hot646 Privacy Policy

This Privacy Policy is issued by the operator of the hot646.asia platform ("hot646," "we," "us," "our"), a PAGCOR-licensed online gaming operator serving Filipino players across the Philippines. hot646 acts as the Personal Information Controller in respect of all personal data collected through the Platform, as that term is defined under Republic Act No. 10173 (the Data Privacy Act of 2012) and its Implementing Rules and Regulations.

As a PAGCOR-licensed operator, hot646 is also subject to data handling obligations stipulated in PAGCOR's regulatory framework, including requirements related to Know Your Customer (KYC) verification, anti-money laundering (AML) record-keeping, and responsible gaming data management.

hot646 collects the minimum personal data necessary to operate the Platform lawfully, verify player identity, process payments, and comply with regulatory obligations. The categories of personal data we collect are set out below:

2.1 Registration and Account Data

• Full legal name;
• Date of birth (for age verification — players must be 21 years or older);
• Philippine mobile number;
• Username and encrypted password;
• Email address (where provided);
• Residential address (required for KYC).

2.2 Identity Verification (KYC) Data

• Copy of a valid Philippine government-issued ID (e.g., UMID, PhilSys ID, Driver's License, Passport);
• Selfie photograph for liveness verification;
• Source of funds documentation, where required by PAGCOR or AMLC regulations.

2.3 Financial and Transaction Data

• GCash account reference number (not your GCash PIN or password);
• Maya account reference number;
• Bank account details where bank transfer is used;
• Deposit and withdrawal transaction history;
• Balance records and ledger history.

2.4 Gaming and Activity Data

• Complete gaming session history, including game titles, stakes, outcomes, and timestamps;
• Bonus claims and wagering requirement completion records;
• Responsible gaming settings (deposit limits, self-exclusion status, session limits);
• Player support communications and chat logs.

2.5 Technical and Device Data

• IP address at time of login and account activity;
• Device type, operating system, and browser version;
• Geolocation data (country/region level, derived from IP address);
• Platform interaction logs and session duration 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 support, set responsible gaming preferences, or interact with any feature of the Platform;
• Automatically — through standard web server logs, cookies, and session tracking technology when you browse or interact with hot646.asia;
• From payment processors — when you conduct a transaction via GCash, Maya, or a Philippine bank, limited transaction reference data is shared with hot646 by the payment processor to confirm and reconcile the transaction;
• From identity verification services — during the KYC process, hot646 may use a third-party identity verification provider to authenticate the documents and selfie you submit. These providers process your data strictly on our instructions;
• From publicly available sources — in limited circumstances related to AML compliance, hot646 may cross-reference information against publicly available sanctions lists or politically exposed persons (PEP) databases.

hot646 uses personal data only for purposes that are compatible with the reason it was collected. The specific purposes for which we process your data are:

4.1 Platform Operations and Account Management

To register and maintain your Account; authenticate your identity at login (including two-factor authentication via your registered Philippine mobile number); process deposits and withdrawals; maintain accurate balance records; and deliver the gaming services you request.

4.2 Regulatory Compliance

To comply with PAGCOR licensing requirements; to perform KYC identity verification as mandated by Philippine gaming regulations; to monitor transactions for compliance with Republic Act No. 9160 (Anti-Money Laundering Act) as amended; and to respond to lawful requests from PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine government authorities.

4.3 Security and Fraud Prevention

To detect, investigate, and prevent fraudulent transactions, account takeover attempts, collusion, and other prohibited conduct as defined in our Terms and Conditions; to enforce our One Account Policy; and to protect the integrity of all games on the Platform.

4.4 Responsible Gaming

To administer the responsible gaming tools available in your Account settings, including deposit limits, loss limits, session time limits, and self-exclusion. Gaming session history is retained to support the effective operation of these tools and to enable hot646 to identify players who may exhibit patterns consistent with problem gambling behavior.

4.5 Customer Support

To respond to inquiries submitted via live chat or email; to maintain records of support interactions for quality assurance and dispute resolution; and to investigate and resolve complaints regarding account operations, payments, or game outcomes.

4.6 Service Improvement

To analyze aggregated, anonymized usage patterns for the purpose of improving Platform performance, game selection, user experience, and payment processing flows. hot646 does not use individually identifiable data for general analytics beyond what is necessary for the purposes listed above.

4.7 Promotional Communications

To send you promotional notifications about bonuses, new games, and offers that may be of interest to you, where you have not opted out of such communications. You may opt out of promotional communications at any time through your Account settings or by contacting our support team.

Under the Data Privacy Act of 2012 and its Implementing Rules, hot646 processes personal data on the following legal bases, depending on the specific processing activity:

• Consent — for promotional communications and non-mandatory data collection activities, where you have provided explicit consent at the time of collection;
• Performance of a Contract — for all processing activities necessary to create and maintain your Account, process payments, and deliver gaming services under our Terms and Conditions;
• Compliance with a Legal Obligation — for KYC verification, AML transaction monitoring, PAGCOR regulatory reporting, and responses to lawful government requests;
• Legitimate Interests — for security monitoring, fraud prevention, responsible gaming pattern monitoring, and service improvement activities, where those interests are not overridden by your privacy rights.

hot646 does not sell, rent, or trade your personal data. We share personal data only in the following limited circumstances:

• Payment Processors: GCash, Maya, BPI, BDO, UnionBank, Metrobank, Coins.ph, and other payment providers receive the minimum data necessary to process your transactions. Each provider operates under its own privacy policy and is independently responsible for data it receives in its capacity as a data processor.
• Identity Verification Providers: Third-party KYC service providers process identity documents and selfies on hot646's instructions for the sole purpose of account verification. They are contractually bound to process data only as directed and to maintain equivalent data protection standards.
• Game Providers: Licensed game providers whose titles appear on the Platform may receive session data necessary to deliver and audit game outcomes. This data is limited to game-specific technical identifiers and does not include your full personal profile.
• Regulatory and Government Authorities: hot646 will disclose personal data to PAGCOR, the AMLC, the NPC, Philippine law enforcement, or courts when required to do so by law, court order, or valid regulatory directive.
• Corporate Transactions: In the event of a merger, acquisition, or restructuring involving the hot646 operator, personal data may be transferred to the successor entity, subject to equivalent privacy protections.

