hoy646 Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how hoy646 ("we," "us," "our," or "the Platform"), operating hoy646.vip, collects, uses, discloses, stores, and protects the personal information of individuals ("you," "your," or "Data Subject") who visit, register on, or use the hoy646 online gaming platform.

hoy646 is committed to respecting your privacy and to processing your personal data lawfully, fairly, and transparently in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA") and its Implementing Rules and Regulations ("IRR"), as administered by the National Privacy Commission ("NPC") of the Philippines.

By registering an account on hoy646 or by continuing to use hoy646.vip, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not register or continue to use the Platform.

02 Who We Are — The Data Controller

hoy646 is the data controller responsible for the personal information collected through hoy646.vip. As data controller, hoy646 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the DPA and applicable data protection regulations.

For questions or requests related to the processing of your personal data, you may contact hoy646 using the contact details provided in Section 16 of this Policy. hoy646 has designated a Data Protection Officer ("DPO") as required under the DPA and NPC regulations.

03 Categories of Personal Data We Collect

hoy646 collects the following categories of personal data in connection with your use of the Platform:

3.1 Identity and Registration Data

• Full legal name (first name, middle name, last name)
• Date of birth and age verification documentation
• Government-issued identification number (e.g., PhilSys ID, Passport, Driver's Licence, UMID)
• Username selected at registration
• Profile photograph (where submitted for KYC purposes)

3.2 Contact Data

• Philippine mobile number (in +63 format)
• Email address (where provided)
• Residential address or mailing address (for KYC or high-value account verification)

3.3 Financial and Transaction Data

• GCash account number or Maya account identifier linked to your hoy646 wallet
• Bank account numbers and bank name (where bank transfer is used)
• Deposit history, withdrawal history, and net gaming revenue data
• Bonus activations and wagering progress records

3.4 Technical and Usage Data

• Internet Protocol (IP) address at time of login and transaction
• Device type, operating system, and browser type
• Session duration, page views, and clickstream data
• Game play data including wagers placed, games accessed, and outcomes
• Login timestamps and geographic location data derived from IP address

3.5 Communication Data

• Records of communications between you and the hoy646 support team, including live chat transcripts, email correspondence, and support ticket content
• Responses to surveys, feedback forms, or promotional campaigns where voluntarily provided

04 How We Collect Your Personal Data

hoy646 collects personal data through the following means:

05 Purposes of Processing Your Personal Data

hoy646 processes your personal data for the following purposes, each of which is necessary for the lawful operation of the Platform and the delivery of services to you as a player:

1. Account Registration and Management: Creating and maintaining your hoy646 player account, verifying your identity and eligibility, and administering your account settings and preferences.
2. Age and Identity Verification: Confirming that you are at least 21 years of age and that your identity matches the information provided during registration, in compliance with PAGCOR requirements and the DPA.
3. Payment Processing: Facilitating deposits to and withdrawals from your hoy646 wallet via GCash, Maya, and Philippine bank transfer channels.
4. Anti-Money Laundering Compliance: Conducting customer due diligence, monitoring transactions for suspicious activity, and meeting reporting obligations under Republic Act No. 9160 (Anti-Money Laundering Act) as amended.
5. Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, account compromise, abuse of bonuses, and other conduct prohibited under the hoy646 Terms and Conditions.
6. Regulatory Compliance: Meeting obligations to PAGCOR, the National Privacy Commission, and other relevant Philippine regulatory and law enforcement authorities.
7. Customer Support: Responding to your enquiries, complaints, and requests submitted through hoy646's support channels.
8. Platform Improvement: Analysing aggregated and anonymised usage data to improve the Platform's functionality, game offering, and user experience.
9. Responsible Gaming: Monitoring play patterns to identify potential problem gambling behaviors and, where appropriate, applying responsible gaming tools or restrictions as required by PAGCOR regulations.
10. Marketing Communications: Sending promotional offers, bonus notifications, and product updates to players who have provided separate, specific consent to receive such communications. This is an optional processing purpose — see Section 14.

