This Privacy Policy explains how 639ph collects, uses, stores, protects, and discloses your personal data in compliance with the Philippine Data Privacy Act of 2012 and PAGCOR licensing requirements. Your privacy is not an afterthought here — it is a legal obligation we take seriously.
These highlights summarize the most important aspects of how 639ph handles your data. They do not replace the full policy below, which you should read in its entirety.
639ph collects personal information you provide during registration (name, date of birth, email, mobile number, address), identity documents for KYC, payment transaction data, device and usage information, and communications with our support team. We collect only what is necessary for the purposes described in this policy.
Your data is used to operate your 639ph account, process deposits and withdrawals, verify your identity under PAGCOR KYC requirements, detect and prevent fraud, comply with Philippine legal obligations, and improve the platform experience. We do not use your data for purposes beyond what is stated in this policy without your consent.
639ph shares personal data only with payment processors (GCash, Maya, BPI, BDO), game providers where technically necessary, PAGCOR and relevant Philippine regulatory authorities as required by law, and fraud prevention services. We do not sell your personal data to advertisers, data brokers, or any commercial third parties.
639ph employs 256-bit SSL/TLS encryption on all data in transit, encrypted storage for personal data at rest, access controls limiting staff access to data on a need-to-know basis, regular security audits, and intrusion detection systems. Identity documents are stored in a segregated, access-controlled system separate from general platform data.
Under the Philippine Data Privacy Act, you have the right to access your personal data held by 639ph, correct inaccurate information, object to specific processing, request data portability, and in certain circumstances request erasure. You may exercise these rights by contacting our Data Protection Officer at [email protected].
639ph retains personal data for the duration of your account's active life and for up to five (5) years following account closure, as required by PAGCOR compliance obligations and Philippine anti-money laundering regulations. Identity documents may be retained for longer periods where required by specific regulatory mandates.
This Privacy Policy applies to all personal data processed by 639ph in connection with the operation of the 639ph online gaming platform accessible at 639ph.club and its associated subdomains (the "Platform"). It applies to all registered Players, visitors, and individuals who interact with 639ph through the Platform, our support channels, or any other means.
639ph is committed to protecting the privacy of Filipino players and all individuals whose personal data it processes. This commitment is not merely a statement of intent — it is backed by legal obligations under the Philippine Data Privacy Act of 2012 (Republic Act 10173, hereinafter "DPA"), the Implementing Rules and Regulations issued under the DPA, and the data protection requirements forming part of 639ph's PAGCOR licensing conditions.
This policy is written in plain, accessible English. Where legal terminology is unavoidable, it is explained in context. 639ph believes Filipino players deserve to understand what happens to their data in straightforward language — not buried in confusing legalese.
For the purposes of the Philippine Data Privacy Act, 639ph is the Personal Information Controller in respect of all personal data collected through the Platform. This means 639ph determines the purposes and means of processing your personal data and bears primary responsibility for ensuring that processing is conducted lawfully and in accordance with your rights.
639ph has appointed a Data Protection Officer (DPO) as required under the DPA. The DPO is responsible for overseeing 639ph's data protection compliance programme, acting as the point of contact for data subject rights requests, and liaising with the National Privacy Commission (NPC) where necessary.
639ph collects the following categories of personal data in the course of operating the Platform:
639ph collects personal data through the following means:
The majority of personal data 639ph holds about you is provided directly by you — during account registration, during the KYC verification process, when you make a deposit or withdrawal, when you contact our support team, and when you use responsible gaming tools such as deposit limit requests or self-exclusion applications.
When you access the 639ph Platform, certain technical data is collected automatically by our servers and analytics systems — including your IP address, device type, browser information, and session activity data. This data collection is necessary for the secure and functional operation of the Platform and for fraud detection purposes.
In limited circumstances, 639ph may receive personal data about you from third parties, including: payment providers (transaction confirmation data from GCash, Maya, or your bank); identity verification service providers used to assist in KYC processing; and fraud detection agencies where 639ph has a legitimate compliance interest in verifying the integrity of an account or transaction.
Under the Philippine Data Privacy Act, 639ph processes personal data on the following lawful bases:
| Processing Purpose | Legal Basis |
|---|---|
| Account registration and management | Performance of contract (your account agreement with 639ph) |
| Processing deposits and withdrawals | Performance of contract |
| KYC identity verification | Legal obligation (PAGCOR licensing requirement) |
| Anti-money laundering compliance | Legal obligation (Republic Act 9160, as amended) |
| Fraud detection and security monitoring | Legitimate interest of 639ph and protection of all players |
| Responsible gaming monitoring | Legal obligation (PAGCOR responsible gaming requirements) |
| Reporting to PAGCOR and regulatory authorities | Legal obligation |
| Platform improvement and analytics | Legitimate interest of 639ph |
| Marketing communications (where opted in) | Consent (you may withdraw consent at any time) |
| Dispute resolution and legal proceedings | Legitimate interest / legal obligation |
639ph uses your personal data for the following purposes:
639ph does not sell, rent, or trade your personal data to any third party for commercial purposes. Personal data is shared only in the following circumstances and only to the minimum extent necessary:
To process your deposits and withdrawals, 639ph shares the minimum necessary transaction and account reference data with payment providers including GCash (G-Xchange, Inc.), Maya Philippines, Inc., and the banking institutions you use for transfers. These providers process your data under their own privacy policies and are required by Philippine financial regulation to maintain appropriate data security standards.
