1. Overview
This Privacy Policy describes how lode646 ("we", "us", "the Platform") collects, uses, stores, and protects the personal information of users ("you", "Player") who access and use the lode646 online gaming platform at lode646.app.
lode646 takes data privacy seriously. We are committed to being transparent about what information we hold about you and giving you meaningful control over how it is used. This policy has been written to comply with the Data Privacy Act of 2012 (RA 10173) and its implementing rules and regulations as administered by the National Privacy Commission (NPC) of the Philippines.
This policy applies to all personal data collected through the lode646 website, mobile platform, customer support channels, and any other interaction you have with lode646. It applies to both registered players and visitors who browse the platform without creating an account.
Please read this policy carefully alongside our Terms and Conditions and Responsible Gaming Policy, which together form the complete agreement governing your relationship with lode646.
lode646 keeps your personal data secure wherever you play in the Philippines.
Built Around Filipino Data Rights
The Data Privacy Act of 2012 gives every Filipino citizen clear rights over their personal information. At lode646, we don't just comply with these rights on paper — we've built our data handling processes around them from the ground up.
From the moment you register to the day you close your account, your data is handled with care. We collect only what we need, we use it only for legitimate purposes, and we never sell it to anyone — ever.
2. Data We Collect
lode646 collects personal information in order to operate the platform safely, comply with legal obligations, and provide you with the best possible gaming experience. Here is a breakdown of the categories of data we collect:
| Category | Examples | Required? |
|---|---|---|
| Identity Data | Full name, date of birth, nationality, government ID details | Yes – for KYC |
| Contact Data | Email address, mobile number, residential address | Yes – for account |
| Financial Data | GCash/Maya numbers, bank account details, transaction history | Yes – for payments |
| Account Data | Username, login history, betting activity, balance records | Yes – for platform |
| Technical Data | IP address, device type, browser, operating system, session duration | Automatic |
| Marketing Data | Promotion preferences, communication opt-in status | Optional |
| Support Data | Chat transcripts, email correspondence, complaint records | When applicable |
We do not collect sensitive personal information (as defined under RA 10173) such as health data, religious beliefs, or political affiliations, unless you voluntarily provide such information in the context of a responsible gaming assessment or support interaction.
3. How We Collect Your Data
lode646 collects your personal information through the following channels:
Direct Collection
When you register an account, complete your KYC verification, make a deposit, withdraw funds, contact customer support, or respond to a survey, you provide us with personal data directly. This is the most significant source of the information we hold about you.
Automated Collection
When you visit lode646.app, our servers automatically log certain technical information — your IP address, the pages you visit, how long you spend on each page, your device type, browser version, and connection method. This happens via cookies and similar tracking technologies (see Section 9 for full details on cookies).
Third-Party Sources
In some cases, lode646 may receive data about you from third parties, including:
- Payment processors (e.g., confirmation of GCash or bank account ownership)
- Identity verification services used for KYC compliance
- Analytics providers who help us understand how the platform is used
- Responsible gaming and self-exclusion registers, where applicable under Philippine regulations
4. Why We Use Your Data
lode646 uses your personal data only for specific, legitimate purposes. We do not collect data "just in case" — every piece of information we hold has a defined reason for being there. Here's how we use your data:
- Account creation and management: To set up and maintain your lode646 account, verify your identity, and keep your preferences up to date.
- Payment processing: To facilitate deposits and withdrawals through your chosen payment method, and to maintain an accurate record of your transaction history.
- Legal compliance: To meet our obligations under the Data Privacy Act, Anti-Money Laundering Act (RA 9160), and any other applicable Philippine laws and gaming regulations.
- Security and fraud prevention: To detect and prevent unauthorized access to your account, identify suspicious betting patterns, and protect the integrity of the platform.
- Customer support: To respond to your inquiries, resolve disputes, and maintain records of our interactions with you.
- Promotions and marketing: To send you information about lode646 offers and promotions that you have opted in to receive. You can opt out at any time through your account settings.
- Platform improvement: To analyze usage patterns and improve the speed, functionality, and content of lode646 for all players.
- Responsible gaming: To monitor account activity for signs of problem gambling and to apply any self-exclusion or deposit limits you have set.
lode646 supports GCash, Maya, and all major Philippine payment methods — all handled securely.
Payment Data Is Handled With Extra Care
When you deposit via GCash, Maya, or a bank transfer, your financial data is processed through secure, certified payment gateways. lode646 itself does not store full card numbers, GCash PINs, or banking passwords on its servers.
