Privacy Policy

1. Introduction

This Privacy Policy ("Policy") applies to the 639 Club website at 639club.lat and all associated services, mobile experiences, and features (collectively, the "Platform") operated by 639 Club ("639 Club," "we," "us," or "our"). It describes how we handle personal data relating to individuals who register accounts, visit the Platform, or otherwise interact with 639 Club services.

639 Club is committed to protecting the privacy of Filipino players and all other users in accordance with the Philippines Data Privacy Act of 2012 (Republic Act No. 10173, or "DPA") and its Implementing Rules and Regulations. We process personal data only for legitimate purposes, in a manner that is proportionate, transparent, and secure.

2. Data Controller

For the purposes of applicable data protection law, the data controller responsible for your personal information is 639 Club. If you have questions or requests relating to your personal data, you may contact our Data Protection Officer at the address provided in Section 13 of this Policy.

3. Information We Collect

3.1 Information You Provide Directly

When you register an account, verify your identity, make deposits or withdrawals, or contact our support team, 639 Club may collect the following categories of personal information:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification number (e.g., PhilSys ID number, UMID, driver's license, or passport number).
• Contact Data: Email address, Philippine mobile number, and mailing address.
• Financial Data: GCash account number, Maya account number, bank account details (BPI, BDO, Metrobank, UnionBank, etc.), and transaction history on the 639 Club platform.
• Verification Documents: Copies of government-issued IDs, selfies with ID, and proof of address documents submitted for KYC purposes.
• Support Communications: Records of your conversations with the 639 Club customer support team, including live chat transcripts and email correspondence.

3.2 Information Collected Automatically

When you access the 639 Club Platform, we automatically collect certain technical data including:

• IP address and approximate geographic location derived from it.
• Device type, operating system, and browser information.
• Pages visited, game sessions initiated, bet history, and session duration.
• Referral source (if you arrived via a link from another site or campaign).
• Cookie identifiers and similar tracking technologies as described in Section 7.

4. How We Use Your Personal Data

639 Club uses your personal data only for the specific purposes listed below. We do not use your data for any purpose incompatible with the original collection purpose without your prior consent.

• Account Management: To create, maintain, and manage your 639 Club player account, including processing deposits, withdrawals, and bonus claims.
• Identity Verification (KYC): To verify your identity and age in compliance with anti-money laundering regulations and PAGCOR licensing requirements.
• Regulatory Compliance: To meet reporting obligations to regulators and law enforcement authorities as required by Philippine law.
• Fraud Prevention & Security: To detect and prevent fraudulent activity, money laundering, and other illegal conduct on the platform.
• Responsible Gaming: To monitor gaming patterns and implement responsible gaming tools where player protection concerns are identified.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Platform Improvement: To analyse usage patterns and improve the functionality, performance, and content of the 639 Club Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and product updates, where you have opted in or where we have a legitimate interest in doing so. You may opt out at any time.

5. Legal Basis for Processing

Under the Philippines Data Privacy Act, 639 Club processes your personal data on the following legal grounds:

• Contractual Necessity: Processing required to fulfil the 639 Club Terms & Conditions and to operate your player account.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, tax reporting obligations, and PAGCOR requirements.
• Legitimate Interest: Processing for fraud prevention, platform security, customer support quality monitoring, and aggregate analytics.
• Consent: Processing for marketing communications and for certain cookie technologies, where we have obtained your explicit consent.

6. Sharing Your Data with Third Parties

639 Club does not sell your personal information. We may share your data with the following categories of third parties strictly as necessary:

• Payment Processors: GCash (Mynt), Maya (PayMaya Philippines), partner banks, and cryptocurrency wallet providers, to process deposits and withdrawals.
• Game Providers: Licensed software providers whose games are available on the 639 Club Platform, where game session data must be transmitted to facilitate gameplay.
• Identity Verification Services: Third-party KYC providers engaged to assist with document verification and fraud screening.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government bodies, where required by law or regulation.
• IT & Cloud Service Providers: Third-party hosting, database, and security service providers engaged under data processing agreements that restrict their use of your data to defined service delivery purposes.

All third parties with whom 639 Club shares personal data are contractually required to maintain appropriate security standards and to use your data only for the purposes for which it was shared.

7. Cookies and Tracking Technologies

The 639 Club Platform uses cookies and similar technologies to deliver, maintain, and improve the service. Cookies are small text files stored on your device when you visit the Platform.

Types of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to function, including session authentication and security tokens. These cannot be disabled.
• Functional Cookies: Remember your preferences, language settings, and game lobby layout choices.
• Analytics Cookies: Collect anonymised data about how players use the Platform to help us identify improvement opportunities.
• Marketing Cookies: Track campaign effectiveness and help us serve relevant promotions where you have consented to marketing.

You can manage non-essential cookies via your browser settings or through the cookie preference centre on the Platform. Disabling certain cookies may affect Platform functionality.

8. Data Retention

639 Club retains your personal data for as long as your account is active and for such additional periods as are required by law or legitimate business purpose. In general:

• Account and transaction records are retained for a minimum of five (5) years following account closure, in compliance with Philippine anti-money laundering record-keeping requirements.
• KYC documents are retained for a minimum of five (5) years or as required by the relevant regulatory authority.
• Customer support communications are retained for two (2) years.
• Marketing consent records are retained until you withdraw consent plus two (2) years for compliance evidence purposes.

On expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 639 Club data disposal procedures.

9. Data Security

639 Club implements technical and organisational security measures appropriate to the sensitivity of the personal data we process. These measures include:

• SSL/TLS encryption for all data in transit between the Platform and your device.
• Encryption of sensitive data fields at rest, including financial account details and identity document references.
• Role-based access controls limiting internal access to personal data to personnel who require it for defined job functions.
• Regular security assessments and penetration testing of Platform infrastructure.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

Notwithstanding these measures, no internet transmission is completely secure. 639 Club cannot guarantee absolute security and recommends that players also take steps to protect their own account credentials.

10. Your Data Rights

Under the Philippines Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 639 Club:

• Right to be Informed: The right to know how your personal data is being collected, processed, and used — which is the purpose of this Policy.
• Right to Access: The right to obtain a copy of the personal data we hold about you and information about how it is used.
• Right to Correction: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention requirements.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to Object: The right to object to processing based on legitimate interest, including direct marketing.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, contact the 639 Club Data Protection Officer as described in Section 13. We will respond to verified requests within thirty (30) days.

11. Children and Minors

The 639 Club Platform is strictly for individuals who are 21 years of age or older. We do not knowingly collect personal data from persons under the age of 21. If we become aware that personal data has been submitted by an individual under 21, we will delete that data and close the associated account promptly. If you believe a minor has registered on the Platform, please contact our support team immediately.

12. Changes to This Privacy Policy

639 Club may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, we will post a notice on the Platform and update the "Last Updated" date at the top of this page. We encourage you to review this Policy periodically. Your continued use of the 639 Club Platform following the posting of any update constitutes your acknowledgement of the revised Policy.

13. Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact the 639 Club Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 from within the Platform (login required). Mark your message as "Privacy / Data Request."
• Response Time: We aim to acknowledge all data-related requests within 5 business days and to resolve them within 30 days.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.