hoy646 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") sets out how hoy646 ("hoy646," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "Player," or "Data Subject") who access or use the hoy646 online gaming platform at hoy646.app and all associated services (collectively, the "Platform").

hoy646 is committed to protecting your personal data in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, the issuances of the National Privacy Commission ("NPC"), and all other applicable Philippine data protection laws and regulations.

As a PAGCOR-regulated online gaming operator, hoy646 is also subject to the data handling and record-keeping obligations prescribed by PAGCOR and the Anti-Money Laundering Council (AMLC). These regulatory obligations inform certain aspects of how we collect, retain, and disclose your information.

2. Who We Are — Data Controller

For the purposes of the Data Privacy Act of 2012, hoy646 is the Personal Information Controller in respect of the personal data collected through the Platform. This means hoy646 determines the purposes and means by which your personal data is processed.

hoy646 operates as a Philippines-based online casino and sports betting platform under PAGCOR oversight, serving Filipino players across Metro Manila, Cebu, Davao, Quezon City, and throughout the Philippine archipelago. All data processing activities are conducted in compliance with the DPA and applicable PAGCOR licensing conditions.

Where hoy646 engages third-party service providers to process personal data on its behalf (for example, payment processors or game software providers), those parties act as Personal Information Processors under written data processing agreements that obligate them to handle your data in accordance with this Policy and Philippine law.

3. Personal Data We Collect

hoy646 collects personal data from you directly when you register, use the Platform, contact support, or participate in promotions. We also collect certain data automatically when you access the Platform. The categories of data we collect are described below.

3.1 Registration and Account Data

When you create a hoy646 account, we collect:

• Full legal name
• Date of birth (to verify age eligibility — you must be 21 or older)
• Philippine mobile number
• Email address
• Username and encrypted password
• Residential address in the Philippines

3.2 Identity Verification (KYC) Data

Before processing your first withdrawal, hoy646 is required by PAGCOR and AMLC regulations to verify your identity. KYC data may include:

• Government-issued Philippine ID (e.g., PhilSys National ID, Passport, Driver's License, UMID, PRC ID, Voter's ID)
• Selfie photograph for liveness verification
• Proof of address (e.g., utility bill, bank statement addressed to your registered address)
• Source of funds documentation (where required by AML rules)

3.3 Financial Transaction Data

• GCash account number (linked to your verified mobile number)
• PayMaya / Maya account details
• Bank account details (BPI, BDO, Metrobank, UnionBank, etc.) for bank transfer withdrawals
• Deposit and withdrawal history, including amounts, timestamps, and method used
• Transaction reference numbers

3.4 Gameplay and Betting Data

• Game sessions, bet amounts, game outcomes, and win/loss records
• Bonus usage and wagering requirement progress
• Sports betting selections, stakes, and settlement records

3.5 Technical and Device Data

• IP address and approximate geographic location
• Device type, operating system, and browser type
• Session timestamps and duration
• Platform access logs

3.6 Communications Data

• Live chat transcripts with hoy646 support agents
• Email correspondence
• Complaint and dispute records

4. How hoy646 Uses Your Data

hoy646 processes your personal data only for specified, explicit, and legitimate purposes. We do not process your data in ways that are incompatible with the purposes stated below.

hoy646 does not use your personal data for automated decision-making that produces legal or similarly significant effects on you without human review, except where required by AMLC regulations for transaction monitoring purposes.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, hoy646 relies on the following legal bases for processing your personal data:

• Consent: Where you have given clear, specific, and informed consent — for example, for marketing communications. You may withdraw consent at any time via your account settings without affecting the lawfulness of prior processing.
• Performance of Contract: Processing necessary to fulfill our contractual obligations to you under the hoy646 Terms and Conditions, including account management, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including the Anti-Money Laundering Act, PAGCOR licensing requirements, and NPC regulations.
• Legitimate Interest: Processing necessary for the legitimate interests of hoy646, such as fraud prevention, platform security, and service improvement — provided such interests are not overridden by your rights and interests.

6. Data Sharing and Disclosure

hoy646 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your data only in the following circumstances:

6.1 Service Providers and Processors

hoy646 engages carefully selected third-party processors to support Platform operations. These may include payment gateway providers (GCash, PayMaya, banking partners), game software providers, cloud hosting providers, KYC and identity verification platforms, and customer support technology providers. All processors are bound by data processing agreements requiring compliance with the DPA and this Policy.

6.2 Regulatory and Law Enforcement Disclosure

hoy646 is required by law to disclose certain information to regulatory authorities including PAGCOR, the AMLC, the National Privacy Commission, and law enforcement agencies when required by valid legal process, court order, or statutory obligation. Suspicious transaction reports (STRs) submitted to the AMLC are strictly confidential under Philippine AML law and may not be disclosed to the subject of the report.

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of assets involving hoy646, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in advance where practicable.

6.4 With Your Consent

hoy646 may share your data with third parties in circumstances not described above where you have given explicit prior consent to such sharing. You may withdraw such consent at any time.

7. Cookies and Tracking Technologies

The hoy646 Platform uses cookies and similar tracking technologies to ensure the Platform functions correctly, to maintain your login session, and to analyze how the Platform is used so we can improve it.

