Privacy Policy — top646e

1. Introduction

top646e ("top646e," "we," "us," or "our") is committed to protecting the privacy and personal data of all users ("Player," "User," or "you") who access and use the top646e Platform at https://top646e.app. This Privacy Policy describes how we collect, use, store, disclose, and safeguard your personal information in connection with your use of our online casino services.

This Privacy Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC). By registering an account or using the top646e Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy should be read together with our Terms & Conditions, available at /terms-conditions.

2. Personal Data We Collect

top646e collects personal data that is necessary for the provision of our services, compliance with legal obligations, and the prevention of fraud and money laundering. The categories of personal data we collect include:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence).
• Contact Data: Email address, Philippine mobile number, and residential address (city/municipality, province, region).
• Account Data: Username, encrypted password, account preferences, and communication history with top646e support.
• Financial Data: GCash number, Maya/PayMaya account details, bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), transaction history, deposit and withdrawal records.
• Gaming Data: Game history, wagering activity, session duration, bonus usage, and responsible gaming tool settings.
• Technical Data: IP address, device type, browser type and version, operating system, and access timestamps.
• Usage Data: Pages visited, features used, click-through data, and navigation patterns within the Platform.

We collect this data directly from you during registration and account use, automatically through cookies and similar technologies, and from third-party identity verification and payment service providers where applicable.

3. How We Use Your Personal Data

top646e processes your personal data for the following purposes:

• Account Management: To create, maintain, and manage your top646e account, including verifying your identity and age (21+ requirement) in accordance with PAGCOR regulations.
• Service Delivery: To provide access to casino games, process deposits and withdrawals, and deliver customer support.
• Legal Compliance: To comply with anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, PAGCOR reporting obligations, and other applicable Philippine laws and regulations.
• Fraud Prevention: To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct on the Platform.
• Responsible Gaming: To monitor gaming activity and enforce responsible gaming tools such as deposit limits, session reminders, and self-exclusion where requested or required.
• Communications: To send you transactional notifications, account alerts, and — where you have opted in — promotional communications about top646e offers and updates.
• Platform Improvement: To analyse usage patterns and improve the functionality, security, and user experience of the top646e Platform.

4. Legal Basis for Processing

top646e processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and top646e (i.e., the Terms & Conditions governing your use of the Platform).
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, PAGCOR licensing requirements, and NPC guidelines.
• Legitimate Interests: Processing is necessary for top646e's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities, such as sending promotional communications, we rely on your explicit consent, which you may withdraw at any time.

5. Data Sharing and Disclosure

top646e 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 only to the extent necessary:

• Payment Processors: GCash, Maya/PayMaya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your financial transactions.
• Identity Verification Providers: Third-party KYC and AML compliance service providers engaged to verify your identity and comply with regulatory requirements.
• Game Software Providers: Licensed game developers and live dealer studios whose games are available on the top646e Platform, to the extent necessary for game delivery and fairness auditing.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities where disclosure is required by law or regulation.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and technical infrastructure providers engaged to operate and secure the Platform.

All third-party service providers engaged by top646e are contractually required to process your personal data only for the specified purpose and in accordance with applicable data protection laws.

6. Data Retention

top646e retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with AML and PAGCOR record-keeping requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Gaming activity logs are retained for a minimum of three (3) years.
• Marketing consent records are retained for the duration of your consent and for a reasonable period thereafter as evidence of consent.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymised in accordance with our data disposal procedures.

7. Security Measures

top646e implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the top646e Platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Multi-factor authentication options for account access.
• Regular security audits, penetration testing, and vulnerability assessments.
• Strict access controls limiting employee access to personal data on a need-to-know basis.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

While top646e takes all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, top646e will notify you and the NPC in accordance with applicable legal requirements.

8. Cookies and Tracking Technologies

top646e uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and deliver relevant content. The types of cookies we use include:

• Essential Cookies: Necessary for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Analytics Cookies: Used to collect aggregated, anonymised data about how users interact with the Platform, helping us improve functionality and performance.
• Preference Cookies: Used to remember your settings and preferences, such as language and display options.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. top646e does not use cookies to serve third-party advertising.

9. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by top646e:

• Right to be Informed: The right to be informed about how your personal data is collected and processed.
• Right of Access: The right to request a copy of the personal data top646e holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to our legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact top646e's Data Protection Officer via the contact details provided in Section 13 of this Policy. We will respond to all verified requests within fifteen (15) business days.

10. Children's Privacy

top646e's Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine law and PAGCOR regulations. We do not knowingly collect personal data from individuals under the age of 21.

If top646e becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on top646e, please contact our support team immediately.

11. Third-Party Links

The top646e Platform may contain links to other websites or services operated by third parties. This Privacy Policy applies solely to the top646e Platform and does not cover the privacy practices of any third-party websites. top646e is not responsible for the content or privacy practices of any linked third-party sites. We encourage you to review the privacy policies of any third-party websites you visit.

12. Updates to This Privacy Policy

top646e reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Where changes are material, we will provide reasonable notice to registered players 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 Policy. Your continued use of the top646e Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must cease using the Platform and close your account.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact top646e's Data Protection Officer:

• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the Platform
• Response Time: Within 15 business days for data privacy requests; within 4 hours for general support enquiries

Our support team is available around the clock and is familiar with the needs of Filipino players across Manila, Cebu, Davao, Quezon City, Makati, and the rest of the Philippines.

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