06 Legal Bases for Processing

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

• Consent: Where you have provided your express, freely given, specific, informed, and unambiguous consent to the processing of your data for a specific purpose — particularly marketing communications.
• Performance of Contract: Where processing is necessary for the performance of the service agreement between you and hoy646, including account management, payment processing, and game delivery.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to hoy646, including obligations under the DPA, AMLA, and PAGCOR regulatory requirements.
• Legitimate Interests: Where processing is necessary for the purposes of legitimate interests pursued by hoy646, including fraud prevention, platform security, and responsible gaming monitoring, and where such interests are not overridden by your rights and freedoms.

07 Disclosure and Sharing of Personal Data

hoy646 does not sell, rent, or trade your personal data to any third party for commercial purposes. Your personal data may be shared only with the following categories of third parties, strictly for the purposes described:

7.1 Payment Service Providers

GCash (Mynt — Globe Fintech Innovations, Inc.), Maya (PayMaya Philippines, Inc.), and Philippine banking institutions — for the purpose of processing deposits and withdrawals to and from your hoy646 wallet. These providers are bound by their own data protection obligations and the terms of their regulatory licences.

7.2 Identity and KYC Verification Providers

Accredited identity verification and Know Your Customer service providers engaged by hoy646 to verify player identities, validate government-issued identification documents, and perform anti-money laundering screening as required by Philippine law.

7.3 Game Content Providers

Licensed game software providers (including but not limited to JILI Gaming, PG Soft, and Pragmatic Play) may receive anonymised or pseudonymised session identifiers necessary for game delivery and integrity verification. These providers do not receive directly identifiable personal information unless technically required and contractually restricted.

7.4 Regulatory and Law Enforcement Authorities

PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission, and other Philippine government agencies and law enforcement bodies — where hoy646 is required by applicable law, court order, or regulatory directive to disclose personal data.

7.5 Professional Advisers

Legal counsel, auditors, and compliance consultants engaged by hoy646 under obligations of professional confidentiality, where access to personal data is necessary for the provision of their professional services to hoy646.

08 Cookies and Tracking Technologies

hoy646 uses cookies and similar tracking technologies on hoy646.vip to deliver, maintain, and improve the Platform's functionality and your experience as a player. The following types of cookies are used:

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will prevent you from logging in to or using hoy646. Disabling analytics or functional cookies will not prevent Platform access but may affect the quality of your experience.

09 Data Retention

hoy646 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in compliance with PAGCOR recordkeeping requirements and AMLA obligations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required under the Anti-Money Laundering Act and PAGCOR regulations.
• KYC Verification Documents: Retained for the statutory period required under applicable Philippine law, currently a minimum of five (5) years from the date of last business relationship.
• Communication and Support Records: Retained for up to three (3) years from the date of the last interaction, unless a complaint or dispute remains unresolved, in which case records are retained until final resolution.
• Technical and Usage Logs: Retained for up to twelve (12) months from collection, subject to earlier deletion where the data is no longer required for fraud detection, security monitoring, or performance analysis.
• Marketing Consent Records: Retained for the duration of your consent to receive marketing communications plus a period sufficient to demonstrate compliance with consent requirements, typically three (3) years following withdrawal of consent.

