639 Club Privacy Policy

1 Introduction

1.1 639 Club is committed to protecting the privacy and security of your personal information. We understand that trust is the foundation of our relationship with every Filipino player on our platform, and we take our data protection obligations seriously.

1.2 This Policy applies to all personal information collected through the 639 Club website, mobile platform, customer support channels, and any other 639 Club service. It applies to registered members and unregistered visitors alike.

1.3 639 Club acts as the data controller for personal information collected through the platform. Our designated Data Protection Officer (DPO) can be contacted at the details provided in Section 13 of this Policy.

1.4 Please read this Policy carefully alongside our Terms & Conditions and Responsible Gaming Policy, which together govern your use of the 639 Club platform.

2 Information We Collect

2.1 Registration Information. When you create a 639 Club account, we collect: full name, date of birth, gender, nationality, residential address (including city, province, and ZIP code), email address, and mobile number. This information is required to verify your identity and comply with our Know Your Customer (KYC) obligations.

2.2 Identity Verification Documents. To comply with Philippine anti-money laundering regulations and gaming licensing requirements, we may collect copies of government-issued identification documents such as a Philippine passport, driver's license, SSS/GSIS ID, PhilSys National ID, or Voter's ID, as well as proof of address documents.

2.3 Financial Information. We collect information about your deposits, withdrawals, and transaction history on the 639 Club platform. We also collect payment method details such as GCash account numbers, PayMaya account details, and bank account information (BPI, BDO, Metrobank, UnionBank) as necessary to process transactions. Full payment credentials are processed through secure, certified payment processors and are not stored on 639 Club servers.

2.4 Gaming Activity. We collect records of your gaming activity on 639 Club, including games played, bets placed, wins and losses, session duration, and bonus usage. This information is used for account management, responsible gaming monitoring, and regulatory compliance.

2.5 Technical Information. When you access the 639 Club platform, we automatically collect: IP address, device type and operating system, browser type and version, referring URL, pages visited, time and date of access, and session duration. This information is collected through cookies and similar tracking technologies as described in Section 8.

2.6 Communications. We retain records of communications between you and 639 Club, including live chat transcripts, email correspondence, and support ticket history. These records are used to resolve disputes, improve our services, and comply with regulatory requirements.

2.7 Voluntary Information. You may voluntarily provide additional information such as preferred language, gaming preferences, and feedback through surveys or promotional activities.

3 How We Use Your Information

3.1 639 Club uses your personal information for the following purposes:

• Account Management: To create, maintain, and manage your 639 Club account, including processing deposits and withdrawals, crediting bonuses, and maintaining your gaming history;
• Identity Verification: To verify your identity, age (21+), and eligibility to use the 639 Club platform in compliance with Philippine gaming regulations;
• Regulatory Compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML) requirements, gaming licensing conditions, and tax reporting obligations;
• Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion requests, and provide responsible gaming tools and interventions;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Platform Improvement: To analyze usage patterns, identify technical issues, and improve the features and performance of the 639 Club platform;
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, subject to your communication preferences and applicable law.

3.2 639 Club will not use your personal information for any purpose incompatible with those stated in this Policy without first obtaining your consent or as otherwise permitted by applicable law.

4 Legal Basis for Processing

4.1 639 Club processes your personal information on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary for the performance of our contract with you (i.e., providing the 639 Club gaming service);
• Legal Obligation: Processing necessary to comply with our legal obligations under Philippine law, including AML regulations, gaming licensing requirements, and tax laws;
• Legitimate Interests: Processing necessary for our legitimate interests in operating a secure, fair, and compliant gaming platform, provided such interests are not overridden by your rights and interests;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5 Sharing Your Information

5.1 639 Club does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We may share your information with the following categories of recipients only as necessary and in accordance with this Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment service providers, solely to process your financial transactions;
• Identity Verification Providers: Third-party KYC and AML compliance service providers who assist us in verifying player identities and screening for sanctions;
• Game Providers: Software providers whose games are available on the 639 Club platform, to the extent necessary to provide the gaming service;
• Regulatory Authorities: The Philippine Amusement and Gaming Corporation (PAGCOR), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, as required by law;
• Law Enforcement: Philippine law enforcement agencies where required by law or court order;
• Professional Advisors: Legal, accounting, and auditing professionals bound by professional confidentiality obligations;
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of 639 Club's assets, your information may be transferred to the acquiring entity, subject to equivalent privacy protections.

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

6 Data Retention

6.1 639 Club retains your personal information for as long as your account is active and for such additional period as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

6.2 In accordance with Philippine AML regulations and gaming licensing requirements, transaction records and identity verification documents are retained for a minimum of five (5) years following the closure of your account or the completion of the relevant transaction, whichever is later.

6.3 Gaming activity records are retained for a minimum of three (3) years for responsible gaming monitoring and dispute resolution purposes.