In all cases where data is shared with third-party processors, hot646 maintains data processing agreements that require those parties to comply with applicable Philippine privacy law and to process data only as directed by hot646.

Some of hot646's third-party service providers — including game providers, cloud infrastructure providers, and certain KYC vendors — may process data in countries outside the Philippines. Where such cross-border transfers occur, hot646 ensures that appropriate safeguards are in place in accordance with Section 21 of the Data Privacy Act of 2012, including:

• Contractual clauses requiring the recipient to maintain equivalent data protection standards;
• Transfers only to jurisdictions with data protection laws recognized as providing adequate protection;
• Where neither of the above applies, obtaining your explicit consent prior to the transfer.

The primary data infrastructure supporting hot646 accounts is located within the Asia-Pacific region. Transfers outside this region are limited to specific service functions and are subject to the safeguards described above.

hot646 retains personal data only for as long as is necessary for the purpose for which it was collected, or as required by applicable law and regulation. The following retention periods apply:

After the applicable retention period expires, personal data is securely deleted or anonymized in a manner that prevents re-identification. Anonymized aggregated data may be retained indefinitely for statistical and analytical purposes.

hot646 implements a layered security architecture to protect personal data against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• Encryption in Transit: All data transmitted between your device and hot646's servers is encrypted using TLS (Transport Layer Security) protocols. The Platform enforces HTTPS across all pages and services.
• Encryption at Rest: Sensitive data, including identity documents and payment reference data, is stored in encrypted form using industry-standard encryption algorithms.
• Access Controls: Access to personal data within hot646's systems is restricted on a strict need-to-know basis. Staff access is governed by role-based access control and is subject to regular review and audit.
• Two-Factor Authentication: Players are strongly encouraged to enable SMS-based two-factor authentication on their Accounts. Internal system access by hot646 staff is protected by multi-factor authentication.
• Penetration Testing and Security Audits: hot646's security posture is subject to regular independent security assessments to identify and remediate vulnerabilities.
• Incident Response: hot646 maintains a documented data breach response procedure. In the event of a breach affecting your personal data, hot646 will notify the National Privacy Commission and affected Players in accordance with the timelines and requirements of the Data Privacy Act of 2012.

hot646 uses cookies and similar session technologies on the Platform for the following purposes:

• Strictly Necessary Cookies: Required for the Platform to function — including maintaining your session after login, remembering your game preferences within a session, and enabling secure payment flows. These cookies cannot be disabled without preventing normal use of the Platform.
• Functional Cookies: Remember your Platform preferences, such as language settings and responsible gaming tool configurations, across sessions.
• Analytics Cookies: Collect aggregated, anonymized data about how players navigate the Platform to help us improve the user experience. No individually identifiable data is included in analytics reporting.
• Security Cookies: Support fraud detection and session integrity functions by tracking login patterns and identifying anomalous access behavior.

hot646 does not use third-party advertising cookies or tracking pixels for behavioral advertising purposes. You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will affect your ability to use the Platform's core functions.

Under the Data Privacy Act of 2012, you have the following rights in relation to the personal data hot646 holds about you. To exercise any of these rights, contact our support team via live chat or at the email address provided in Section 14.

hot646 will respond to data rights requests within 30 calendar days of receipt. Where a request is complex or involves a large volume of data, hot646 may extend this period by a further 30 days with prior notice. hot646 reserves the right to verify your identity before processing any data rights request.

hot646 does not knowingly collect personal data from individuals under 21 years of age. The Platform is strictly intended for adults aged 21 and over, as required by PAGCOR regulations governing online gaming in the Philippines.

Age verification is performed during the KYC process using government-issued identification. Where hot646 becomes aware — through any means — that personal data has been collected from an individual who is under 21 years of age, that Account will be immediately closed, the personal data will be deleted (subject to any mandatory regulatory retention requirements relating to the reporting of underage account activity), and any funds deposited will be returned to the source payment method.

If you are a parent or guardian and believe your child under the age of 21 has created an Account on hot646, please contact our support team immediately via live chat so that we may take prompt remedial action.

hot646 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or Platform operations. When material changes are made to this Policy, hot646 will:

• Update the "Last Updated" date displayed at the top of this page;
• Post a prominent notice on the Platform for a reasonable period following the change;
• Where required by the Data Privacy Act, obtain fresh consent from registered Players for any new processing activities that require consent as a legal basis.

Your continued use of the Platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the changes. hot646 encourages you to review this Policy periodically to stay informed about how your personal data is being handled.

For all inquiries, requests, or complaints relating to this Privacy Policy or the handling of your personal data by hot646, please contact us through the following channels:

• Live Chat: Available 24/7 on the Platform. For data rights requests, please indicate in your opening message that you are submitting a data privacy inquiry so that it can be directed to the appropriate team.
• Email: [email protected] (plain text — not a clickable link). For formal data rights requests submitted by email, please include your registered username, the nature of your request, and a copy of a valid ID for identity verification purposes. Allow up to 30 calendar days for a response.

If you are not satisfied with our response to a data privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC). Information on the NPC's complaint process is available through official Philippine government channels.