63free2 Privacy Policy

1 Introduction

This Privacy Policy ("Policy") is published by 63free2 ("we", "us", "the Company", "63free2") and applies to all personal data collected through the 63free2 online gaming platform accessible at 63free2.net, its sub-pages, mobile interface, and all associated services (collectively, the "Platform"). This Policy should be read alongside our Terms and Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

63free2 is committed to protecting the privacy and personal data of all users, with particular regard to the rights of Filipino players under the Philippines Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations. By registering an account or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein.

If you do not agree with any part of this Privacy Policy, you should discontinue use of the 63free2 Platform immediately and contact our support team to close your account.

2 Data Controller

For the purposes of the Philippines Data Privacy Act of 2012 and other applicable data protection legislation, 63free2 is the data controller responsible for the personal data collected and processed through the Platform. As data controller, 63free2 determines the purposes and means by which your personal data is processed.

63free2 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. The DPO can be contacted at:

Data Protection Officer — 63free2
Email: [email protected]
Subject line: "Data Protection / Privacy Request"

3 Personal Data We Collect

63free2 collects personal data from you in three primary ways: directly from you when you provide it, automatically when you use the Platform, and from third-party sources such as identity verification providers and payment processors. The categories of personal data we collect are detailed below.

3.1 Data You Provide Directly

• Registration Data: Full legal name, date of birth, nationality, gender, email address, mobile number, and residential address (including city — Manila, Cebu, Davao, Quezon City, Makati, or other Philippine cities).
• Identity Verification (KYC) Data: Government-issued ID (e.g., Philippine Passport, SSS/GSIS ID, Driver's License, PhilSys National ID), selfie photos for liveness verification, and proof of address documents.
• Payment Data: GCash account number, Maya account details, bank account details (BPI, BDO, Metrobank, UnionBank), or partial card numbers. Full card numbers are processed exclusively by our PCI-DSS-compliant payment processors and are never stored on 63free2 servers.
• Communications: Content of messages you send to 63free2 customer support, feedback submissions, and survey responses.
• Responsible Gaming Data: Self-exclusion requests, deposit limit settings, and cooling-off period preferences where these are voluntarily submitted by you.

3.2 Data Collected Automatically

• Technical Data: IP address, device type and model, operating system, browser type and version, screen resolution, and time zone.
• Usage Data: Pages visited, games played, wagers placed, session duration, in-platform navigation patterns, and feature interactions.
• Transaction Data: Deposit and withdrawal history, bonus claims, wagering activity, and account balance movements.
• Cookie and Tracking Data: Session cookies, persistent cookies, pixel tags, and similar identifiers as described in Section 7 of this Policy.

3.3 Data from Third-Party Sources

• Identity verification results from our KYC/AML compliance partners.
• Fraud screening scores and risk indicators from financial security providers.
• Payment confirmation data from GCash, Maya, BPI, BDO, Metrobank, and other payment processors.
• Publicly available information from Philippine government databases consulted for AML and sanctions screening purposes.

4 How We Use Your Personal Data

63free2 processes your personal data only for specified, legitimate purposes. The table below sets out the primary purposes for which we use your data and the corresponding legal basis for each processing activity.

5 Legal Basis for Processing

63free2 relies on the following legal bases under the Philippines Data Privacy Act of 2012 and applicable international data protection standards when processing your personal data:

• Consent (Section 12(a), RA 10173): Where you have given clear, informed, and freely given consent — primarily for marketing communications and optional cookies.
• Contractual Necessity (Section 12(b), RA 10173): Where processing is necessary for the performance of the contract between you and 63free2 — primarily account management, payment processing, and service delivery.
• Legal Obligation (Section 12(c), RA 10173): Where processing is required to comply with Philippine law — including AML/CTF obligations, PAGCOR licensing requirements, and court orders.
• Legitimate Interest (Section 12(f), RA 10173): Where processing is necessary for the legitimate interests of 63free2 or a third party, provided those interests are not overridden by your rights and freedoms — primarily fraud prevention, platform security, and service improvement analytics.
• Vital Interests: Where processing is necessary to protect your vital interests or those of another person — primarily responsible gaming interventions where problem gambling behaviour is identified.

