Identity Data | Full legal name, date of birth, nationality, government-issued ID number | Registration, KYC verification |
| Contact Data | Email address, Philippine mobile number, residential address | Registration, account settings |
| Financial Data | GCash number, bank account details, transaction history, deposit and withdrawal records | Payment processing, transaction logs |
| Verification Data | Selfie photograph, ID document images, liveness check data | KYC verification process |
| Usage Data | Game history, session duration, betting patterns, login timestamps, device type | Automated platform logging |
| Technical Data | IP address, browser type and version, operating system, cookie identifiers | Automated collection via cookies and server logs |
| Communications Data | Live chat transcripts, support ticket content, email correspondence | Customer support interactions |
p646 does not intentionally collect sensitive personal information as defined under Section 3(l) of the DPA (such as health data, political opinions, or religious beliefs) unless specifically required by law or regulatory obligation, such as for responsible gaming assessments.
p646 processes your personal data for the following specific, legitimate purposes:
p646 will not process your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.
Under the Data Privacy Act of 2012, p646 relies on the following legal bases for processing your personal data:
p646 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 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:
All third-party processors engaged by p646 are required to enter into data processing agreements that impose obligations consistent with the DPA and this Policy.
p646 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:
Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with p646's data disposal procedures.
p646 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:
While p646 takes all reasonable steps to protect your data, no system is completely immune to security risks. You are responsible for maintaining the security of your account credentials and for notifying p646 immediately if you suspect unauthorized access to your account.
p646 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how the Platform is used.
The types of cookies used by p646 include:
You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the Platform. p646 does not use cookies to track your activity on third-party websites.
Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by p646:
To exercise any of these rights, please contact the p646 Data Protection Officer using the contact details in Section 14. p646 will respond to all data subject requests within fifteen (15) business days of receipt, as required by the DPA.
The p646 Platform is strictly intended for individuals aged 21 years and above, in compliance with PAGCOR regulations governing casino-style online gambling in the Philippines. p646 does not knowingly collect personal data from individuals under the age of 21.
If p646 discovers or has reason to believe that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data collected, and report the matter to the relevant regulatory authorities where required.
If you are a parent or guardian and believe that your child under 21 has provided personal data to p646, please contact us immediately at the details provided in Section 14 so that we can take appropriate action.
p646 primarily processes and stores personal data within the Republic of the Philippines. In certain circumstances, personal data may be transferred to or accessed from servers or service providers located outside the Philippines, for example where cloud infrastructure or specialized technology services are provided by international vendors.
Any cross-border transfer of personal data by p646 is conducted in compliance with Section 21 of the Data Privacy Act of 2012 and the NPC's guidelines on cross-border data transfers. p646 ensures that adequate safeguards are in place, including contractual clauses that impose DPA-equivalent data protection obligations on the recipient.
p646 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining NPC approval.
p646 reserves the right to update or am end this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, p646 will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect, where practicable.
The "Last Updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically to stay informed about how p646 protects your personal data. Your continued use of the Platform following the effective date of any update constitutes your acceptance of the revised Policy.
Previous versions of this Policy are available upon request by contacting the Data Protection Officer.
If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by p646, please contact our Data Protection Officer through the following channels:
p646 will acknowledge receipt of your request within three (3) business days and provide a substantive response within fifteen (15) business days, as required under the Data Privacy Act of 2012.
If you are not satisfied with p646's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the DPA.
Here are the six core commitments p646 makes to every player regarding the handling of personal data. These highlights complement — but do not replace — the full Policy above.
p646 processes all player data in full compliance with Republic Act No. 10173, the Philippine Data Privacy Act of 2012. Our practices are regularly reviewed to align with NPC guidelines and any updates to the law.
All data transmitted to and from the p646 Platform is protected by TLS encryption. Sensitive data stored in our systems uses AES-256 encryption — the same standard used by major financial institutions across the Philippines.
p646 will never sell, rent, or trade your personal information to third parties for their own marketing purposes. Your data is used solely to provide and improve the p646 Platform and to meet our legal obligations.
As a p646 player, you have the right to access, correct, delete, and port your personal data at any time. Submit a request to our Data Protection Officer and we will respond within 15 business days as required by the DPA.
p646 keeps your data only as long as necessary. Most account data is retained for five years after closure to meet PAGCOR and AMLA requirements, after which it is securely deleted or anonymized per our disposal procedures.
In the unlikely event of a data breach that poses a real risk of serious harm, p646 will notify the National Privacy Commission within 72 hours and inform affected players promptly, in line with NPC breach notification guidelines.