et645 Privacy Policy – How We Handle Your Personal Data

This Privacy Policy ("Policy") applies to all personal data collected, processed, and stored by et645 in connection with the operation of the online gaming platform accessible at et645.cam and all related services, features, games, and communications provided thereunder.

This Policy governs your relationship with et645 as a registered player, a prospective player, or a visitor to the et645 platform, regardless of the device or connection type you use to access the platform. It applies to players located in the Republic of the Philippines, which is the primary market for et645 services, as well as to any other eligible jurisdiction where et645 is lawfully accessible.

This Policy should be read together with the et645 Terms & Conditions, which form the overarching agreement governing your use of the platform. By registering an account or using the et645 platform in any capacity, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

For the purposes of applicable data protection legislation, including the Republic Act No. 10173 (Data Privacy Act of 2012) of the Philippines and its implementing rules and regulations, et645 acts as the personal information controller in respect of all personal data collected and processed through the et645.cam platform.

As the personal information controller, et645 determines the purposes for which and the manner in which personal data is processed. et645 has designated a data protection contact to handle all data privacy inquiries, access requests, and complaints. Contact details for privacy-related matters are set out in Section 16 of this Policy.

et645 collects the following categories of personal data from players and platform users:

3.1 Identity and Registration Data

• Full legal name as appearing on a valid Philippine government-issued identification document;
• Date of birth (to verify compliance with the 21-year minimum age requirement);
• Gender (where voluntarily provided during registration);
• Nationality and country of residence;
• Government-issued ID number and ID document images submitted for KYC verification (e.g., UMID, Passport, PhilSys National ID, Driver's License, Voter's ID).

3.2 Contact and Communication Data

• Email address;
• Philippine mobile number;
• Residential address (for KYC and compliance purposes);
• Records of all communications between the player and et645 support team, including live chat transcripts and email correspondence.

3.3 Financial and Transaction Data

• GCash account number, PayMaya account number, or other payment account identifiers used for deposits and withdrawals;
• Bank account details (BPI, BDO, Metrobank, UnionBank) where applicable;
• Cryptocurrency wallet addresses where applicable;
• Complete deposit and withdrawal transaction history, including amounts, timestamps, and payment method used;
• Source of funds information where required for anti-money laundering compliance.

3.4 Gaming Activity Data

• Complete gaming history including all bets placed, game types, wager amounts, outcomes, and winnings across all et645 game sections (WL Live, Slots, Sports Betting, Bingo);
• Bonus and promotion usage history;
• Responsible gaming tool settings (deposit limits, self-exclusion status, session time preferences).

3.5 Technical and Device Data

• IP address at the time of each login and gaming session;
• Device type, operating system version, and browser type;
• Mobile network provider (Globe, Smart, DITO, TNT, or others);
• Session timestamps, login history, and general geographic location derived from IP address;
• Cookies and similar tracking technology data as described in Section 10 of this Policy.

et645 collects personal data through the following means:

• Direct submission: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotional activities;
• Automated collection: Technical and device data collected automatically when you access and interact with the et645 platform, including through cookies, server logs, and analytics tools;
• Third-party verification services: Identity and document verification data provided by third-party KYC service providers engaged by et645 to assist with identity authentication;
• Payment processors: Transaction confirmation and account holder verification data provided by payment processors including GCash, PayMaya, and Philippine banking institutions in the course of processing your deposits and withdrawals;
• Fraud prevention services: Risk indicators and flagging data provided by third-party fraud prevention and anti-money laundering compliance service providers.

et645 processes your personal data only for clearly defined purposes, each supported by a lawful basis under the Data Privacy Act of 2012 and its implementing rules. The primary purposes and their respective legal bases are as follows:

5.1 Account Registration and Service Delivery

Purpose: To create and administer your et645 account, provide access to all gaming services, process your bets and transactions, and deliver customer support. Legal Basis: Performance of a contract — your et645 account relationship.

5.2 Identity Verification (KYC)

Purpose: To verify your identity, confirm your age (21+), and satisfy anti-money laundering, counter-terrorist financing, and responsible gaming compliance obligations. Legal Basis: Legal obligation — Philippine AML regulations and PAGCOR-aligned gaming compliance requirements.

