Privacy Policy

01 Overview

This Privacy Policy ("Policy") describes how hot646 ("hot646," "we," "us," or "our") collects, uses, stores, discloses, and otherwise processes personal data in connection with your use of the hot646 online gaming platform, including all associated websites, mobile-optimized interfaces, games, features, and services (collectively, the "Platform").

hot646 is committed to protecting the privacy and personal data of all users, particularly those based in the Philippines. This Policy is designed to comply with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC").

By registering an account on the hot646 Platform, logging in, or otherwise using the Platform, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

This Policy should be read together with hot646's Terms & Conditions, which govern your use of the Platform generally.

02 Personal Data We Collect

hot646 collects the following categories of personal data from users of the Platform:

Identity & Contact Data

• Full legal name
• Date of birth
• Gender
• Nationality and country of residence
• Residential address (including barangay, city/municipality, province, and ZIP code for Philippine-based users)
• Email address
• Mobile phone number

Identity Verification (KYC) Data

• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, UMID, PRC ID, voter's ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or facial image for identity verification purposes
• Proof of payment method ownership where required

Financial Data

• Payment method details (e.g., GCash mobile number, Maya account reference, bank account details for BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, or debit card details)
• Transaction history, including deposits, withdrawals, and gaming activity
• Account balance information

Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session data, including login timestamps and session duration
• Pages visited, features used, and game activity logs
• Cookies and similar tracking technologies (see Section 9)

Communications Data

• Records of communications with hot646 customer support, including live chat transcripts and email correspondence
• Feedback, complaints, and dispute records

03 How We Collect Your Data

hot646 collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions.
• Automatically: Through cookies, web beacons, log files, and similar technologies when you access and use the Platform. See Section 9 for details.
• From third-party service providers: Including payment processors (e.g., GCash, Maya, banks), identity verification providers, and fraud detection services, where such providers share data with us in connection with your use of the Platform.
• From publicly available sources: Where permitted by law, hot646 may supplement your data with information from publicly available sources for fraud prevention and compliance purposes.

04 Purpose of Processing

hot646 processes your personal data for the following purposes:

• Account management: To register, maintain, and administer your hot646 account.
• Identity verification (KYC): To verify your identity and age (21+) in compliance with PAGCOR requirements and anti-money laundering regulations.
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the features of the Platform.
• Customer support: To respond to your inquiries, complaints, and requests.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct.
• Regulatory compliance: To comply with applicable Philippine laws and regulations, including the DPA, Anti-Money Laundering Act (AMLA), and PAGCOR requirements.
• Responsible gaming: To monitor gaming activity and implement responsible gaming tools, including deposit limits and self-exclusion.
• Marketing and promotions: To send you information about hot646 promotions, bonuses, and updates, where you have consented to receive such communications.
• Platform improvement: To analyze usage patterns and improve the performance, features, and user experience of the Platform.
• Legal proceedings: To establish, exercise, or defend legal claims.

05 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, hot646 processes your personal data on the following legal bases:

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual necessity: Where processing is necessary for the performance of the contract between you and hot646 (i.e., the Terms & Conditions), including account management, service delivery, and payment processing.
• Legal obligation: Where processing is necessary for hot646 to comply with a legal obligation, including KYC/AML requirements and PAGCOR regulatory obligations.
• Legitimate interests: Where processing is necessary for the legitimate interests of hot646, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and interests.

06 Sharing Your Personal Data

hot646 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:

• Payment service providers: Including GCash, Maya, and Philippine banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification service providers engaged by hot646 to verify your identity and age.
• Fraud prevention and security providers: Service providers that assist hot646 in detecting and preventing fraudulent activity and ensuring platform security.
• Game software providers: Game developers and providers whose games are available on the Platform, to the extent necessary for game delivery and technical support.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law or regulation.
• Legal and professional advisors: Lawyers, auditors, and other professional advisors engaged by hot646 in connection with legal proceedings or compliance matters.
• Business successors: In the event of a merger, acquisition, or sale of all or part of hot646's business, your personal data may be transferred to the successor entity, subject to the same privacy protections.

All third-party service providers engaged by hot646 are required to process your personal data only in accordance with hot646's instructions and applicable data protection laws.