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

10 Data Security Measures

hoy646 implements technical and organisational security measures appropriate to the risk associated with the processing of your personal data. These measures include, but are not limited to:

• Encryption in Transit: All data transmitted between your device and hoy646.vip is encrypted using 256-bit SSL/TLS technology. The padlock icon in your browser address bar confirms that your connection is secure.
• Encryption at Rest: Personal data and financial records stored in hoy646's database infrastructure are stored in encrypted form using current industry-standard encryption algorithms.
• Access Controls: Access to personal data within hoy646's systems is restricted on a role-based, need-to-know basis. All internal access events are logged for audit purposes.
• Two-Factor Authentication: Player accounts on hoy646 support SMS-based two-factor authentication, which adds a second verification layer to the login process and significantly reduces the risk of unauthorised account access.
• Fraud Detection Systems: Automated monitoring systems operate continuously across the Platform, detecting anomalous transaction patterns, login behaviors, and gameplay characteristics that may indicate fraud or account compromise.
• Penetration Testing and Security Audits: hoy646 conducts periodic security assessments of its platform infrastructure to identify and remediate vulnerabilities before they can be exploited.
• Employee Training: All hoy646 personnel who have access to personal data receive mandatory data protection and security training as a condition of their role.

11 Your Rights as a Data Subject

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

To exercise any of the above rights, submit a written request to hoy646's Data Protection Officer using the contact details in Section 16. Requests are acknowledged within five (5) business days and responded to within thirty (30) calendar days of receipt of a verified request. Where a request is complex or numerous, the response period may be extended by a further thirty (30) calendar days with written notice to you.

hoy646 may decline a data subject request where compliance would conflict with a legal obligation, the rights of other persons, or ongoing fraud or law enforcement investigations. In such cases, hoy646 will provide written reasons for the refusal where permitted by law.

12 Children's Privacy — 21+ Platform

hoy646 is strictly an adult gaming platform. The minimum age for registration and use of all hoy646 services is 21 years. hoy646 does not knowingly collect, use, or retain personal data from individuals who are under 21 years of age.

Age verification is a mandatory step in the hoy646 account registration process. Where hoy646 discovers or has reasonable grounds to believe that an account has been registered by a person under 21 years of age, the account will be immediately suspended, all balances will be frozen pending investigation, and the personal data associated with the account will be deleted or retained only to the extent required by law for the purposes of the investigation.

13 International Data Transfers

hoy646's primary data processing infrastructure is located in or directed at the Philippines. Where personal data is transferred to data processors or service providers located outside the Philippines — for example, internationally operated game content providers or cloud infrastructure providers — such transfers are conducted under appropriate safeguards including:

• Data processing agreements containing standard contractual clauses consistent with NPC requirements;
• Transfers only to countries, territories, or organisations offering an adequate level of data protection as recognised by the National Privacy Commission; or
• Other lawful transfer mechanisms permitted under the DPA and its IRR.

hoy646 does not transfer personal data to jurisdictions that do not provide adequate data protection without implementing appropriate contractual safeguards.

14 Marketing Communications

hoy646 may send you promotional offers, bonus notifications, game release announcements, and other marketing communications by SMS or push notification, but only where you have provided separate, specific, and freely given consent to receive such communications.

You may withdraw your consent to marketing communications at any time by:

• Updating your communication preferences in your hoy646 account settings;
• Following the unsubscribe instructions included in any marketing message; or
• Submitting a written opt-out request to hoy646's support team.

Withdrawal of consent to marketing communications does not affect hoy646's ability to send you transactional messages related to your account, such as deposit confirmations, withdrawal notifications, account security alerts, and KYC verification requests, which are sent on the basis of contract performance and legal obligation rather than consent.

15 Amendments to This Privacy Policy

hoy646 reserves the right to amend, update, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. When material changes are made, hoy646 will provide notice by posting the updated Policy on hoy646.vip with a revised effective date, and where practicable, by notifying you via your registered contact details.

Continued use of hoy646 following publication of an amended Privacy Policy constitutes your acceptance of the revised terms. If you do not accept any amendment, you must discontinue use of the Platform and may request account closure.

It is your responsibility to review this Policy periodically. The current version of the Policy is always accessible at hoy646.vip/privacy-policy.

16 Contact Us — Data Protection Officer

For questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by hoy646, please contact our Data Protection Officer:

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

This Privacy Policy was last reviewed and updated on 1 January 2026. hoy646 reserves all rights not expressly granted herein.