639gl Privacy Policy

1 Introduction

1.1 639gl is committed to protecting the privacy and personal data of every player who uses our platform. We understand that trust is the foundation of any good relationship – and that goes double when real money and personal information are involved. This Policy sets out, in plain and transparent terms, exactly what data we collect, why we collect it, how we use it, and what rights you have over it.

1.2 639gl operates in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), and its Implementing Rules and Regulations. We are registered with the National Privacy Commission (NPC) as required under Philippine law.

1.3 This Policy applies to all personal data collected through the 639gl website, mobile platform, customer support channels, and any other touchpoint where you interact with 639gl. It covers data collected from players based in the Philippines and from any other jurisdiction where 639gl operates.

1.4 This Policy should be read alongside 639gl's Terms & Conditions and Responsible Gaming Policy, which together form the complete framework governing your relationship with 639gl.

2 Personal Data We Collect

2.1 639gl collects the following categories of personal data from players and platform users:

2.2 We do not collect sensitive personal information (as defined under the DPA) unless it is strictly necessary for regulatory compliance, such as for anti-money laundering (AML) or responsible gaming purposes, and only with your explicit consent where required.

3 How We Collect Your Data

3.1 639gl collects personal data through the following means:

• Direct interactions: When you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions, you provide us with personal data directly.
• Automated technologies: When you access the 639gl platform, we automatically collect technical and usage data through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: We may receive data about you from payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), identity verification providers, fraud prevention services, and analytics partners.
• Regulatory sources: We may receive data from regulatory authorities, law enforcement agencies, or other government bodies where required by law.

4 How We Use Your Personal Data

4.1 639gl uses your personal data for the following purposes:

• To create and manage your 639gl player account;
• To verify your identity and age (21+ requirement) in compliance with Philippine law and PAGCOR regulations;
• To process deposits and withdrawals via your chosen payment method;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities;
• To provide customer support and resolve disputes;
• To send you transactional communications, including account notifications, deposit confirmations, and withdrawal updates;
• To send you promotional communications about 639gl offers and bonuses, where you have consented to receive such communications;
• To monitor your gaming activity for responsible gaming purposes and to apply any self-imposed limits or restrictions;
• To improve the 639gl platform, games, and services through analytics and user research;
• To comply with our legal and regulatory obligations under Philippine law.

4.2 639gl will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

5 Legal Basis for Processing

5.1 Under the Data Privacy Act of 2012, 639gl processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to perform our contract with you (i.e., to provide the 639gl gaming services you have registered for).
• Legal obligation: Processing is necessary to comply with our legal obligations, including KYC, AML, and responsible gaming requirements under Philippine law and PAGCOR regulations.
• Legitimate interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and interests.
• Consent: Where we rely on your consent as the legal basis for processing (for example, for marketing communications), you have the right to withdraw that consent at any time by contacting our support team or updating your account preferences.

6 Sharing Your Personal Data

6.1 639gl does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to process your deposits and withdrawals;
• Identity verification providers: Third-party KYC and AML service providers who assist us in verifying player identities and complying with regulatory requirements;
• Technology and hosting providers: Cloud hosting, data storage, and platform infrastructure providers who process data on our behalf under strict data processing agreements;
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies, where required by law;
• Law enforcement: Philippine law enforcement agencies, where we are legally required to disclose information in connection with a criminal investigation or legal proceeding;
• Professional advisers: Lawyers, auditors, and accountants, where necessary for the conduct of our business.

6.2 All third parties with whom 639gl shares personal data are required to maintain appropriate technical and organizational security measures and to process your data only in accordance with our instructions and applicable law.

7 Cookies & Tracking Technologies

7.1 639gl uses cookies and similar tracking technologies to enhance your experience on our platform, to keep you logged in, to remember your preferences, and to collect analytics data that helps us improve our services.

7.2 The following types of cookies are used on the 639gl platform:

• Strictly necessary cookies: Essential for the platform to function. These cannot be disabled without affecting core functionality such as login sessions and security.
• Performance cookies: Collect anonymized data about how players use the platform, which pages are visited most, and where errors occur. This data helps us improve the 639gl experience.
• Functional cookies: Remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics cookies: Used to understand aggregate player behaviour and platform usage patterns. Data collected is anonymized and used for internal reporting only.

7.3 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 639gl platform. Strictly necessary cookies cannot be disabled.

8 Data Retention

8.1 639gl retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

8.2 In general, 639gl retains player account data for a minimum of five (5) years following account closure, in compliance with Philippine AML regulations and PAGCOR record-keeping requirements. Financial transaction records are retained for a minimum of ten (10) years.

8.3 Where personal data is no longer required for any lawful purpose, 639gl will securely delete or anonymize it in accordance with our data retention schedule and applicable law.

8.4 If you request deletion of your personal data, we will assess your request against our legal retention obligations. Where we are required by law to retain certain data, we will inform you of this and retain only the minimum data necessary to comply with our legal obligations.

9 Your Data Privacy Rights

9.1 Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 639gl:

• Right to be informed: You have the right to be informed about how your personal data is collected and processed. This Policy fulfils that obligation.
• Right of access: You have the right to request a copy of the personal data 639gl holds about you.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You have the right to request deletion of your personal data, subject to our legal retention obligations.
• Right to object: You have the right to object to the processing of your personal data where we rely on legitimate interests as our legal basis.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• 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 processing carried out before withdrawal.

9.2 To exercise any of these rights, please contact 639gl's Data Protection Officer via our support team. We will respond to all verified requests within thirty (30) days in accordance with the DPA. We may need to verify your identity before processing your request.

9.3 If you believe that 639gl has not handled your personal data in accordance with this Policy or applicable law, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

10 Data Security

10.1 639gl implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 639gl platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Two-factor authentication options for player accounts;
• Continuous monitoring for suspicious activity and unauthorized access attempts.

10.2 While 639gl takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for keeping your 639gl login credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

10.3 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 639gl will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

11 Children's Privacy

11.1 The 639gl platform is strictly intended for persons aged 21 years and above. 639gl does not knowingly collect personal data from persons under the age of 21. If you are under 21, you must not use the 639gl platform or provide any personal data to us.

11.2 If 639gl becomes aware that it has inadvertently collected personal data from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the 639gl platform, please contact our support team immediately.

12 Changes to This Privacy Policy

12.1 639gl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. Where changes are material, we will provide reasonable notice to registered players via email or a prominent notice on the platform prior to the changes taking effect.

12.2 The "Last Updated" date at the top of this page indicates when this Policy was most recently revised. We encourage you to review this Policy periodically to stay informed about how 639gl protects your personal data.

12.3 Your continued use of the 639gl platform following the posting of any changes to this Policy constitutes your acceptance of those changes.

13 Contact Our Data Protection Officer

13.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the way 639gl handles your personal data, please contact our Data Protection Officer through any of the following channels:

• Support Email: support@639gl.com
• Live Chat: Available 24/7 via the 639gl platform

13.2 We are committed to resolving all privacy-related concerns promptly and transparently. If you are not satisfied with our response, you may escalate your complaint to the National Privacy Commission of the Philippines.