top646a Privacy Policy

1. Introduction

top646a ("we," "us," "our") is committed to protecting the privacy and personal data of every Filipino player who uses our online gaming platform. This Privacy Policy has been prepared in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines.

This Policy describes the types of personal information we collect when you use the top646a Platform, the purposes for which we process that information, the parties with whom we may share it, the security measures we employ to protect it, and the rights available to you as a data subject under Philippine law.

Please read this Policy carefully. If you do not agree with any part of it, you should discontinue use of the top646a Platform. For questions or concerns, contact our Data Protection Officer (DPO) using the details in Section 15.

2. Data Controller

top646a is the personal information controller (PIC) for all personal data collected through the Platform, as defined under Section 3(h) of the Data Privacy Act of 2012. As PIC, top646a determines the purposes and means of processing your personal data and is responsible for ensuring that processing is carried out lawfully, fairly, and transparently.

3. Personal Data We Collect

3.1 Registration Data

When you create a top646a account, we collect the following information:

• Full legal name (as it appears on a government-issued ID)
• Date of birth (to verify the 21+ age requirement)
• Philippine mobile number
• Email address
• Username and encrypted password
• Residential address

3.2 Identity Verification (KYC) Data

To comply with PAGCOR regulations and the Anti-Money Laundering Act (AMLA), top646a is required to verify the identity of all players. KYC data may include:

• Government-issued photo ID (e.g., PhilSys ID, passport, driver's licence, SSS/GSIS card)
• Proof of address (e.g., utility bill, bank statement)
• Selfie or live photo for facial verification
• Source of funds declaration for high-value accounts

3.3 Financial Data

We collect transaction records including deposit amounts, withdrawal requests, GCash or PayMaya reference numbers, and bank account details used for fund transfers. We do not store full debit card numbers — card data is tokenised by our payment processor.

3.4 Platform Usage Data

We automatically collect technical and behavioural data when you use the top646a Platform, including:

• IP address and approximate geolocation
• Device type, operating system, and browser
• Pages visited, games played, session duration, and click patterns
• Login timestamps and session activity logs

3.5 Communications Data

If you contact top646a support via live chat or email, we retain records of those communications to resolve disputes, improve service quality, and comply with regulatory record-keeping requirements.

4. How We Use Your Personal Data

top646a processes your personal data for the following purposes:

Purpose	Data Used
Account creation and management	Registration data, KYC data
Age and identity verification (21+ compliance)	KYC data, date of birth
Processing deposits and withdrawals	Financial data, KYC data
Fraud prevention and security monitoring	Usage data, financial data, IP address
AMLA compliance and suspicious transaction reporting	Financial data, KYC data
Customer support and dispute resolution	Communications data, account data
Responsible gaming monitoring and intervention	Usage data, account data
Sending promotional offers (with consent)	Email address, mobile number
Platform analytics and improvement	Usage data (aggregated/anonymised)

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, top646a processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations under the top646a Terms & Conditions, including account management and payment processing.
• Legal obligation: Processing required to comply with Philippine law, including PAGCOR regulations, AMLA, and NPC directives.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights.
• Consent: Processing for marketing communications and optional analytics features, where you have given explicit, informed consent. You may withdraw consent at any time.

6. Data Sharing & Disclosure

top646a does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your data only in the following circumstances:

6.1 Service Providers

We engage trusted third-party service providers to assist in operating the top646a Platform, including payment processors (GCash, PayMaya, and Philippine banking partners), KYC and identity verification providers, cloud hosting and infrastructure providers, and customer support platform operators. All service providers are contractually bound to process your data only on our instructions and in compliance with the DPA.

6.2 Regulatory and Law Enforcement Authorities

top646a is required by Philippine law to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent authorities upon lawful request or as mandated by applicable regulations. We will notify you of such disclosures where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of top646a's business, your personal data may be transferred to the successor entity. We will notify affected players and ensure the successor entity is bound by equivalent data protection obligations.

7. Data Retention

top646a retains your personal data for as long as your account remains active and for a minimum of five (5) years after account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act. KYC documents are retained for a minimum of five years from the date of the last transaction, as required by AMLA.

Usage and analytics data that has been fully anonymised may be retained indefinitely for statistical purposes. Communications data is retained for three (3) years from the date of the interaction. When data is no longer required, it is securely deleted or anonymised in accordance with NPC guidelines.

8. Data Security

top646a implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and the top646a Platform is encrypted using TLS 1.2 or higher. Sensitive data at rest is encrypted using AES-256.
• Access controls: Access to personal data is restricted to authorised top646a personnel on a strict need-to-know basis, with role-based access controls and full audit logging.
• Two-factor authentication: top646a supports and encourages the use of two-factor authentication (2FA) for all player accounts.
• Penetration testing: The Platform undergoes regular third-party security assessments and penetration testing.
• Incident response: top646a maintains a documented data breach response plan. In the event of a breach affecting your personal data, we will notify you and the NPC within the timeframes required by the DPA.

While top646a takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your top646a login credentials and for notifying us immediately of any suspected unauthorised access to your account.

9. Cookies & Similar Technologies

top646a uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

Cookie Type	Purpose	Can Be Disabled?
Essential	Session management, login state, security tokens	No — required for Platform to function
Functional	Language preferences, game settings, UI customisation	Yes, via browser settings
Analytics	Aggregated usage statistics to improve Platform performance	Yes, via account settings
Responsible Gaming	Session time tracking, reality check reminders	No — required for player protection compliance

top646a does not use third-party advertising cookies or cross-site tracking technologies. You can manage cookie preferences through your browser settings; however, disabling essential cookies will prevent you from using the Platform.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by top646a:

• Right to be informed: You have the right to know what personal data top646a collects and how it is processed — which is the purpose of this Privacy Policy.
• Right of access: You may request a copy of the personal data top646a holds about you at any time.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data in your top646a account.
• Right to erasure: You may request deletion of your personal data, subject to our legal retention obligations under PAGCOR and AMLA regulations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time. Objections to other forms of processing will be assessed on a case-by-case basis.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: If you believe top646a has violated your data privacy rights, you may file a complaint with the National Privacy Commission at privacy.gov.ph.

To exercise any of these rights, contact our Data Protection Officer at the details provided in Section 15. We will respond to all valid requests within thirty (30) days, as required by the DPA.

11. Children's Privacy

The top646a Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect personal data from persons under 21. If we become aware that a minor has registered an account, we will immediately close the account, delete all associated personal data, and report the incident as required by applicable law.

If you believe a minor has accessed the top646a Platform, please contact our support team immediately so we can take appropriate action.

12. International Data Transfers

top646a primarily stores and processes personal data within the Philippines. Where data is transferred to service providers located outside the Philippines — for example, cloud infrastructure providers — top646a ensures that such transfers are subject to appropriate safeguards, including contractual data protection clauses that meet the standards required by the NPC and the Data Privacy Act.

top646a will not transfer your personal data to a country that does not provide an adequate level of data protection without first obtaining your explicit consent or implementing appropriate contractual safeguards.

13. Third-Party Links

The top646a Platform may contain links to third-party websites or services, such as payment provider portals. top646a is not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to data collected by the top646a Platform.

14. Changes to This Privacy Policy

top646a reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via email or a prominent notice on the Platform at least seven (7) days before taking effect.

The effective date at the top of this Policy indicates when it was last revised. Your continued use of the top646a Platform after the effective date of any revision constitutes your acceptance of the updated Policy. We encourage you to review this page periodically.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by top646a, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government portal.