6.4 Upon expiry of the applicable retention period, your personal information will be securely deleted or anonymized in accordance with 639 Club's data disposal procedures.

7 Data Security

7.1 639 Club implements comprehensive technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 639 Club servers;
• Encryption of sensitive data at rest using industry-standard encryption algorithms;
• Multi-factor authentication options for player accounts;
• Regular security audits and penetration testing by independent security professionals;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Regular staff training on data protection and information security;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

7.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 639 Club will notify the Philippine National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay where required by law.

7.3 While 639 Club takes all reasonable steps to protect your personal information, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the security of your 639 Club login credentials and for notifying us immediately of any suspected unauthorized access to your account.

8 Cookies & Tracking Technologies

8.1 639 Club uses cookies and similar tracking technologies to enhance your experience on the platform, analyze usage patterns, and support our security and fraud prevention measures. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the 639 Club platform, including session management, authentication, and security. These cookies cannot be disabled.
• Performance & Analytics Cookies: Used to collect anonymized information about how players use the 639 Club platform, helping us identify areas for improvement and optimize performance.
• Functional Cookies: Used to remember your preferences such as language settings, display preferences, and recently played games to provide a more personalized experience.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns. These cookies are only set with your consent.

8.2 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 639 Club platform. Instructions for managing cookies in common browsers are available through your browser's help documentation.

8.3 639 Club does not use cookies to collect sensitive personal information such as financial details or government ID numbers.

9 Your Rights Under the Data Privacy Act

9.1 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 639 Club:

• Right to be Informed: The right to be informed of how your personal data is being collected and processed, as described in this Policy;
• Right of Access: The right to obtain confirmation of whether 639 Club holds personal data about you and to receive a copy of that data;
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected or updated;
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention requirements;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: The right to lodge a complaint with the Philippine National Privacy Commission (NPC) if you believe your data protection rights have been violated.

9.2 To exercise any of the above rights, please contact 639 Club's Data Protection Officer using the contact details in Section 13. We will respond to your request within thirty (30) days. In complex cases, this period may be extended by a further sixty (60) days, and you will be notified of any such extension.

9.3 Marketing Opt-Out. You may opt out of receiving marketing communications from 639 Club at any time by clicking the "unsubscribe" link in any marketing email, updating your communication preferences in your account settings, or contacting our support team. Opting out of marketing communications will not affect transactional or service-related communications.

10 Children's Privacy

10.1 The 639 Club platform is strictly intended for persons aged twenty-one (21) years and above. 639 Club does not knowingly collect personal information from individuals under the age of 21. If we become aware that we have inadvertently collected personal information from a person under 21, we will take immediate steps to delete that information and close the associated account.

10.2 If you are a parent or guardian and believe that your child under the age of 21 has provided personal information to 639 Club, please contact us immediately at the details provided in Section 13 so that we can take appropriate action.

11 International Data Transfers

11.1 639 Club primarily processes and stores personal data within the Philippines. In certain circumstances, your personal data may be transferred to and processed in countries outside the Philippines, for example where our technology service providers or game software providers are located in other jurisdictions.

11.2 Where personal data is transferred outside the Philippines, 639 Club ensures that appropriate safeguards are in place to protect your data in accordance with the requirements of the Philippine Data Privacy Act, including the use of contractual clauses approved by the National Privacy Commission or transfers to countries with an adequate level of data protection.

11.3 By using the 639 Club platform, you consent to the transfer of your personal information to countries outside the Philippines where necessary for the provision of our services, subject to the safeguards described in this section.

12 Changes to This Privacy Policy

12.1 639 Club reserves the right to update or modify this Privacy Policy at any time. When we make material changes to this Policy, we will notify you by posting the updated Policy on this page with a revised "Last Updated" date, and where appropriate, by sending you a notification via email or through the 639 Club platform.

12.2 Your continued use of the 639 Club platform following the posting of any changes to this Policy constitutes your acceptance of those changes. We encourage you to review this Policy periodically to stay informed about how 639 Club protects your personal information.

12.3 If you do not agree to the revised Privacy Policy, you must discontinue your use of the 639 Club platform and may request closure of your account in accordance with our Terms & Conditions.

13 Contact & Complaints

13.1 If you have any questions, concerns, or requests regarding this Privacy Policy or 639 Club's data protection practices, please contact our Data Protection Officer:

• Data Protection Officer, 639 Club
• Email: [email protected]
• General Support: [email protected]
• Response Time: Within 30 days of receipt of your request

13.2 If you are not satisfied with 639 Club's response to your privacy concern, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC). The NPC is the government body responsible for administering and implementing the Data Privacy Act of 2012 in the Philippines.

13.3 639 Club takes all privacy complaints seriously and will work diligently to resolve any concerns you may have regarding the handling of your personal information.