Privacy Policy — How 639ph Protects Your Data

1. Introduction and Scope

639ph (the "Platform," "we," "us," or "our") is committed to protecting the privacy and personal data of all users who register accounts, access gaming services, or otherwise interact with our online gaming platform. This Privacy Policy applies to all personal information collected through the 639ph website, mobile applications, customer support channels, and any other services we provide.

By using the 639ph Platform, you consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with our data practices, please do not use the Platform or provide us with any personal information.

2. Data Controller and Contact Information

The data controller responsible for your personal information is 639ph. For questions, requests, or concerns regarding this Privacy Policy or our data processing practices, you may contact our Data Privacy Officer through the following channels:

• Email: Our support email address, available in the footer of every page
• Live Chat: Available 24/7 via the Platform interface
• Written Correspondence: Address inquiries to our customer support team, who will forward them to the appropriate department

We will respond to all data privacy inquiries within fifteen (15) business days, or within the timeframe required by the Data Privacy Act of 2012, whichever is shorter.

3. Personal Information We Collect

3.1 Information You Provide Directly

When you register an account with 639ph, we collect the following categories of personal information:

• Identity Information: Full legal name, date of birth, gender, and nationality
• Contact Information: Email address, mobile phone number, and residential address
• Account Credentials: Username, password (stored in encrypted form), and security questions
• Payment Information: GCash account details, PayMaya account details, bank account information, and transaction history
• Verification Documents: Government-issued identification (passport, driver's license, national ID), proof of address (utility bills, bank statements), and proof of payment method ownership
• Gaming Preferences: Preferred games, deposit limits, responsible gaming settings, and communication preferences

3.2 Information Collected Automatically

When you access the 639ph Platform, we automatically collect certain technical and usage information, including:

• Device Information: Device type, operating system, browser type and version, screen resolution, and device identifiers
• Connection Information: IP address, internet service provider, geographic location (city and region level), and time zone
• Usage Data: Pages visited, games played, wagers placed, session duration, click patterns, and navigation paths
• Cookie Data: Session cookies, preference cookies, security cookies, and analytics cookies (see Section 8 for details)

3.3 Information from Third Parties

We may receive personal information about you from the following third-party sources:

• Payment Processors: Transaction verification and fraud detection data from GCash, PayMaya, and partner banks
• Game Providers: Gaming session data and gameplay statistics from licensed game suppliers
• Identity Verification Services: Age verification and identity authentication data from third-party KYC providers
• Public Databases: Information used to comply with anti-money laundering and sanctions screening requirements

4. How We Use Your Personal Information

4.1 Purposes of Data Processing

639ph processes your personal information for the following purposes, all of which are lawful under the Data Privacy Act of 2012:

Purpose	Legal Basis
Account registration and authentication	Performance of contract
Processing deposits and withdrawals	Performance of contract
Providing access to gaming services	Performance of contract
Age and identity verification (KYC)	Legal obligation (PAGCOR regulations)
Anti-money laundering (AML) compliance	Legal obligation (AMLA)
Fraud detection and prevention	Legitimate interest (platform security)
Customer support services	Performance of contract
Responsible gaming protection	Legal obligation and legitimate interest
Marketing communications (with consent)	Consent (opt-in required)
Platform improvement and analytics	Legitimate interest (service optimization)

4.2 Marketing Communications

With your explicit consent, 639ph may send promotional emails, SMS messages, or push notifications regarding new games, bonuses, and special offers. You may opt out of marketing communications at any time by clicking the "unsubscribe" link in any email, replying "STOP" to SMS messages, or adjusting your notification preferences in your account settings. Opting out of marketing will not affect transactional communications (such as deposit confirmations or withdrawal notifications).

5. Data Sharing and Disclosure

5.1 Third Parties with Whom We Share Data

639ph does not sell, rent, or trade your personal information to third parties for their marketing purposes. We share your data only with the following categories of recipients, and only to the extent necessary for the purposes described:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners, solely for the purpose of processing deposits and withdrawals
• Licensed Game Providers: JILI and other accredited game suppliers who provide gaming software and content on the Platform
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to fulfil regulatory obligations
• Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent Philippine government agencies as required by law
• IT and Security Service Providers: Cloud hosting providers, cybersecurity firms, and data analytics vendors engaged under strict confidentiality and data processing agreements
• Legal and Professional Advisors: Lawyers, auditors, and compliance consultants where disclosure is necessary for legal proceedings or professional advice

5.2 International Data Transfers

In certain circumstances, your personal data may be processed or stored outside the Philippines, for example when we use cloud infrastructure hosted in other jurisdictions. In such cases, 639ph ensures that appropriate safeguards are in place to protect your data, including contractual clauses that require overseas processors to maintain standards equivalent to those required under the Data Privacy Act of 2012.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 639ph's business assets, your personal information may be transferred to the relevant successor entity. We will notify affected users via email or prominent Platform notice before any such transfer takes effect and will ensure that your data continues to be protected under standards at least equivalent to this Privacy Policy.

