tap646 Privacy Policy

1. Data Controller Information

tap646 ("tap646," "we," "us," or "our") is the data controller responsible for the personal data of players and visitors to tap646.app. tap646 operates as an online gaming and sports betting platform serving Filipino players across the Philippines, regulated under the Philippine Amusement and Gaming Corporation (PAGCOR) framework.

For all data privacy matters, tap646 can be contacted via the details provided in Section 14 of this Policy. tap646 has designated a Data Protection Officer (DPO) as required under the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

2. Personal Data We Collect

tap646 collects personal data in the following categories. The specific data points collected depend on the nature of your interaction with the Platform:

3. How We Collect Your Data

tap646 collects personal data through the following methods:

3.1 Directly From You

• When you register a tap646 account and complete the KYC verification process.
• When you make a deposit or request a withdrawal via GCash, PayMaya, BPI, BDO, Metrobank, or other supported payment methods.
• When you contact tap646 customer support via Live Chat, email, or any other supported channel.
• When you participate in promotions, surveys, or bonus offers.
• When you submit responsible gaming requests such as deposit limits or self-exclusion.

3.2 Automatically Through Technology

• Browser cookies, session tokens, and local storage used to maintain your login session and preferences on tap646.
• Server logs capturing IP address, access timestamps, device information, and browsing behavior on tap646.app.
• Game server records of all gameplay events, wager placements, and outcomes on the Platform.
• Fraud detection systems that monitor transaction and gameplay patterns for anomalous activity.

3.3 From Third Parties

• Identity verification service providers used to authenticate government-issued IDs and validate KYC documents.
• Payment service providers including GCash and PayMaya, which share transaction confirmation data with tap646.
• Fraud and AML screening services that provide risk intelligence relating to transactions and player profiles.
• Regulatory bodies including PAGCOR, where disclosure of player information is legally required.

4. How We Use Your Personal Data

tap646 processes your personal data for the following purposes:

• Account Management: Creating, maintaining, and securing your tap646 player account.
• Identity Verification: Complying with KYC (Know Your Customer) requirements under Philippine anti-money laundering and gaming regulations.
• Transaction Processing: Facilitating deposits, withdrawals, and the crediting of winnings to your tap646 account.
• Game Operation: Running games, recording outcomes, resolving disputes, and maintaining game integrity records.
• Customer Support: Responding to your queries, complaints, and support requests via Live Chat and email.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraud, money laundering, account takeovers, and other prohibited conduct.
• Responsible Gaming: Monitoring for indicators of problem gambling, administering deposit limits and self-exclusion requests, and fulfilling our duty of care obligations.
• Legal & Regulatory Compliance: Meeting our obligations under Philippine law, PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
• Marketing Communications: Sending promotional offers, bonus notifications, and gaming news — only where you have consented to receive such communications. You may withdraw consent at any time via your account preferences.
• Platform Improvement: Analyzing aggregated usage data to improve the tap646 user experience, game library, and technical performance.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, tap646 processes personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfill our contractual obligations to you as a tap646 player — including account management, transaction processing, and game operation.
• Legal Obligation: Processing required to comply with Philippine law, including KYC/AML requirements under the Anti-Money Laundering Act, PAGCOR reporting obligations, and the Data Privacy Act.
• Legitimate Interests: Processing for fraud prevention, platform security, and responsible gaming monitoring — where our legitimate interests do not override your rights and freedoms.
• Consent: Processing for marketing communications and optional analytics features, where you have provided explicit, informed consent that may be withdrawn at any time.

6. Data Sharing & Disclosure

tap646 does not sell your personal data. We share personal data only in the following limited circumstances:

• Service Providers: Third-party vendors who provide identity verification, payment processing, fraud detection, cloud infrastructure, customer support software, and other services essential to tap646's operation. All service providers are bound by data processing agreements requiring them to protect your data and use it only for the specified purpose.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies where disclosure is required by law or regulatory directive.
• Law Enforcement: Philippine law enforcement agencies where disclosure is required pursuant to a valid legal order, subpoena, or court directive.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of tap646's assets, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.
• Dispute Resolution: To the extent necessary to resolve a formal dispute between you and tap646, including arbitration or court proceedings.