6 Data Sharing & Disclosure

63free2 does not sell, rent, or trade your personal data to any third party for commercial gain. We share your personal data only in the circumstances and with the categories of recipients described below, and only to the extent necessary for the specified purpose.

6.1 Service Providers and Data Processors

63free2 engages trusted third-party service providers who process personal data on our behalf under strict data processing agreements. These include:

• Payment Processors: GCash (Globe Fintech Innovations), Maya (Voyager Innovations), BPI, BDO, Metrobank, and card processing networks — for deposit and withdrawal processing.
• Identity Verification Providers: Third-party KYC/AML compliance platforms that verify government-issued IDs and perform sanctions screening.
• Cloud Infrastructure Providers: Hosting and data storage providers operating within secure, access-controlled environments.
• Customer Support Platforms: Software providers that facilitate live chat, ticketing, and email support communications.
• Analytics Providers: Platforms that help us analyse Platform usage in aggregated, anonymised form to improve services.
• Fraud Prevention Providers: Security platforms that assess transaction risk and detect prohibited account activity.

6.2 Regulatory and Law Enforcement Authorities

63free2 may disclose your personal data to Philippine government agencies, regulatory bodies (including PAGCOR and the Anti-Money Laundering Council), and law enforcement authorities where required to do so by law, court order, or regulatory directive. Such disclosures are made only to the extent required and with appropriate safeguards where legally permissible.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets involving 63free2, your personal data may be transferred to the successor entity as part of that transaction. You will be notified of any such transfer and of any changes to this Privacy Policy that result from it, in accordance with RA 10173.

7 Cookies & Tracking Technologies

63free2 uses cookies and similar technologies (pixel tags, local storage, session tokens) to operate and improve the Platform, maintain your session state, and deliver relevant content. The following cookie categories are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without impairing your ability to use the Platform.
• Functional Cookies: Remember your language preferences, game display settings, and last-visited sections of the Platform. These enhance your experience but are not strictly necessary.
• Analytical Cookies: Collect anonymised data about how players interact with the Platform — such as most-visited pages, session duration, and error frequency — to help us improve performance and usability.
• Marketing Cookies: Track your engagement with 63free2 promotions and, where consent has been given, enable personalised bonus and game recommendations based on your activity on the Platform.

You may manage your cookie preferences at any time through your browser settings. Please note that disabling certain cookie categories may affect the functionality of the 63free2 Platform. Your cookie preferences will be respected on subsequent visits to the Platform, subject to the technical limitations of your browser.

8 Data Retention

63free2 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, 63free2 will securely delete or anonymise your personal data in accordance with our internal data disposal procedures and applicable Philippine law.

9 Data Security

63free2 takes the security of your personal data seriously and has implemented a comprehensive set of technical and organisational security measures designed to protect your data against unauthorised access, loss, alteration, disclosure, or destruction. Our security measures include:

• Encryption in Transit: All data transmitted between your device and the 63free2 Platform is encrypted using TLS 1.2 or higher, enforced across all Platform endpoints.
• Encryption at Rest: Sensitive personal data stored on 63free2 servers is encrypted using AES-256 encryption standards.
• Access Controls: Access to personal data within 63free2 is restricted on a need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and undergo regular data protection training.
• Infrastructure Security: 63free2 servers are hosted in secure data centres with physical access controls, network firewalls, intrusion detection systems, and DDoS mitigation protections.
• Regular Security Audits: 63free2 conducts periodic third-party penetration testing and vulnerability assessments of its Platform and infrastructure.
• Payment Security: Payment card processing is handled by PCI-DSS-certified processors. 63free2 does not store full card numbers, CVV codes, or PIN details on its own servers.
• Two-Factor Authentication (2FA): 63free2 supports and encourages two-factor authentication on all player accounts as an additional layer of account security.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 63free2 will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the requirements of RA 10173.

