Privacy Policy

1. Introduction

646lodi ("we", "us", "our", "the Platform") is committed to protecting the privacy and personal data of all individuals who interact with our platform. We understand that entrusting us with your personal information is a significant act of confidence, and we take that responsibility seriously.

This Privacy Policy describes in detail how 646lodi collects, uses, stores, shares, and protects your personal data when you access or use the 646lodi website and gaming platform. It also explains the rights available to you as a data subject under Philippine law and how you can exercise those rights.

This policy should be read together with our Terms & Conditions, which govern your use of the 646lodi platform. In the event of any conflict between this Privacy Policy and the Terms & Conditions on matters of data privacy, this Privacy Policy shall prevail.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, 646lodi is the personal information controller responsible for the personal data collected through the 646lodi platform. This means that 646lodi determines the purposes and means of processing your personal data.

646lodi has appointed a Data Protection Officer (DPO) as required under the Data Privacy Act. The DPO is responsible for overseeing compliance with this policy and applicable data protection laws. You may contact the DPO directly for any privacy-related concerns.

3. Data We Collect

646lodi collects the following categories of personal data in connection with your use of the platform:

3.1 Identity & Contact Data

• Full legal name
• Date of birth (to verify the 21+ age requirement)
• Gender
• Nationality and country of residence
• Email address
• Mobile phone number
• Residential address (including city, province, and postal code)

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., Philippine passport, driver's license, PhilSys National ID, UMID, SSS/GSIS ID)
• Proof of address documents
• Selfie or facial image for identity verification purposes
• Proof of payment method ownership

3.3 Financial Data

• GCash or Maya account details (registered name and number)
• Bank account details for bank transfer transactions
• Debit card details (card number, expiry — stored in tokenized form only)
• Transaction history (deposits, withdrawals, wagers, winnings)

3.4 Gaming & Activity Data

• Game history and session logs
• Wagering patterns and betting history
• Bonus and promotion usage
• Responsible gaming tool usage (deposit limits, self-exclusion requests)
• Customer support interaction records

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps and duration
• Cookie identifiers and similar tracking data
• Platform access logs

4. How We Collect Data

646lodi collects your personal data through the following means:

4.1 Directly From You

• When you register an account on the 646lodi platform.
• When you complete the KYC identity verification process.
• When you make a deposit or request a withdrawal.
• When you contact our customer support team via live chat or email.
• When you participate in promotions, surveys, or feedback requests.
• When you update your account profile or communication preferences.

4.2 Automatically

• Through cookies and similar tracking technologies when you browse the platform.
• Through server logs that record your IP address, device information, and session activity.
• Through game engines that record your wagering activity and session data.
• Through fraud detection and security monitoring systems.

4.3 From Third Parties

• From identity verification service providers during the KYC process.
• From payment processors (GCash, Maya, banks) to confirm transaction details.
• From fraud prevention and anti-money laundering screening services.
• From PAGCOR or other regulatory bodies where required by law.

5. Purpose of Processing

646lodi processes your personal data for the following specific purposes:

1. Account Registration and Management: To create, maintain, and manage your 646lodi player account, including authentication and account security.
2. Identity Verification (KYC): To verify your identity and confirm that you meet the 21+ age requirement and other eligibility criteria as required by PAGCOR regulations and Philippine law.
3. Transaction Processing: To process deposits, withdrawals, and other financial transactions on the platform in Philippine Peso (PHP).
4. Regulatory Compliance: To comply with obligations under the Anti-Money Laundering Act (AMLA), PAGCOR licensing requirements, the Data Privacy Act, and other applicable Philippine laws and regulations.
5. Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, and other prohibited conduct on the platform.
6. Customer Support: To respond to your inquiries, complaints, and support requests in a timely and effective manner.
7. Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion.
8. Platform Improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the 646lodi platform.
9. Marketing Communications: To send you promotional offers, bonuses, and platform updates — but only where you have provided your explicit consent to receive such communications.
10. Legal Claims: To establish, exercise, or defend legal claims in connection with your use of the platform.

6. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 646lodi processes your personal data on the following legal bases:

6.1 Contractual Necessity

Processing is necessary for the performance of the contract between you and 646lodi — specifically, the Terms & Conditions you agreed to upon registration. This covers account management, transaction processing, and the delivery of gaming services.

6.2 Legal Obligation

Processing is required to comply with legal obligations applicable to 646lodi, including PAGCOR licensing requirements, the Anti-Money Laundering Act, and the Data Privacy Act itself. This includes KYC verification, transaction monitoring, and regulatory reporting.

