hoy646 Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how hoy646 ("hoy646," "we," "our," or "us") collects, uses, stores, shares, and protects the personal data of individuals ("Data Subjects") who access or use the hoy646 online gaming platform at hoy646.org, including all associated services, features, and communications.

This Policy applies to all players, registered members, prospective members, and visitors who interact with hoy646 from anywhere within the Philippines — including Metro Manila, Cebu, Davao, Iloilo, Cagayan de Oro, Zamboanga, and all other regions and provinces — as well as any person whose personal data is processed by hoy646 in connection with the operation of the platform.

By registering on hoy646 or continuing to use the platform after this Policy has been made available to you, you acknowledge that you have read, understood, and consent to the collection and processing of your personal data as described herein.

2. Data Controller Information

hoy646 acts as the Personal Information Controller (PIC) with respect to the personal data collected through the hoy646 platform. As PIC, hoy646 determines the purposes and means of processing your personal data and is responsible for ensuring that processing is carried out in compliance with applicable Philippine data privacy laws.

hoy646 has appointed a Data Privacy Officer (DPO) who is responsible for overseeing data protection compliance, handling data subject rights requests, and serving as the primary point of contact for data privacy inquiries. Contact details for the DPO are provided in Section 15 of this Policy.

3. Personal Data We Collect

hoy646 collects the following categories of personal data in connection with the operation of the platform:

3.1 Registration and Identity Data:

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify 21+ age requirement);
• Registered Philippine mobile number (Globe, Smart, DITO, or other networks);
• Email address (if provided during registration);
• Username and encrypted password hash.

3.2 KYC and Verification Data:

• Government-issued ID number and issuing authority (e.g., PhilSys National ID, passport, driver's license, SSS/GSIS ID, voter's ID, PRC ID);
• Photographs of identification documents submitted for KYC verification;
• Selfie or liveness verification images where required;
• Proof of address documents where required for enhanced due diligence.

3.3 Financial and Transaction Data:

• GCash or Maya mobile wallet account number associated with your hoy646 account;
• BPI, BDO, or Metrobank account details used for deposits or withdrawals;
• Deposit and withdrawal transaction amounts, timestamps, and reference numbers;
• Wagering history including game type, bet amounts, and outcomes.

3.4 Technical and Device Data:

• IP address and approximate geographic location at the time of login;
• Device type, operating system, and browser version;
• Session duration, page views, and clickstream data;
• Cookie identifiers and similar tracking technology data.

4. How We Collect Personal Data

hoy646 collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make deposits or withdrawal requests, contact customer support, or respond to surveys or promotions;
• Automatically — through cookies, server logs, and analytics tools that record your interactions with the hoy646 website and platform features;
• From third-party payment providers — GCash, Maya, BPI, BDO, and Metrobank may share transaction confirmation data with hoy646 as part of the deposit and withdrawal processing workflow;
• From identity verification services — hoy646 may use third-party KYC and identity verification providers to cross-reference the documents you submit during the verification process.

5. Purposes for Processing Personal Data

hoy646 processes your personal data for the following specific purposes:

• Creating and managing your hoy646 player account;
• Verifying your identity and age (21+ requirement) in compliance with Philippine gaming regulations;
• Processing deposits and withdrawals through GCash, Maya, and bank transfer channels;
• Detecting, preventing, and investigating fraudulent activity, money laundering, and unauthorized account access;
• Delivering customer support services through live chat and email channels;
• Sending transactional communications (deposit confirmations, withdrawal notifications, OTP codes);
• Sending promotional communications and bonus offers to opted-in players;
• Improving the hoy646 platform through usage analytics and performance monitoring;
• Complying with PAGCOR regulatory reporting requirements and other applicable Philippine legal obligations;
• Enforcing hoy646's Terms and Conditions and responsible gaming commitments.

6. Legal Bases for Processing

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

• Contractual Necessity — processing required to fulfill our obligations under the hoy646 Terms and Conditions, including account management, payment processing, and game service delivery;
• Legal Obligation — processing required to comply with applicable Philippine laws, including anti-money laundering regulations (AMLA), PAGCOR regulatory requirements, and NPC data privacy obligations;
• Legitimate Interests — processing for fraud detection, platform security, and service improvement, where such interests do not override your data subject rights;
• Consent — processing for marketing communications and non-essential cookies, where you have provided explicit opt-in consent.