10 Your Privacy Rights

Under the Philippines Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by 63free2. To exercise any of these rights, please submit a written request to our Data Protection Officer at [email protected] with the subject line "Privacy Rights Request". We will respond to all verified requests within 30 calendar days.

• Right to Be Informed: You have the right to be informed that your personal data is being collected and processed, and to know the purposes, scope, and method of processing — which is the purpose of this Privacy Policy.
• Right to Access: You have the right to request a copy of the personal data we hold about you, including information on how it has been processed, the sources from which it was obtained, and the recipients to whom it has been disclosed.
• Right to Rectification: You have the right to request correction of any inaccurate, incomplete, or outdated personal data held about you. You can update most account details directly through your 63free2 account settings.
• Right to Erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent, or where you object to processing. This right is subject to 63free2's legal retention obligations under Philippine law.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another service provider where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You also have the right to object to processing based on legitimate interest, subject to overriding legal grounds.
• Right to Restrict Processing: You have the right to request that 63free2 restrict the processing of your personal data in certain circumstances — for example, while a rectification request is being resolved.
• 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.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 63free2 has violated your data privacy rights. The NPC can be contacted via its official website at privacy.gov.ph.

11 International Data Transfers

Some of 63free2's service providers and data processors may be located outside the Philippines. Where personal data is transferred to countries outside the Philippines, 63free2 takes appropriate steps to ensure that your data receives a comparable level of protection to that afforded under Philippine law, including by:

• Entering into data processing agreements that incorporate standard contractual clauses approved by the National Privacy Commission.
• Transferring data only to countries or organisations that provide an adequate level of data protection as determined by the NPC or relevant international standards.
• Implementing supplementary technical and organisational measures (such as encryption and pseudonymisation) where necessary to ensure the security of transferred data.

63free2 ensures that all international data transfers comply with the requirements of RA 10173 and its implementing rules and regulations. You may request details of the specific safeguards in place for any international transfer by contacting our Data Protection Officer.

12 Children & Minors

The 63free2 Platform is strictly intended for adults aged 21 years and above. This age restriction applies to all Filipino players in accordance with Philippine laws and PAGCOR regulations governing online gambling. 63free2 does not knowingly collect, process, or retain personal data from individuals under the age of 21.

63free2 implements age verification checks during the registration process to prevent minors from accessing the Platform. Where 63free2 becomes aware that personal data has been collected from a person under 21 years of age, the account will be suspended immediately, all data will be securely deleted, and any funds held in the account will be handled in accordance with our Terms and Conditions and applicable law.

13 Changes to This Privacy Policy

63free2 reserves the right to update or amend this Privacy Policy at any time in response to changes in applicable Philippine law, regulatory requirements, business practices, or Platform features. All changes will be reflected in an updated version of this Policy published on the Platform, with the "Last Updated" date revised accordingly.

Where changes to this Privacy Policy are material — meaning they significantly affect how we collect, use, or share your personal data — 63free2 will notify registered players via email or prominent in-Platform notification at least 14 days before the changes take effect. Your continued use of the Platform after the effective date of any amended Policy constitutes your acceptance of the changes.

We encourage you to review this Privacy Policy periodically to stay informed about how 63free2 protects your personal data. If you have any questions about changes to this Policy, please contact our Data Protection Officer.

14 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 63free2 handles your personal data, please contact our Data Protection Officer. We are committed to addressing all privacy-related inquiries promptly and transparently.

Data Protection Officer — 63free2
Email: [email protected]
Subject line: "Privacy Policy Inquiry" or "Data Rights Request"

When submitting a privacy rights request, please include your full name, registered email address, and a clear description of your request. 63free2 may need to verify your identity before processing your request to ensure that personal data is not disclosed to an unauthorised party.

If you are not satisfied with 63free2's response to your privacy inquiry or rights request, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012. For more information on the NPC and how to file a complaint, please visit the NPC's official government website.