07 Data Retention

hot646 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general guide:

• Account data: Retained for the duration of your account and for a period of at least five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• KYC documents: Retained for a minimum of five (5) years following the end of the business relationship, as required by the Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years following the date of the transaction.
• Customer support records: Retained for a period of three (3) years following the resolution of the relevant inquiry or complaint.
• Marketing data: Retained until you withdraw your consent to receive marketing communications.

When personal data is no longer required, hot646 will securely delete or anonymize it in accordance with applicable data protection standards.

08 Data Security

hot646 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including KYC documents and financial information.
• Access controls limiting access to personal data to authorized personnel on a need-to-know basis.
• Regular security assessments and vulnerability testing of the Platform.
• Employee training on data privacy and security best practices.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, hot646 will notify the National Privacy Commission (NPC) and affected users in accordance with the requirements of the DPA and NPC Circular No. 16-03.

While hot646 takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are also responsible for maintaining the security of your account credentials and for notifying hot646 immediately if you suspect any unauthorized access to your account.

09 Cookies & Tracking Technologies

hot646 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security and fraud prevention functions. A cookie is a small text file placed on your device when you visit the Platform.

hot646 uses the following categories of cookies:

• Strictly necessary cookies: Essential for the operation of the Platform, including maintaining your login session and enabling core security features. These cookies cannot be disabled without affecting Platform functionality.
• Performance and analytics cookies: Used to collect information about how users interact with the Platform, such as pages visited and features used, to help hot646 improve the Platform's performance and user experience.
• Functional cookies: Used to remember your preferences and settings, such as your preferred language and display options.
• Security and fraud prevention cookies: Used to detect and prevent fraudulent activity and unauthorized access to the Platform.

You can control the use of non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies, refer to your browser's help documentation.

10 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 hot646:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, as set out in this Policy.
• Right of access: You have the right to request a copy of the personal data that hot646 holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request the correction of inaccurate or incomplete personal data held by hot646.
• Right to erasure or blocking: You have the right to request the deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn your consent and there is no other legal basis for processing.
• Right to object: You have the right to object to the processing of your personal data on grounds relating to your particular situation, including processing for direct marketing purposes.
• 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 it to another data 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 hot646 has processed your personal data in violation of the DPA.

To exercise any of the above rights, please contact hot646's Data Protection Officer (DPO) using the contact details provided in Section 14. hot646 will respond to your request within a reasonable timeframe and in accordance with the requirements of the DPA. Please note that certain rights may be subject to limitations where processing is required for legal or regulatory compliance purposes.

11 Minors & Age Policy

The hot646 Platform is strictly intended for individuals who are at least 21 years of age, in accordance with PAGCOR regulations governing casino-style gambling in the Philippines. hot646 does not knowingly collect personal data from individuals under the age of 21.

If hot646 becomes aware that personal data has been collected from a person under the age of 21, it will take immediate steps to delete such data and close the associated account. Any winnings associated with an underage account will be forfeited.

If you are a parent or guardian and believe that your child under the age of 21 has provided personal data to hot646, please contact us immediately using the details in Section 14 so that we can take appropriate action.

12 International Data Transfers

In some cases, your personal data may be transferred to, stored in, or processed in countries outside the Philippines, for example where hot646's service providers or game software partners operate servers or facilities in other jurisdictions.

Where such transfers occur, hot646 ensures that appropriate safeguards are in place to protect your personal data in accordance with the requirements of the DPA and NPC regulations. These safeguards may include contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law.

By using the hot646 Platform, you acknowledge and consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

13 Amendments to This Policy

hot646 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. Where changes are material, hot646 will provide reasonable notice to registered users via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is indicated at the top of this page. Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically to stay informed of how hot646 protects your personal data.

14 Contact & Data Protection Officer

hot646 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests relating to this Policy or the processing of your personal data, please contact our DPO:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe that your data privacy rights have been violated. The NPC can be reached through its official government channels.

hot646 is committed to resolving all data privacy concerns promptly and fairly. We aim to acknowledge all DPO inquiries within five (5) business days and to provide a substantive response within thirty (30) days, in accordance with NPC guidelines.