7. Data Retention

tap646 retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC Data: Retained for a minimum of five (5) years following account closure, as required by Philippine anti-money laundering regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years per AMLA requirements.
• Gaming Records: Retained for a minimum of three (3) years for dispute resolution and regulatory audit purposes.
• Customer Support Communications: Retained for a minimum of two (2) years from the date of the interaction.
• Marketing Consent Records: Retained until consent is withdrawn, plus one (1) year as a compliance record.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized in accordance with tap646's data disposal procedures.

8. Cookies & Tracking Technologies

tap646 uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Essential Cookies: Required for Platform functionality, including login session maintenance and security tokens. These cannot be disabled without affecting Platform usability.
• Analytical Cookies: Used to understand how players navigate and interact with tap646, enabling us to improve the user experience. Data collected is aggregated and anonymized where possible.
• Fraud Prevention Cookies: Technical markers used by our security systems to detect unusual access patterns and protect accounts from unauthorized access.
• Preference Cookies: Used to remember your language and display preferences within tap646.

You may manage cookie preferences through your browser settings. Note that disabling essential cookies may prevent you from logging in to and using tap646.

9. Data Security

tap646 implements comprehensive technical and organizational security measures to protect your personal data, including:

• 256-bit SSL/TLS encryption for all data in transit between your device and tap646 servers.
• Encryption of sensitive data at rest, including payment information and KYC documents.
• Role-based access controls limiting personal data access to authorized tap646 personnel with a demonstrated business need.
• Multi-factor authentication requirements for tap646 staff accessing systems containing personal data.
• Regular third-party security audits and penetration testing of the Platform.
• A formal data breach incident response procedure, including notification to affected players and the National Privacy Commission within the timeframes mandated by Philippine law.

Despite these measures, no internet transmission or digital storage system is completely secure. tap646 cannot guarantee absolute security of your data, but we commit to notifying you promptly if we become aware of a breach affecting your personal information.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by tap646:

• Right to be Informed: You have the right to be notified of how tap646 processes your personal data — satisfied by this Privacy Policy.
• Right to Access: You may request a copy of the personal data tap646 holds about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data in your tap646 account.
• Right to Erasure: You may request deletion of your personal data, subject to tap646's legal retention obligations under AMLA and PAGCOR regulations.
• Right to Object: You may object to processing based on legitimate interests, including direct marketing communications.
• Right to Data Portability: You may request a copy of your data in a structured, commonly used electronic format.
• Right to Lodge a Complaint: If you believe tap646 has violated your data privacy rights, you may file a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, contact tap646's Data Protection Officer using the contact details in Section 14. tap646 will respond to verified data subject requests within thirty (30) days.

11. Minors

tap646 is strictly prohibited for use by persons under the age of 21 years. tap646 does not knowingly collect personal data from individuals under 21. If tap646 becomes aware that personal data has been collected from a person under 21, such data will be deleted and the associated account will be permanently closed.

If you believe a person under 21 has registered a tap646 account, please contact our support team immediately at the contact details in Section 14.

12. Cross-Border Data Transfers

In operating the tap646 Platform, some personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or game software vendors. Where such transfers occur, tap646 ensures that:

• The recipient country provides an adequate level of data protection, or
• Appropriate contractual safeguards (such as standard contractual clauses) are in place to protect your personal data in accordance with the Data Privacy Act of 2012.

tap646 will not transfer your personal data outside the Philippines to any jurisdiction lacking adequate protection without your consent or a valid legal basis.

13. Updates to This Privacy Policy

tap646 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Material changes to this Privacy Policy will be communicated to registered players via email notification and/or a prominent notice on tap646.app prior to the change taking effect. Your continued use of tap646 following notification of a material change constitutes acceptance of the revised Privacy Policy.

We recommend reviewing this Privacy Policy periodically to stay informed of how tap646 protects your personal data.

14. Contact & Data Protection Officer

For all data privacy inquiries, requests to exercise your data subject rights, or to contact tap646's Data Protection Officer, please use the following contact details:

If you are not satisfied with tap646's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.