Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how hoy646 ("Company," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("you," "your," or "Player") of the hoy646 online gaming platform, accessible at hoy646.net (the "Platform").

hoy646 takes your privacy seriously. We only collect the personal data we genuinely need, we hold it only for as long as necessary, and we apply technical and organisational security measures appropriate to the sensitivity of the data we hold. By registering for a hoy646 account or otherwise using the Platform, you acknowledge that you have read and understood this Policy.

This Policy should be read in conjunction with the hoy646 Terms & Conditions. Where this Policy uses terms defined in the Terms & Conditions, those definitions apply here as well.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and PAGCOR regulatory requirements, hoy646 is the personal information controller responsible for the personal data collected via the Platform. Our designated Data Protection Officer ("DPO") can be contacted at the address provided in Section 14 of this Policy.

hoy646 maintains a Data Privacy Management Program ("DPMP") registered with the National Privacy Commission ("NPC") of the Philippines, as required by the DPA's implementing rules and regulations. We take our obligations as a data controller seriously and have implemented appropriate policies, procedures, and technical controls to uphold them.

3. Personal Data We Collect

3.1 Registration and Identity Data

When you create a hoy646 account, we collect your full legal name, date of birth, Philippine mobile number, email address, username, password (stored in hashed, non-reversible format), and nationality. This data is mandatory for account creation.

3.2 KYC / Identity Verification Data

As required by PAGCOR regulations and the Philippine Anti-Money Laundering Act (AMLA), we collect and retain copies of government-issued identification documents you submit for KYC verification, including but not limited to: UMID, Driver's License, Passport, PhilSys ID, or Postal ID. We may also collect proof of address and, for high-volume accounts, source of funds documentation.

3.3 Financial Transaction Data

We collect records of all deposits, withdrawals, bonus credits, and wagering transactions conducted on your hoy646 account, including the payment method used (e-wallet reference numbers, bank account details, or card details as applicable), transaction amounts in Philippine Peso (₱), timestamps, and transaction status.

3.4 Gaming Activity Data

We record your full gaming history on hoy646, including games played, bets placed, outcomes, win/loss records, session durations, and responsible gaming tool usage (deposit limits set, self-exclusion requests, etc.).

3.5 Technical and Device Data

We automatically collect certain technical data when you access hoy646, including your IP address, device type, operating system, browser type and version, screen resolution, and general geographic location derived from IP. This data is used for security, fraud prevention, and platform optimisation.

3.6 Communications Data

We retain records of communications between you and hoy646 customer support, including live chat transcripts, email correspondence, and any documentation submitted in connection with a dispute or complaint.

The categories of data we collect, their purposes, and legal bases are summarised below:

4. How We Use Your Personal Data

hoy646 uses the personal data we collect for the following purposes:

• To create, manage, and secure your hoy646 account;
• To process deposits, withdrawals, and all wagering transactions;
• To verify your identity and age as required by PAGCOR regulations and Philippine law (KYC/AML);
• To detect, investigate, and prevent fraud, money laundering, and other illegal activity;
• To provide customer support and resolve disputes;
• To enforce our Terms & Conditions and other platform policies;
• To comply with PAGCOR reporting obligations and Philippine regulatory requirements;
• To operate responsible gaming tools and monitor for signs of problem gambling;
• To send you service-related communications (account notifications, security alerts, policy updates);
• To send you promotional and marketing communications, where you have provided opt-in consent;
• To analyse and improve the hoy646 platform and user experience.

hoy646 does not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have given explicit consent.

5. Legal Basis for Processing

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

1. Contract performance: Processing necessary to provide the gaming services you have contracted for via account registration and use of the Platform;
2. Legal obligation: Processing required to comply with PAGCOR regulations, AMLA, tax laws, and other applicable Philippine legal requirements;
3. Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights;
4. Consent: Processing for marketing communications and optional features, where you have given clear, informed, freely given, and specific consent. You may withdraw consent at any time without affecting prior processing.

6. Data Sharing and Disclosure

hoy646 may share your personal data with the following categories of recipients only to the extent necessary:

• PAGCOR and Philippine regulatory authorities: As required by our operating licence and applicable law, including mandatory reporting of suspicious transactions under AMLA;
• Payment processors and e-wallet providers: GCash, PayMaya, and banking partners (BPI, BDO, Metrobank) to process deposits and withdrawals. These providers are independent data controllers subject to their own privacy policies;
• Game software and platform providers: Third-party suppliers whose game engines, live dealer studios, or sports data feeds power hoy646's game offerings, under data processing agreements that restrict use to service provision only;
• Identity verification and KYC service providers: Third-party KYC/AML screening services used to fulfil our regulatory verification obligations;
• Professional advisors: Legal, accounting, or auditing firms engaged to provide professional services to hoy646, subject to professional confidentiality obligations;
• Law enforcement and courts: Where required by a valid court order, subpoena, or legal process under Philippine law.