We retain only what's necessary for transaction record-keeping and compliance — your GCash mobile number, the deposit amount, the timestamp, and the transaction status. This data is encrypted at rest and in transit.
5. Legal Basis Under the Data Privacy Act of 2012
Under the Philippine Data Privacy Act of 2012 (RA 10173), lode646 processes your personal data on the following lawful bases:
- Consent: For marketing communications and optional data processing activities. You can withdraw consent at any time.
- Contractual necessity: Processing required to fulfil our obligations to you as a player under the lode646 Terms and Conditions — including account management, bet settlement, and payment processing.
- Legal obligation: Processing required to comply with Philippine laws, including anti-money laundering obligations, gaming regulations, and tax reporting requirements.
- Legitimate interests: Processing necessary for the security of the platform, prevention of fraud, and improvement of lode646 services, where such interests are not overridden by your rights.
lode646 has registered its data processing activities with the National Privacy Commission (NPC) as required by law. Our registered Data Protection Officer (DPO) can be contacted using the details in Section 14.
6. Who We Share Your Data With
lode646 does not sell your personal data to any third party. Ever. We share your data only with the following categories of partners, and only to the extent necessary:
Payment Processors
We share your payment information with licensed payment service providers (e.g., GCash, Maya, BancNet-connected banks) to process your deposits and withdrawals. These providers have their own privacy policies and are independently regulated in the Philippines.
Identity Verification Providers
For KYC compliance, we share your identity documents and personal details with certified identity verification service providers. This is a regulatory requirement and cannot be waived.
Live Casino Providers
Our live casino lobby is powered by third-party game providers. Minimal session data is shared with these providers to operate the games. No financial data beyond what is required to run the game session is shared.
Analytics Providers
We use anonymized and aggregated data with analytics tools to understand platform usage patterns. No personally identifiable information is shared in this context.
Regulatory and Law Enforcement Authorities
lode646 will disclose your personal data to Philippine government authorities, regulators, or law enforcement agencies when legally required to do so — for example, under the Anti-Money Laundering Act, by court order, or in response to a valid NPC data access request.
How lode646 Protects Your Privacy
Practical measures we take every day to keep your data safe.
End-to-End Encryption
All data transmitted between your device and lode646 servers is encrypted using industry-standard TLS protocols. Your information cannot be read in transit.
Secure Data Storage
Personal data is stored on secured servers with access controls, firewalls, and regular security audits. Only authorized personnel can access player data.
KYC & Verification
Identity verification protects both you and other players. It ensures no one else can use your name to open an account or access your funds.
No Data Selling
lode646 never sells, rents, or trades your personal information to any third party for their own marketing or commercial purposes. Full stop.
Two-Factor Authentication
lode646 supports OTP-based login verification to protect your account from unauthorized access, even if your password is compromised.
NPC-Registered DPO
Our Data Protection Officer is registered with the National Privacy Commission and is the point of contact for all data privacy concerns and requests.
7. Data Retention
lode646 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by law. Here's a general guide to how long we keep different types of data:
- Account and identity data: Retained for the duration of your account plus 5 years after closure, as required by anti-money laundering regulations.
- Transaction records: Retained for a minimum of 5 years after each transaction, in compliance with AMLA and BIR requirements.
- Support correspondence: Retained for 3 years after the case is closed.
- Marketing preferences: Retained until you withdraw consent or close your account.
- Technical/log data: Typically retained for 90 days before being automatically purged or anonymized.
When data is no longer required, lode646 securely deletes or anonymizes it so that it can no longer be linked back to you as an individual.
8. How We Protect Your Data
lode646 has implemented a layered data security approach that covers both technical and organizational measures. These include:
- TLS/HTTPS encryption for all data in transit between your device and our servers
- AES-256 encryption for sensitive data stored at rest, including financial records and identity documents
- Role-based access controls ensuring only authorized lode646 staff can access player data, and only for legitimate operational purposes
- Regular penetration testing and vulnerability assessments conducted by independent security firms
- Multi-factor authentication for all internal staff systems that handle player data
- Automated monitoring systems that flag unusual access patterns or potential data breaches in real time
- Staff training on data privacy obligations under RA 10173 and secure data handling practices
Data Breach Response
In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, lode646 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, as required by the DPA Implementing Rules. Affected players will be notified directly as soon as it is safe and practical to do so.
