Privacy Policy

p646 is committed to protecting the personal data of every Filipino player who uses our platform. We operate p646.org — the Philippines' premier online casino and gaming platform — and in doing so, we collect and process personal information about the players who register and interact with us.

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR), as administered by the National Privacy Commission (NPC) of the Philippines. It also reflects our obligations as a platform operating within the regulatory framework established by PAGCOR.

p646 is committed to the three core principles of data privacy under Philippine law: transparency — we tell you clearly what data we collect and why; legitimate purpose — we only collect data for purposes that are lawful, specified, and compatible with our operations; and proportionality — we only collect what is actually necessary for those purposes. Nothing more.

2.1 The data controller responsible for the personal information collected and processed through the p646 platform is the operator of p646.org. For all privacy-related inquiries, requests, and complaints, our Data Protection Officer (DPO) can be contacted at the details provided in Section 14 of this Policy.

2.2 Where p646 engages third-party service providers (such as payment processors, game studios, or identity verification services) to process personal data on our behalf, those entities act as data processors under written agreements that contractually bind them to data security and confidentiality obligations consistent with the Philippine Data Privacy Act.

3.1 Registration Data. When you create a p646 account, we collect: your full legal name, date of birth, email address, Philippine mobile number, and a username and password of your choosing. This information is necessary to create and administer your account.

3.2 Identity Verification (KYC) Data. To comply with PAGCOR requirements and Philippine Anti-Money Laundering Act (AMLA) obligations, we collect copies of government-issued identification documents — such as a Philippine passport, SSS/UMID card, or driver's license — when you submit a withdrawal request or when required by our compliance procedures. We may also request a selfie or video verification.

3.3 Financial Data. We collect records of deposits and withdrawals, including the payment method used (GCash, PayMaya, BPI, BDO, Metrobank, or other), transaction amounts in Philippine Peso, timestamps, and transaction reference numbers. We do not store full GCash PINs, bank account passwords, or card CVV numbers.

3.4 Gaming Activity Data. We collect detailed records of your gameplay on p646 — including games played, bet amounts, win/loss outcomes, session durations, and bonus usage. This data is used for account management, regulatory compliance, and responsible gaming monitoring.

3.5 Communications Data. We collect and retain records of your communications with p646 — including support chat transcripts, emails to [email protected], and any feedback or dispute submissions. These records are kept for quality assurance and dispute resolution purposes.

3.6 Technical & Device Data. When you access the p646 platform, our systems automatically collect your IP address, browser type and version, device type and operating system, referring URL, and session activity logs. This data is used for security monitoring, fraud prevention, and platform performance optimization.

3.7 Location Data. We may collect approximate location data (derived from your IP address) to verify that you are accessing the platform from a jurisdiction where our services are available and to detect account access from unusual locations.

4.1 p646 uses the personal data we collect for the following specific purposes:

• Account creation and management — to register your p646 account, authenticate your logins, and manage account settings;
• Payment processing — to process GCash, PayMaya, and bank deposits and withdrawals, and to maintain accurate transaction records;
• KYC and age verification — to comply with PAGCOR requirements and verify that all players are 21 years of age or older;
• Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, account abuse, multi-accounting, and money laundering;
• Regulatory compliance — to fulfil p646's obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act, and the Data Privacy Act;
• Responsible gaming — to monitor gaming behavior for indicators of problem gambling and to enforce deposit limits, session limits, and self-exclusion requests;
• Customer support — to respond to queries, process complaints, and resolve disputes;
• Platform improvement — to analyze aggregated, anonymized usage data to improve the performance, usability, and game selection of p646;
• Direct marketing — where you have given consent, to send you promotional communications about p646 bonuses, new games, and platform updates. You may withdraw this consent at any time.

5.1 Under the Philippine Data Privacy Act, p646 relies on the following lawful bases to process your personal data:

• Contractual necessity — processing required to perform our contract with you (the Terms & Conditions), including account management, payment processing, and gameplay;
• Legal obligation — processing required to comply with PAGCOR licensing conditions, AMLA obligations, NPC requirements, and other applicable Philippine laws;
• Legitimate interests — processing for fraud prevention, platform security, and improving our services, where these interests are not overridden by your rights;
• Consent — processing for direct marketing purposes, where you have explicitly opted in. You may withdraw consent at any time by contacting [email protected].

6.1 p646 does not sell your personal data to any third party. We may share your data only in the following limited circumstances:

• Payment processors — GCash (G-Xchange, Inc.), PayMaya (PayMaya Philippines, Inc.), BPI, BDO, Metrobank, and other banking partners receive only the transaction data necessary to process your deposit or withdrawal;
• Identity verification providers — where third-party KYC technology is used to verify government-issued ID documents, that provider receives only the data required for verification and is bound by confidentiality obligations;
• Game studios and providers — game providers integrated into the p646 platform may receive anonymized session data for game performance monitoring. No personally identifiable data is shared with game studios for marketing purposes;
• Regulatory authorities — we will disclose personal data to PAGCOR, the AMLC (Anti-Money Laundering Council), the NPC, law enforcement agencies, or Philippine courts when legally required to do so;
• Professional advisors — lawyers, accountants, and auditors engaged by p646 may access data to the minimum extent required to perform their professional services, subject to professional confidentiality obligations.

