top646 Privacy Policy

1. Introduction

top646 ("top646," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses the top646 online casino platform at top646.asia (the "Platform"). This Privacy Policy ("Policy") describes how top646 collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC"). It applies to all personal data processed by top646 in relation to registered players, prospective players, and visitors to the Platform.

By registering an account on top646 or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please do not use the Platform.

2. Data Controller

top646 is the personal information controller ("PIC") responsible for the personal data collected through the Platform. top646 has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with the DPA and this Privacy Policy.

If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, you may contact our Data Protection Officer at:

Email: [email protected]

Please include "Data Privacy Request" in the subject line of your message, along with your registered account username and a clear description of your request.

3. Personal Data We Collect

top646 collects the following categories of personal data from players and Platform users:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (to verify you are 21 years of age or older);
• Philippine mobile number and email address;
• Residential address in the Philippines;
• Government-issued identification document details (e.g., PhilSys ID number, passport number, driver's license number, UMID, SSS ID, or voter's ID).

3.2 Financial Data

• GCash or PayMaya (Maya) mobile wallet number;
• Philippine bank account details (bank name, account number) for withdrawal processing;
• Debit card details where applicable;
• Transaction history, including deposit amounts, withdrawal amounts, and dates.

3.3 Gaming & Account Data

• top646 account username and encrypted password;
• Game history, wagering records, and session logs;
• Bonus and promotion usage history;
• Responsible gaming settings (deposit limits, session limits, self-exclusion status);
• Customer support communications and complaint records.

3.4 Technical & Usage Data

• IP address and approximate geographic location;
• Device type, operating system, and browser information;
• Pages visited, features used, and time spent on the Platform;
• Cookie identifiers and session tokens;
• Login timestamps and access logs.

4. How We Collect Your Data

top646 collects personal data through the following means:

4.1 Directly From You

We collect data you provide directly when you register a top646 account, complete KYC verification, make a deposit or withdrawal, contact our customer support team, participate in promotions, or update your account profile. You are responsible for ensuring that all information you provide to top646 is accurate, current, and complete.

4.2 Automatically During Platform Use

When you access and use the top646 Platform, we automatically collect certain technical and usage data through cookies, web beacons, server logs, and similar technologies. This data is collected to ensure the Platform functions correctly, to detect and prevent fraud, and to improve the overall player experience.

4.3 From Third Parties

top646 may receive personal data about you from third-party sources in limited circumstances, including:

• Payment service providers (e.g., GCash, Maya, Philippine banks) to verify and process financial transactions;
• Identity verification and KYC service providers engaged to assist with document verification;
• PAGCOR and other regulatory bodies, where required by law;
• Fraud prevention and anti-money laundering screening services.

5. How We Use Your Personal Data

top646 uses your personal data for the following purposes:

• Account Management: To register and maintain your top646 player account, verify your identity, and manage your account settings and preferences.
• KYC & Age Verification: To verify that you are at least 21 years of age and to comply with PAGCOR's Know Your Customer requirements before processing withdrawals.
• Transaction Processing: To process deposits and withdrawals via GCash, Maya, bank transfer, and other accepted Philippine payment methods, and to maintain accurate financial records.
• Platform Operation & Improvement: To deliver, maintain, and improve the top646 Platform, including games, features, and customer support services.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, cheating, and other prohibited conduct on the Platform.
• Regulatory Compliance: To comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable Philippine laws and regulations.
• Responsible Gaming: To monitor gaming behaviour, enforce responsible gaming limits and self-exclusion requests, and identify players who may be at risk of problem gambling.
• Communications: To send you account-related notifications, transaction confirmations, security alerts, and — where you have consented — promotional communications about top646 offers and new games.
• Customer Support: To respond to your enquiries, complaints, and support requests in a timely and effective manner.

6. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, top646 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and top646 — specifically, to operate your player account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations, the AMLA, and the DPA itself.
• Legitimate Interests: Processing is necessary for top646's legitimate interests in preventing fraud, ensuring platform security, and improving our services, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending promotional communications or using non-essential cookies — top646 relies on your freely given, specific, and informed consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

7. Sharing Your Personal Data

top646 does not sell, rent, or trade your personal data to third-party marketers. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

7.1 Service Providers

top646 engages trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, Maya, Philippine banks), KYC and identity verification providers, IT infrastructure and cloud hosting providers, and customer support platform providers. These service providers are contractually bound to process your data only on top646's instructions and in accordance with the DPA.

7.2 Regulatory & Law Enforcement Authorities

top646 may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other Philippine government authorities where required or permitted by law, including in response to lawful requests, court orders, or regulatory investigations.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of top646's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. top646 will notify affected players of any such transfer in advance where required by law.

7.4 With Your Consent

top646 may share your personal data with other third parties where you have given your explicit consent to such sharing.

8. Cookies & Tracking Technologies

top646 uses cookies and similar tracking technologies (such as web beacons and session tokens) on the Platform. Cookies are small text files stored on your device that help the Platform function correctly and allow us to recognise you between sessions.

8.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in to your top646 account. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and responsible gaming limits, to personalise your experience on top646.
• Analytics Cookies: Help us understand how players use the Platform — which games are most popular, where players encounter difficulties, and how we can improve the overall experience. Data collected is aggregated and anonymised where possible.
• Security Cookies: Used to detect and prevent fraudulent activity, including account takeover attempts and bot activity.

8.2 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the top646 Platform. Strictly necessary cookies cannot be disabled as they are required for the Platform to operate.

9. Data Retention

top646 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account Data: Retained for the duration of your active top646 account, and for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements.
• Financial & Transaction Records: Retained for a minimum of five (5) years following the date of the transaction, in compliance with the Anti-Money Laundering Act (AMLA) and AMLC regulations.
• KYC & Identity Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Retained for three (3) years following the resolution of the relevant support interaction.
• Technical & Usage Logs: Retained for up to twelve (12) months, unless a longer retention period is required for fraud investigation or regulatory compliance purposes.

When personal data is no longer required, top646 will securely delete or anonymise it in accordance with our internal data disposal procedures.

10. Data Security

top646 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the top646 Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments, vulnerability scanning, and penetration testing;
• Multi-factor authentication for administrative access to systems containing personal data;
• Staff training on data privacy and security obligations under the DPA.

While top646 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in serious harm to affected players, top646 will notify the National Privacy Commission and affected individuals in accordance with the DPA's breach notification requirements.

11. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by top646:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed — which is the purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data top646 holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data top646 holds about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to top646's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe top646 has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Request." top646 will respond to your request within the timeframes prescribed by the DPA.

12. Children's Privacy

The top646 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. top646 does not knowingly collect personal data from individuals under the age of 21. If top646 becomes aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered on the top646 Platform, please contact us immediately at [email protected] so that we can take appropriate action.

13. Changes to This Privacy Policy

top646 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. When a material change is made to this Policy, top646 will notify registered players by email or by posting a prominent notice on the Platform prior to the change taking effect.

The "Effective Date" at the top of this Policy indicates when the current version came into force. We encourage you to review this Policy periodically to stay informed about how top646 protects your personal data. Your continued use of the Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way top646 handles your personal data, please contact our Data Protection Officer:

Data Protection Officer — top646
Email: [email protected]

Please include "Data Privacy Request" in the subject line, along with your registered username and a clear description of your query. top646 aims to acknowledge all data privacy requests within three (3) business days and to resolve them within the timeframes required by the DPA.

If you are not satisfied with top646's response to your data privacy request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.