All third-party data processors engaged by hoy646 are required to implement appropriate data protection measures and are prohibited from using hoy646 player data for any purpose other than the specific service they provide.

7. Cookies and Tracking Technologies

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

• Essential cookies: Required for the Platform to function, including session management and authentication. These cannot be disabled without affecting platform functionality;
• Analytics cookies: Used to understand how players use the Platform and to improve user experience. Data collected is aggregated and anonymised;
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and suspicious login patterns;
• Preference cookies: Used to remember your language and display preferences on hoy646.

Non-essential cookies are set only with your consent, which you may provide or withdraw via the cookie preference controls available on the Platform. Note that withdrawing consent for certain cookies may affect Platform functionality.

8. Data Retention

hoy646 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law and PAGCOR regulations:

• Account and KYC records: Retained for a minimum of five (5) years from account closure, as required by AMLA and PAGCOR recordkeeping obligations;
• Financial transaction records: Retained for a minimum of five (5) years, as required by AMLA;
• Gaming activity records: Retained for a minimum of three (3) years for dispute resolution and regulatory audit purposes;
• Support communications: Retained for two (2) years unless part of an ongoing dispute;
• Marketing consent records: Retained until consent is withdrawn and for a reasonable period thereafter as evidence of consent.

When personal data is no longer required, hoy646 will securely delete or anonymise it in accordance with our data disposal procedures.

9. Data Security

hoy646 implements technical and organisational security measures proportionate to the risk of processing your personal data. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your browser and hoy646 servers;
• Passwords stored using industry-standard cryptographic hashing (not reversibly encrypted);
• Two-factor authentication (2FA) available and recommended for all accounts;
• Access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing of the Platform;
• Incident response procedures compliant with NPC breach notification requirements.

10. Your Rights Under the Data Privacy Act

Under RA 10173 (Data Privacy Act of 2012), you have the following rights in relation to your personal data held by hoy646:

1. Right to be informed: To know what personal data we hold about you, the purposes for which it is processed, and with whom it is shared;
2. Right of access: To request a copy of the personal data hoy646 holds about you;
3. Right to rectification: To request correction of inaccurate or incomplete personal data;
4. Right to erasure / blocking: To request deletion or blocking of personal data that is no longer necessary, unlawfully processed, or processed without valid consent — subject to our legal retention obligations;
5. Right to data portability: To receive your personal data in a structured, commonly used, electronic format;
6. Right to object: To object to processing based on legitimate interests, including direct marketing;
7. Right to damages: To claim compensation for damages sustained due to inaccurate, incomplete, or unlawfully obtained or used personal data.

To exercise any of these rights, please contact our Data Protection Officer at the details in Section 14. hoy646 will respond to all rights requests within fifteen (15) business days of receipt of a verifiable request, as required by the DPA's implementing rules. We may need to verify your identity before processing rights requests.

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

11. Children's Privacy

The hoy646 Platform is strictly for adults aged 21 and over. We do not knowingly collect personal data from persons under the age of 21. If hoy646 determines that an account has been created by or on behalf of a person under 21, we will immediately close the account, forfeit any balance as required by PAGCOR rules, and delete the associated personal data except where retention is required by law.

If you believe that a minor has registered on hoy646, please contact us immediately at the details in Section 14 so we can take swift action.

12. Cross-Border Data Transfers

hoy646's primary data processing infrastructure is hosted in data centres with physical presence in Asia. Some of hoy646's third-party service providers — including certain game software vendors and technology platform providers — may process your data in jurisdictions outside the Philippines. Where such cross-border transfers occur, hoy646 ensures that appropriate safeguards are in place, including contractual data processing agreements that require the recipient to apply data protection standards at least equivalent to those required under the Data Privacy Act of 2012. hoy646 does not transfer personal data to jurisdictions that do not provide adequate data protection without such safeguards in place.

13. Changes to This Privacy Policy

hoy646 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, we will notify you via the Platform or by email to your registered address at least seven (7) days before the changes take effect for existing users. The "Last Updated" date at the top of this Policy will always reflect the most recent revision. Your continued use of hoy646 following the effective date of an updated Policy constitutes acceptance of the revised terms.

14. Contact Us & Data Protection Officer

For any questions, concerns, or rights requests relating to this Privacy Policy or hoy646's handling of your personal data, please contact our Data Protection Officer:

You also have the right to contact the National Privacy Commission of the Philippines directly if you have an unresolved privacy concern. The NPC is the independent government body responsible for enforcing the Data Privacy Act of 2012.