7. Sharing of Personal Data

hoy646 does not sell your personal data to any third party. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purposes:

• Payment Processors — GCash, Maya, BPI, BDO, Metrobank, and USDT processing partners, for the sole purpose of executing your deposit and withdrawal instructions;
• KYC and Identity Verification Providers — licensed third-party services engaged to verify identity documents and screen against applicable sanctions and anti-money laundering databases;
• Game Content Providers — licensed game studios (e.g., JILI, PG Soft, Pragmatic Play) may receive anonymized session data for game performance and fairness monitoring purposes only;
• Regulatory Authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government bodies, in response to lawful requests or mandatory reporting obligations;
• Legal and Professional Advisers — lawyers, auditors, and compliance consultants engaged by hoy646, bound by professional confidentiality obligations.

All third-party recipients are contractually required to process your personal data only for the specific purpose for which it was shared, and to maintain security standards consistent with those of hoy646.

8. International Data Transfers

Some of hoy646's service providers and game content partners are located outside the Philippines. Where personal data is transferred internationally, hoy646 ensures that adequate safeguards are in place, including contractual data processing agreements that impose data protection obligations equivalent to those required by the Data Privacy Act of 2012.

hoy646 will not transfer your personal data to any country that does not provide an adequate level of data protection without first obtaining your explicit consent or implementing appropriate contractual safeguards.

9. Data Retention

hoy646 retains personal data for the following periods:

• Active account data — retained for the duration of your active membership on hoy646;
• Transaction and wagering records — retained for a minimum of five (5) years from the date of the transaction, in compliance with PAGCOR regulatory requirements and the Anti-Money Laundering Act;
• KYC and identity documents — retained for a minimum of five (5) years following account closure or the last transaction, whichever is later;
• Support and communication records — retained for three (3) years from the date of the last communication;
• Technical logs and session data — retained for twelve (12) months and then anonymized or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with hoy646's data disposal procedures.

10. Cookies and Tracking Technologies

hoy646 uses cookies and similar tracking technologies on its platform for the following purposes:

• Essential Cookies — required for the platform to function, including maintaining your login session, remembering language preferences, and enabling secure transactions. These cannot be disabled without affecting platform functionality.
• Analytics Cookies — used to understand how players interact with hoy646, which features are most used, and where technical errors occur. Data collected is aggregated and does not identify individual players.
• Preference Cookies — store your preferences such as remembered game settings and display options to improve your experience on return visits.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent access to hoy646 but may affect certain personalization features. By continuing to use hoy646, you consent to the use of essential cookies as described above.

11. Security Measures

hoy646 implements the following technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS encryption for all data transmissions between your device and hoy646 servers;
• Encrypted storage of passwords using industry-standard hashing algorithms (passwords are never stored in recoverable plain text);
• Two-factor authentication (2FA) via OTP for account login and withdrawal authorization;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing of the hoy646 platform infrastructure;
• Incident response procedures for detecting, reporting, and containing data breaches in compliance with NPC notification requirements.

While hoy646 implements robust security measures, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your own login credentials.

12. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by hoy646:

To exercise any of these rights, please contact hoy646's Data Privacy Officer using the contact details in Section 15. We will respond to all data subject rights requests within fifteen (15) calendar days of receipt, or within thirty (30) days for complex requests, in accordance with NPC guidelines.

13. Children and Minors

hoy646 does not knowingly collect personal data from any person under the age of twenty-one (21) years. The hoy646 platform is strictly restricted to adult players aged 21 and above in accordance with Philippine gaming regulations.

If hoy646 discovers or is notified that personal data has been collected from a person under 21 years of age, that account will be immediately suspended, all associated data will be deleted, and any deposited funds will be returned to the originating payment method after verification. Any winnings accumulated by an underage player are not payable and will be forfeited.

If you are a parent or guardian and believe that a minor under your care has registered on hoy646, please contact our support team immediately via live chat or email so that we may take appropriate action.

14. Changes to This Policy

hoy646 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable Philippine law, NPC guidelines, PAGCOR regulatory requirements, or our own data processing practices. Material changes will be communicated to registered players via in-platform notification or email to the address on file at least seven (7) days before the amended Policy takes effect.

The date at the top of this Policy ("Last Updated") indicates when the most recent revision was made. We encourage you to review this Policy periodically. Your continued use of hoy646 following publication of an amended Policy constitutes your acceptance of the updated terms.

15. Contact and Data Privacy Officer

For any questions, concerns, or formal requests related to this Privacy Policy or the processing of your personal data by hoy646, please contact us through the following channels:

• Data Privacy Officer (DPO): hoy646 Data Privacy Office
• Email: [email protected] — subject line: "Data Privacy Request"
• Live Chat: Available 24/7 through the hoy646 platform — select "Data & Privacy" in the support category menu
• Response Time: We aim to acknowledge all data privacy requests within 24 hours and provide a substantive response within fifteen (15) calendar days

If you are not satisfied with our response to a data privacy request, you have the right to file a complaint with the National Privacy Commission of the Philippines. Information about the NPC complaints process is available through official Philippine government channels.