5.3 Payment Processing

Purpose: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, Bitcoin, and USDT, and to maintain accurate transaction records. Legal Basis: Performance of a contract.

5.4 Security and Fraud Prevention

Purpose: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other security threats to the et645 platform and its players. Legal Basis: Legitimate interest of et645 and legal obligation.

5.5 Responsible Gaming Compliance

Purpose: To administer responsible gaming tools including deposit limits, loss limits, session reminders, cooling-off periods, and self-exclusion; to monitor for indicators of problem gambling behavior and intervene appropriately. Legal Basis: Legal obligation and protection of vital interests.

5.6 Marketing and Promotions

Purpose: To send promotional emails, SMS notifications, and in-platform messages about et645 bonuses, new games, and platform features. Legal Basis: Your explicit consent provided during registration or subsequently via account preferences. You may withdraw this consent at any time.

5.7 Platform Analytics and Improvement

Purpose: To analyze aggregated and anonymized player behavior and platform usage patterns to improve the et645 user experience, optimize game offerings, and enhance platform performance. Legal Basis: Legitimate interest of et645 in improving its services.

et645 does not sell, rent, or trade your personal data to third parties for commercial purposes. Personal data may be shared with third parties only in the following circumstances:

6.1 Service Providers

et645 engages carefully selected third-party service providers who process personal data on our behalf for specific operational purposes, including KYC and identity verification providers, payment processing partners (GCash, PayMaya, banking institutions), customer support platform providers, and anti-fraud and AML compliance service providers. All such providers are contractually bound to process data only on et645's instructions and to maintain appropriate security standards.

6.2 Legal and Regulatory Disclosure

et645 may disclose personal data to government authorities, regulatory bodies, law enforcement agencies, or courts of the Republic of the Philippines where such disclosure is required by applicable Philippine law, by court order, by regulatory demand from PAGCOR or the National Privacy Commission, or as necessary to prevent, detect, or prosecute fraud, money laundering, or other criminal activity.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of the et645 business, personal data held by et645 may be transferred to the acquiring entity as part of the transaction, subject to the acquiring entity's agreement to honor the privacy commitments set out in this Policy.

Some of the service providers engaged by et645 to support its operations may be located outside the Republic of the Philippines. Where personal data is transferred to entities in other countries, et645 ensures that appropriate safeguards are in place to protect that data, including contractual clauses that require recipient organizations to maintain standards of data protection equivalent to those applicable under Philippine law.

et645 will not transfer personal data to countries or organizations that cannot provide adequate data protection guarantees without first obtaining the necessary approvals required under Philippine data protection regulations, or without implementing appropriate supplementary measures to safeguard the transferred data.

et645 retains personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable Philippine law, whichever is longer. The following retention periods generally apply:

• Account registration and KYC data: Retained for the duration of the active account relationship and for a minimum of five (5) years following account closure, in line with AML and gaming compliance record-keeping obligations;
• Financial and transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required for anti-money laundering compliance and tax record purposes;
• Gaming activity history: Retained for the duration of the active account and for three (3) years following account closure;
• Support communications: Retained for three (3) years from the date of each communication;
• Self-exclusion records: Retained for the full duration of the self-exclusion period plus a minimum of five (5) years thereafter, to prevent re-registration during exclusion;
• Marketing consent records: Retained until consent is withdrawn and for one (1) year following withdrawal of consent.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized in accordance with et645's data lifecycle management procedures.

et645 implements a comprehensive range of technical and organizational security measures to protect personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL (Secure Sockets Layer) encryption for all data transmitted between your device and the et645 platform;
• Encryption of sensitive personal and financial data at rest in et645's secure data storage environments;
• Strict access controls limiting data access to authorized et645 personnel on a need-to-know basis;
• Two-factor authentication requirements for internal administrative access to player data systems;
• Regular security assessments, penetration testing, and vulnerability monitoring of the et645 platform;
• Employee training on data protection obligations and secure data handling practices;
• Incident response procedures for detecting, containing, and reporting personal data breaches in accordance with NPC requirements.

The et645 platform uses cookies and similar technologies to deliver a functional and personalized player experience. The categories of cookies used by et645 are as follows:

10.1 Strictly Necessary Cookies

These cookies are essential for the et645 platform to function correctly. They enable core features such as login session management, account authentication, and security verification. These cookies cannot be disabled without severely impairing your ability to use the platform.