Game providers whose titles are featured on the 639ph Platform (including Pragmatic Play, PG Soft, Habanero, Evolution Gaming, and SA Gaming) may receive session data necessary for game operation — such as a session token, wager amounts, and game results. This data is transmitted over encrypted channels and is limited to what is required for game functionality. Game providers do not receive your full personal identity information.
639ph is legally required to disclose personal data to PAGCOR as part of its licensing obligations and to Philippine law enforcement and judicial authorities when required by law, court order, or legal process. 639ph will notify you of such disclosures where it is legally permitted to do so.
Under the Anti-Money Laundering Act of 2001 (Republic Act 9160) as amended by Republic Act 10365 and Republic Act 11521, 639ph is required to report certain transactions to the Anti-Money Laundering Council (AMLC). Such reports are mandated by law and are not subject to your consent or objection.
639ph may share limited data with fraud detection and identity verification service providers engaged to assist with KYC processing and account security monitoring. Such providers are engaged under data processing agreements and are prohibited from using your data for any purpose beyond the specific service they provide to 639ph.
In the event of a merger, acquisition, or sale of 639ph's business or assets, personal data held by 639ph may be transferred to the acquiring entity. In such circumstances, 639ph will provide advance notice to affected Players and ensure the acquiring entity is bound by privacy obligations no less protective than those in this policy.
639ph uses cookies and similar tracking technologies on the Platform for the following purposes:
639ph does not use advertising or retargeting cookies. Your browsing activity on the Platform is not shared with advertising networks. You may manage your cookie preferences through your browser settings, noting that disabling strictly necessary and security cookies may affect Platform access and functionality.
639ph implements technical and organizational measures designed to protect your personal data against unauthorized access, alteration, disclosure, loss, or destruction. These measures include:
639ph retains personal data for no longer than is necessary for the purposes for which it was collected, subject to the following retention schedules:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account registration data | Duration of account + 5 years post-closure | PAGCOR compliance; AML obligations |
| KYC identity documents | Duration of account + 5 years post-closure (minimum) | Anti-Money Laundering Act (RA 9160) |
| Financial transaction records | 5 years from transaction date | PAGCOR; AML; tax obligations |
| Game history and wager records | 5 years from transaction date | PAGCOR licensing; dispute resolution |
| Support communications | 3 years from last interaction | Legitimate interest; dispute resolution |
| Technical/usage logs | 12 months from creation | Security; fraud detection |
| Marketing consent records | Until consent withdrawn + 3 years | Compliance with DPA consent requirements |
Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 639ph's data disposal procedures. Note that certain data may be retained for longer periods where 639ph is subject to ongoing legal proceedings, regulatory investigations, or specific PAGCOR directives requiring extended retention.
Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 639ph. To exercise any of these rights, contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Rights Request."
The 639ph Platform is strictly restricted to individuals aged 21 years and above, as required by PAGCOR regulations and Philippine law governing online gambling. 639ph does not knowingly collect or process personal data from any individual under the age of 21. Age verification is a mandatory component of the KYC process for all accounts.
If 639ph discovers or is notified that it has inadvertently collected personal data from an individual under the age of 21, it will immediately suspend the associated account, initiate a review, return any deposited funds to the originating payment method, and permanently delete all personal data collected from that individual upon completion of any mandatory regulatory reporting obligations.
Parents or guardians who believe a minor has created a 639ph account should contact our support team immediately at [email protected]. We will investigate and take appropriate action within 24 hours of notification.
639ph primarily processes and stores personal data within the Philippines. In limited circumstances — specifically in connection with internationally headquartered game providers whose infrastructure is located outside the Philippines — certain session and gameplay data may be processed on servers located in other jurisdictions.
Where personal data is transferred outside the Philippines, 639ph ensures that such transfers comply with the requirements of the Data Privacy Act and implementing rules. This includes verifying that the receiving jurisdiction provides an adequate level of protection for personal data, or implementing contractual safeguards (standard data protection clauses) with the receiving party that bind them to processing standards equivalent to those required under Philippine law.
Identity documents, KYC data, and financial transaction records are not transferred outside the Philippines without explicit legal authority or your specific consent, except where required by law enforcement or regulatory mandate.
639ph reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or changes in PAGCOR regulatory requirements. Where changes are material — meaning they significantly affect your rights or how your data is processed — 639ph will provide at least fourteen (14) days' advance notice to registered Players via the email address associated with your account.
The effective date at the top of this page will be updated whenever the policy is revised. The current version of this Privacy Policy is always accessible at 639ph.club/privacy-policy. We encourage you to review this policy periodically, particularly if you receive a notification of changes. Continued use of the 639ph Platform following the effective date of any revision constitutes acceptance of the revised policy.
Archived previous versions of this Privacy Policy are available upon request by contacting our Data Protection Officer.
For any questions about this Privacy Policy, how 639ph handles your personal data, or to exercise your data subject rights, please contact:
If your concern is not satisfactorily resolved by our DPO, you have the right to raise a complaint with the National Privacy Commission of the Philippines, the independent government body responsible for enforcing the Data Privacy Act.
Your data is protected under Philippine law. Your funds are secured under PAGCOR licensing. Your cashout lands in GCash in 1–2 hours. Join 639ph today.
21+ only. PAGCOR-licensed. Gamble responsibly.