7.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to function — including session management, authentication tokens, and security cookies. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language, display settings, and responsible gaming tool configurations.
• Analytics Cookies: Collect aggregated, anonymized data about how players navigate the Platform. This helps hoy646 identify usability issues and improve the player experience.
• Security Cookies: Used to detect and prevent fraud, bot activity, and unauthorized access attempts.

7.2 Managing Cookies

You can manage non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies. Note that disabling strictly necessary cookies will prevent the hoy646 Platform from functioning correctly and you will not be able to log in or play games. hoy646 does not use third-party advertising cookies or share cookie data with advertising networks.

8. Data Retention

hoy646 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following indicative retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years after account closure, in compliance with PAGCOR licensing requirements and AMLC record-keeping obligations.
• Financial transaction records: Retained for a minimum of five (5) years as required by the Anti-Money Laundering Act.
• Gameplay and betting records: Retained for five (5) years for regulatory audit purposes.
• Customer support communications: Retained for three (3) years from the date of last interaction.
• Marketing consent records: Retained for as long as you remain opted in, plus one (1) year after opt-out as evidence of consent management.
• Technical and device logs: Retained for ninety (90) days unless required for ongoing fraud investigations.

Where data is no longer required for any lawful purpose, hoy646 will securely delete or anonymize it using industry-standard data destruction methods. Anonymized data — from which no individual can be identified — may be retained indefinitely for statistical analysis.

9. Data Security

hoy646 implements technical, organizational, and physical security measures appropriate to the nature of the personal data processed. These include:

• TLS 1.3 encryption for all data in transit between your device and hoy646 servers.
• AES-256 encryption for sensitive data at rest, including KYC documents and financial records.
• Password hashing using one-way cryptographic algorithms — your actual password is never stored in plaintext and cannot be retrieved by hoy646 staff.
• Access controls restricting data access to authorized personnel on a need-to-know basis, with audit logging of all access events.
• Multi-factor authentication for hoy646 staff accessing systems containing personal data.
• Intrusion detection systems and regular security assessments by independent third parties.
• Secure data centers with physical access controls and environmental protections.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, hoy646 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects without undue delay where required by the DPA.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by hoy646. To exercise any of these rights, contact hoy646's Data Protection Officer using the details in Section 14.

• Right to Be Informed: You have the right to know what personal data hoy646 collects about you, how it is used, and with whom it is shared. This Policy fulfills that obligation.
• Right to Access: You may request a copy of the personal data hoy646 holds about you. Requests will be processed within thirty (30) days of receipt.
• Right to Correction / Rectification: You may request that inaccurate or incomplete personal data be corrected. Most account details can be updated directly within your hoy646 account settings.
• 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. Note that this right is subject to hoy646's statutory retention obligations under PAGCOR and AMLC regulations — data legally required to be retained cannot be deleted upon request.
• Right to Data Portability: You may request that your personal data be provided to you in a structured, commonly used, and machine-readable format.
• Right to Object: You may object to processing of your personal data where it is based on legitimate interest, including processing for direct marketing purposes. An objection to marketing will be actioned immediately.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.
• Right to Lodge a Complaint: If you believe hoy646 has breached your data privacy rights, you may lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Children and Minors

The hoy646 Platform is strictly restricted to individuals who are twenty-one (21) years of age or older. hoy646 does not knowingly collect personal data from individuals under the age of 21. If hoy646 discovers that personal data has been collected from a person under 21, it will immediately delete that data, terminate the associated account, and forfeit any associated balances.

hoy646 implements age verification controls during registration and during KYC processing. If you are a parent or guardian and believe a minor has registered on hoy646 using false information, please contact us immediately using the details in Section 14. hoy646 takes underage gambling prevention extremely seriously and will act on any such report without delay.

12. International Data Transfers

hoy646's primary data processing operations are based in the Philippines. However, certain service providers — including cloud infrastructure providers, game software platforms, and KYC verification services — may process data in data centers located outside the Philippines.

Where personal data is transferred internationally, hoy646 ensures that adequate safeguards are in place in accordance with Section 21 of the Data Privacy Act and relevant NPC issuances. These safeguards may include: standard contractual clauses in data processing agreements; adequacy findings by the NPC or equivalent; or binding corporate rules applicable to the receiving entity.

hoy646 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without first implementing appropriate contractual and technical safeguards.

13. Amendments to This Policy

hoy646 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, Platform functionality, or data processing practices. Where amendments are material — affecting your rights as a data subject or the categories of data we collect — we will notify you via the email address registered in your hoy646 account at least seven (7) days before the changes take effect.

For non-material changes (such as clarifications of existing language or corrections of typographical errors), we may update the Policy without advance notice, but will update the "Last Updated" date at the top of this page. We encourage you to review this Policy periodically to stay informed about how hoy646 protects your personal data.

14. Contact and Data Protection Officer

hoy646 has designated a Data Protection Officer (DPO) in compliance with Section 21 of the Data Privacy Act of 2012. If you have questions about this Policy, wish to exercise your data subject rights, or have a concern about how your personal data is handled, please contact the hoy646 DPO using the details below.

If you are not satisfied with hoy646's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines through its official channels.