10.2 Functional Cookies

These cookies remember your preferences and settings, such as your preferred language, game lobby view preferences, and responsible gaming settings. They improve your experience by reducing the need to re-enter preferences on each visit.

10.3 Analytics Cookies

These cookies help et645 understand how players navigate and interact with the platform, which sections are most visited, where performance bottlenecks occur, and how the overall player experience can be improved. Analytics data is processed in aggregate and anonymized form. You may opt out of analytics cookies through your browser settings.

10.4 Cookie Management

Most web browsers allow you to control cookies through browser settings. You can choose to block or delete cookies at any time. Note that blocking all cookies may affect the functionality of the et645 platform, particularly features that depend on session and authentication cookies. Specific cookie management instructions vary by browser and are available in your browser's help documentation.

The et645 platform is strictly for adults aged 21 years and above. et645 does not knowingly collect personal data from individuals under the age of 21. The mandatory KYC identity verification process is specifically designed to confirm that every registered player meets this age requirement before any real-money gaming activity is permitted.

If et645 becomes aware that personal data has been inadvertently collected from an individual who is under 21 years of age, all such data will be deleted immediately and the associated account will be closed. Any funds deposited by an underage player will be returned to the originating payment account after deduction of any applicable processing costs, and the matter will be reported to the relevant Philippine authorities if required by law.

Parents and guardians who become aware that a minor has accessed or attempted to register an account on the et645 platform should contact et645's customer support immediately so that the account can be closed and all associated data removed without delay.

Under the Data Privacy Act of 2012 of the Philippines and its implementing rules, you have the following rights in relation to your personal data held by et645. These rights may be exercised by contacting et645's data protection contact as described in Section 16.

et645 may send you promotional emails, SMS messages to your registered Philippine mobile number, and in-platform notifications regarding bonuses, new game releases, tournaments, and special offers on the et645 platform. These communications will be sent only where you have provided your explicit consent to receive them during registration or through your account preferences.

You may withdraw your consent to receive marketing communications at any time by updating your notification preferences in your et645 account settings, or by contacting et645 customer support directly. Withdrawal of marketing consent will not affect the validity of processing carried out prior to withdrawal, and will not affect the delivery of service-related communications that are necessary for the operation of your account.

The et645 platform may contain references to third-party service providers such as game software suppliers and payment processors whose privacy practices are independent of et645. et645 is not responsible for the privacy practices of any third party whose products or services are accessible through or in connection with the et645 platform.

All game software provided by third-party game developers on the et645 platform is delivered under licensing arrangements that require game providers to maintain appropriate data security standards. However, player interaction data may be processed by game providers in the course of delivering games, and players should be aware that such processing is governed by the game provider's own applicable policies in addition to this et645 Privacy Policy.

et645 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable Philippine law, or changes in the operational structure of the et645 platform. When material changes are made, the "Last Reviewed" date at the top of this page will be updated and, where the changes are significant, et645 will provide notice to registered players via their registered email address or through a prominent in-platform notification at the time of next login.

Your continued use of the et645 platform following the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not agree with any changes, you must discontinue use of the platform and may request account closure in accordance with the et645 Terms & Conditions.

We encourage you to review this Privacy Policy periodically. Historical versions of this Policy are available upon request by contacting et645 customer support.

If you have any questions about this Privacy Policy, wish to exercise any of your privacy rights, or have a concern about how et645 handles your personal data, please contact the et645 data protection contact through the following channels:

• Live Chat: Available 24/7 via the chat function on et645.cam. Please indicate "Privacy Inquiry" or "Data Rights Request" in your opening message for prompt routing.
• Email: [email protected] — please include "DATA PRIVACY REQUEST" in your subject line.

et645 will acknowledge all privacy rights requests within five (5) business days and will endeavor to provide a substantive response or fulfill the request within fifteen (15) business days of acknowledgment. Where the request is complex or requires additional verification, et645 may extend this period by a further fifteen (15) business days, with notice provided to you of the extension and the reasons for it.

If you are not satisfied with et645's response to a privacy complaint or rights request, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC), the independent regulatory body responsible for enforcing the Data Privacy Act of 2012.