9. Cookies & Tracking Technologies
lode646 uses cookies and similar technologies to make the platform work correctly, remember your preferences, and understand how players use the site. Here's what we use:
Essential Cookies
These are necessary for the platform to function. They handle your login session, security tokens, and basic account state. You cannot opt out of essential cookies while using lode646.
Preference Cookies
These remember choices you've made — like your preferred language or the last game category you visited — so you don't have to reset them every time you log in.
Analytics Cookies
We use anonymized analytics tools to understand how players navigate the platform, which pages are most visited, and where technical issues tend to occur. This data helps us improve lode646 for everyone. You can opt out of analytics cookies by adjusting your browser settings.
Marketing Cookies
If you've opted in to receive lode646 promotions, certain cookies help us measure the effectiveness of our campaigns. These are only active if you have given consent and can be disabled at any time through your account settings.
Bacolod to BGC — lode646 protects your privacy across the whole Philippines.
Privacy on Mobile — The Way Most Filipinos Play
The majority of lode646 players access the platform on their smartphones — and that's by design. Our mobile platform has the same data protection standards as the desktop version, with no corners cut.
We don't request unnecessary device permissions. lode646 does not access your contacts, call logs, or photos. The only device permissions we may request are for notifications (so we can alert you about withdrawals and promotions, if you opt in) and camera access for the optional in-app document scan during KYC.
You can review and manage all app permissions at any time through your phone's settings menu.
10. Your Rights Under the Data Privacy Act
As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal information held by lode646:
Right to Be Informed
You have the right to know what personal data lode646 collects about you, why we collect it, and how it is used. This Privacy Policy is our primary way of fulfilling that right.
Right to Access
You can request a copy of the personal data lode646 holds about you. Submit your request to our Data Protection Officer and we will respond within 30 days.
Right to Correction
If any of the personal data we hold about you is inaccurate or incomplete, you have the right to have it corrected. You can update basic account information directly in your account settings.
Right to Erasure (Right to be Forgotten)
You may request deletion of your personal data. Note that we are legally required to retain certain records (e.g., transaction history) for compliance purposes even after an account is closed.
Right to Object
You can object to the processing of your data for marketing purposes at any time. Simply update your communication preferences in account settings or contact our DPO.
Right to Data Portability
You can request your personal data in a structured, commonly used format so you can transfer it to another service. Submit a portability request to our DPO.
Right to Lodge a Complaint
If you believe lode646 has mishandled your personal data, you can lodge a complaint with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.
To exercise any of the above rights, contact our Data Protection Officer using the details provided in Section 14. We may need to verify your identity before processing your request.
11. Minors
lode646 is strictly for adults aged 21 and above. We do not knowingly collect personal data from individuals under the age of 21. If you are under 21, please do not register on lode646 or provide any personal information to us.
If lode646 discovers that it has inadvertently collected personal data from a minor, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe your child has registered on lode646, please contact our support team immediately with the relevant account details so we can investigate and act promptly.
12. Third-Party Services
The lode646 platform may reference or integrate with third-party services such as payment gateways and game providers. These third parties operate under their own privacy policies, and lode646 is not responsible for how they handle your data beyond our contractual arrangements with them.
When you make a payment via GCash or Maya, for example, you are also subject to the privacy practices of those providers. We recommend reviewing their respective privacy policies if you have questions about how they handle your financial data.
lode646 does not embed third-party advertising networks or social media trackers on the platform without disclosure. Any third-party integrations we add in the future will be disclosed in this policy.
13. Policy Updates
lode646 may update this Privacy Policy from time to time to reflect changes in our data practices, new regulatory requirements, or platform improvements. When we make significant changes, we will:
- Update the "Last Updated" date at the top of this page
- Notify registered players via email or in-platform notification at least 7 days before changes take effect
- Highlight the key changes in the notification so you don't have to read the whole policy again to know what's new
Your continued use of lode646 after any changes to this policy are effective constitutes your acceptance of the updated terms. If you do not agree, please stop using the platform and contact our DPO to exercise your right to erasure.
We recommend bookmarking this page and checking it periodically, especially if you are concerned about how your data is being used.
14. Contact & Data Protection Officer
For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by lode646, please contact our Data Protection Officer (DPO):
lode646 Data Protection Officer
Email: privacy@lode646.app
General Support: support@lode646.app
Response Time: Within 5 business days for DPO requests; within 30 days for formal data access or erasure requests.
If you are not satisfied with our response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC). Information on filing a complaint with the NPC is available at the NPC's official website.