6. Data Retention

639ph retains your personal information for as long as your account remains active or as necessary to fulfil the purposes described in this Privacy Policy. Upon account closure, we retain certain data for the following minimum periods to comply with our legal obligations:

• Transaction records and financial data: Five (5) years from the date of each transaction, as required by anti-money laundering regulations
• Account registration and identity verification data: Five (5) years from the date of account closure
• Customer support records: Three (3) years from the date of the support interaction
• Responsible gaming records: Five (5) years from the date of account closure to facilitate re-registration checks and exclusion compliance
• Marketing preference data: Until you withdraw consent, after which data is promptly deleted or anonymised

After the applicable retention period expires, personal data is securely deleted or irreversibly anonymised so that it can no longer be linked to any individual.

7. Your Rights Under the Data Privacy Act of 2012

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal information held by 639ph:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and shared, which this Privacy Policy satisfies.
• Right of Access: You may request a copy of the personal information we hold about you at any time. We will provide this within twenty (20) business days of a verified request.
• Right to Rectification: If any personal information we hold about you is inaccurate or incomplete, you may request that we correct or update it.
• Right to Erasure or Blocking: You may request that we delete or block your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Data Portability: Where technically feasible, you may request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You may object at any time to the processing of your personal data for direct marketing purposes or where we rely on legitimate interest as our legal basis, subject to overriding legal grounds.
• Right to File a Complaint: If you believe that your data privacy rights have been violated, you may file a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact our Data Privacy Officer via live chat or the support email listed in the footer of this page. We may require you to verify your identity before processing your request to ensure your data is protected from unauthorised access.

8. Cookies and Tracking Technologies

8.1 Types of Cookies We Use

639ph uses cookies and similar tracking technologies to enhance the functionality, security, and performance of the Platform. Cookies are small text files stored on your device by your web browser. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including session management, authentication, and security tokens. These cannot be disabled without affecting core Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, preferred payment method, and responsible gaming limits to provide a personalised experience.
• Performance and Analytics Cookies: Collect anonymised data about how users interact with the Platform, helping us identify areas for improvement and optimise page performance.
• Security Cookies: Help detect and prevent fraudulent activity, bot traffic, and account takeover attempts by monitoring session behaviour patterns.

8.2 Managing Your Cookie Preferences

You can manage or delete cookies through your browser settings at any time. Most browsers allow you to refuse new cookies, delete existing cookies, or receive notifications before a cookie is stored. Please note that disabling certain cookies may affect the availability of some Platform features, including the ability to maintain your logged-in session.

9. Data Security Measures

639ph implements comprehensive technical and organisational security measures to protect your personal information against unauthorised access, loss, destruction, or alteration. Our security practices include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers
• AES-256 encryption for sensitive personal data stored in our databases
• Multi-factor authentication (MFA) options for account access
• Regular independent security audits and penetration testing by accredited third-party firms
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis
• 24/7 network monitoring and intrusion detection systems
• Regular staff training on data privacy obligations and cybersecurity best practices

While we take every reasonable precaution to protect your data, no internet transmission or electronic storage system is completely secure. In the unlikely event of a data breach affecting your personal information, 639ph will notify you and the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, as required by law.

10. Children's Privacy

The 639ph Platform is strictly intended for persons who are twenty-one (21) years of age or older. We do not knowingly collect personal information from any individual under the age of 21. If we become aware that personal information has been collected from a person under this age threshold, we will take immediate steps to delete such information and close the associated account. If you believe that a minor has provided us with personal information, please contact our support team immediately.

11. Links to Third-Party Services

The 639ph Platform may display or reference information about third-party payment providers and licensed game suppliers as part of our service delivery. These third-party providers maintain their own separate privacy policies. 639ph is not responsible for the data practices of third-party service providers beyond the contractual obligations we impose on them as data processors acting on our behalf.

12. Changes to This Privacy Policy

639ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or business operations. When we make material changes, we will provide notice by posting the updated policy on the Platform with a revised "Last Updated" date and, where required, by sending direct notification to affected users via email or Platform notification.

Your continued use of the 639ph Platform following the effective date of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically to stay informed about how we protect your data.

13. Governing Law and Jurisdiction

This Privacy Policy shall be governed by and interpreted in accordance with the laws of the Republic of the Philippines, including but not limited to Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations. Any disputes arising from this Privacy Policy shall be subject to the jurisdiction of the appropriate Philippine courts and regulatory bodies, including the National Privacy Commission.