6.2 All third-party processors engaged by p646 are required to enter into data processing agreements that impose obligations consistent with the Philippine Data Privacy Act and restrict the use of personal data to the specific purpose for which it was shared.

7.1 p646 takes the security of financial data particularly seriously given that our platform processes Philippine Peso transactions through GCash, PayMaya, and major Philippine banks.

7.2 p646 does not store your GCash PIN, your PayMaya PIN, your internet banking password, or any card verification numbers. Payment authentication is handled directly by the respective payment provider within their own secure environment.

7.3 Transaction records — including deposit and withdrawal amounts, timestamps, and payment method references — are retained as required by Philippine financial regulations and PAGCOR compliance obligations. These records are stored in encrypted form.

7.4 p646 employs a mandatory withdrawal-to-same-payment-method policy wherever technically supported. This means withdrawals are processed to the same GCash number or bank account used for the deposit associated with the funds being withdrawn — a key AML control measure.

8.1 p646 uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device by your browser.

8.2 We use the following categories of cookies:

• Essential cookies — strictly necessary for the platform to function, including session authentication and security tokens. These cannot be disabled.
• Functional cookies — remember your preferences such as language and display settings to improve your experience on p646.
• Analytics cookies — collect anonymized data about how players navigate and use p646 to help us improve platform performance and usability. No personally identifiable data is passed to analytics providers.
• Security cookies — used for fraud detection, bot prevention, and login security monitoring.

8.3 You may manage or delete non-essential cookies through your browser settings at any time. Note that disabling essential cookies will prevent you from accessing your p646 account.

9.1 p646 retains personal data for only as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable Philippine law.

9.2 The following standard retention periods apply:

• Account and KYC data — retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR licensing conditions and AMLA obligations;
• Transaction records — retained for a minimum of five (5) years from the transaction date in compliance with Philippine financial record-keeping requirements;
• Support communications — retained for two (2) years from the date of the final communication, unless the matter relates to an unresolved dispute or regulatory investigation;
• Marketing preference records — retained until you withdraw consent and for a period of one (1) year thereafter to demonstrate compliance;
• Technical logs — retained for ninety (90) days for security monitoring purposes, then securely deleted.

9.3 Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized using industry-standard data destruction procedures.

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by p646:

• Right to be Informed — you have the right to be informed of what personal data p646 collects about you and how it is processed. This Privacy Policy fulfils that obligation.
• Right to Access — you may request a copy of the personal data p646 holds about you. We will respond to verified access requests within thirty (30) days.
• Right to Rectification — if any personal data p646 holds about you is inaccurate or incomplete, you have the right to request correction. Minor corrections (e.g., contact details) can be made via your account settings.
• Right to Erasure — subject to our legal retention obligations, you may request deletion of your personal data. Requests are processed within thirty (30) days. Note that KYC and transaction data must be retained for the periods specified in Section 9 regardless of erasure requests.
• Right to Data Portability — you may request a copy of your personal data in a structured, machine-readable format.
• 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 Lodge a Complaint — if you believe p646 has not handled your personal data in compliance with the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

10.2 To exercise any of the above rights, please submit a written request to our Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will verify your identity before processing any request.

11.1 p646 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction.

11.2 Key security measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your browser and p646's servers;
• Encryption of sensitive data at rest, including KYC documents and identity verification records;
• Role-based access controls ensuring that p646 staff can only access personal data relevant to their specific operational function;
• Two-factor authentication available to all players and mandatory for p646 staff accessing internal systems;
• Continuous intrusion detection and security monitoring of platform infrastructure;
• Regular security assessments and penetration testing conducted by independent security professionals;
• Data breach response procedures aligned with NPC notification requirements.

11.3 In the event of a personal data breach that is likely to result in risk to your rights and freedoms, p646 will notify the NPC within seventy-two (72) hours of becoming aware of the breach and will notify affected players without undue delay.

12.1 If p646 discovers or is notified that a person under the age of 21 has registered an account, the account will be immediately suspended, all personal data associated with the account will be deleted from our active systems (subject to any mandatory regulatory retention requirements), and the registration will be reported to the relevant PAGCOR authority.

12.2 Parents or guardians who believe their child may have registered on p646 should contact us immediately at [email protected] so that we can take prompt action.

13.1 p646 may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable Philippine law. When we make material changes, we will notify registered players by email to the address associated with their account at least seven (7) days before the changes take effect.

13.2 The current version of this Privacy Policy is always available at p646.org/privacy-policy. The "Last updated" date at the top of this page indicates when the most recent revision was made.

13.3 Your continued use of the p646 platform following notification of changes constitutes your acceptance of the revised Privacy Policy. If you do not accept the revised policy, you should cease using the platform and may request account closure.

For all privacy-related inquiries, data access requests, complaints, or to exercise any of your rights under the Philippine Data Privacy Act, please contact the p646 Data Protection Officer:

If you are not satisfied with our response to a privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which may be contacted through the NPC's official channels as published on the NPC website.

p646 is committed to resolving all data privacy concerns in a transparent, timely, and fair manner consistent with our obligations under Philippine law and our commitment to the Filipino players who trust us with their data.