6.3 Legitimate Interests

Processing is necessary for the legitimate interests of 646lodi, including fraud prevention, platform security, responsible gaming monitoring, and improving the quality of our services — provided that such interests are not overridden by your rights and freedoms.

6.4 Consent

For certain processing activities — particularly marketing communications and the use of non-essential cookies — 646lodi relies on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Data Sharing & Disclosure

646lodi 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, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

7.1 Service Providers

We engage trusted third-party service providers who process data on our behalf under written data processing agreements. These include:

• Identity verification and KYC service providers
• Payment processors (GCash, Maya, banking partners)
• Cloud hosting and infrastructure providers
• Customer support platform providers
• Fraud detection and cybersecurity service providers
• Game software providers and content licensors

7.2 Regulatory and Law Enforcement Authorities

646lodi may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or other government bodies where required or permitted by Philippine law, including in response to lawful requests, court orders, or regulatory directives.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 646lodi's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the privacy practices of the new entity prior to the transfer taking effect.

7.4 With Your Consent

646lodi may share your personal data with other third parties where you have provided your explicit consent to such sharing.

8. Cookies & Tracking Technologies

646lodi uses cookies and similar tracking technologies to enhance your experience on the platform, remember your preferences, and gather analytics data to improve our services.

8.1 Types of Cookies We Use

8.2 Managing Cookies

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 646lodi platform. Instructions for managing cookies are available in the help documentation of your browser (Chrome, Firefox, Safari, Edge, etc.).

9. Data Retention

646lodi retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations.

9.1 Retention Periods

• Active Account Data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in accordance with AMLA record-keeping requirements.
• KYC and Identity Documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later.
• Transaction Records: Retained for a minimum of five (5) years in compliance with AMLA and PAGCOR requirements.
• Customer Support Records: Retained for three (3) years from the date of the last interaction.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years to demonstrate compliance.
• Technical Logs: Retained for up to twelve (12) months for security and fraud detection purposes.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymized in accordance with 646lodi's data disposal procedures.

10. Data Security

646lodi implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS Encryption: All data transmitted between your device and the 646lodi platform is encrypted using 256-bit SSL/TLS technology.
• Data Encryption at Rest: Sensitive personal data stored on our servers is encrypted at rest using industry-standard encryption protocols.
• Access Controls: Access to personal data is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Regular Security Audits: 646lodi conducts regular security assessments, penetration testing, and vulnerability scans to identify and address potential security risks.
• Intrusion Detection: Our systems are monitored 24/7 for suspicious activity using automated intrusion detection and prevention systems.
• Payment Tokenization: Financial data such as debit card details are stored in tokenized form only — we do not store raw card numbers on our servers.

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 646lodi:

1. Right to Be Informed: You have the right to be informed about how your personal data is being collected and processed, which is the primary purpose of this Privacy Policy.
2. Right to Access: You have the right to request a copy of the personal data that 646lodi holds about you, along with information about how it is being processed.
3. Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You may update basic account information directly through your account settings.
4. Right to Erasure: You have 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 our legal retention obligations.
5. Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
6. Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
7. Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
8. Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that your data protection rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within fifteen (15) business days, as required by the Data Privacy Act.

12. Children's Privacy

The 646lodi platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. The 21+ age requirement is enforced through our KYC verification process, which requires documentary proof of age from all players.

If 646lodi becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and take appropriate action in accordance with our Terms & Conditions and applicable law.

If you are a parent or guardian and believe that your child has registered on the 646lodi platform, please contact us immediately at [email protected] so that we can take prompt action.

13. International Data Transfers

646lodi primarily processes and stores personal data within the Philippines. However, some of our third-party service providers — including cloud infrastructure providers and game software licensors — may process data in other countries.

Where personal data is transferred outside the Philippines, 646lodi ensures that appropriate safeguards are in place to protect your data in accordance with the Data Privacy Act. These safeguards may include:

• Standard contractual clauses approved by the National Privacy Commission.
• Transfers to countries recognized as providing an adequate level of data protection.
• Binding corporate rules where applicable.

You may request information about the specific safeguards in place for any international data transfer by contacting our Data Protection Officer.

14. Updates to This Privacy Policy

646lodi reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When material changes are made, we will notify registered players via email and/or a prominent notice on the platform prior to the changes taking effect.

The date of the most recent revision is always displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal data. Your continued use of the 646lodi platform following the effective date of any update constitutes your acknowledgment of the revised policy.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 646lodi, please contact our Data Protection Officer:

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: