639 Club Privacy Policy

1. Introduction

1.1  639 Club respects the privacy of every player who accesses our platform. This Policy explains in clear terms what personal data we collect from you, why we collect it, how we use and protect it, how long we keep it, and what rights you have over your own data.

1.2  639 Club is the data controller for personal information collected through the 639 Club platform. As data controller, 639 Club is responsible for determining the purposes and means of processing your personal data and for implementing appropriate technical and organizational measures to ensure its security.

1.3  This Policy applies to all personal data processed by 639 Club in connection with your registration, account management, deposits, withdrawals, gameplay, customer support interactions, and promotional communications relating to the 639 Club service.

2. Personal Data We Collect

639 Club collects the following categories of personal data:

2.1 Identity Data

• Full legal name as it appears on government-issued ID;
• Date of birth (for age verification — must be 21 or older);
• Gender (optional);
• Copies of government-issued identification documents (UMID, PhilSys ID, passport, driver's license) submitted during KYC verification.

2.2 Contact Data

• Philippine mobile number used as account identifier;
• Email address (where provided);
• Residential address (for KYC purposes, where required).

2.3 Financial Data

• GCash mobile number, Maya account details, or bank account information (used for transaction processing only — 639 Club does not store full payment credentials);
• Transaction history: deposits, withdrawals, bets placed, and winnings received;
• Account balance history.

2.4 Technical & Usage Data

• IP address and approximate geolocation at the time of login;
• Device type, operating system, and browser information;
• Session logs: login timestamps, pages visited, games played, time spent;
• Clickstream data and platform interaction patterns.

2.5 Communications Data

• Records of communications between you and 639 Club customer support (live chat transcripts, support tickets);
• Feedback and survey responses submitted through the platform.

3. How We Collect Your Data

639 Club collects personal data through the following methods:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, or contacting customer support;
• Automated Collection: Technical data collected automatically when you access the 639 Club platform, including through cookies, log files, and device fingerprinting technologies;
• Third-Party Sources: Identity and fraud-check data obtained from KYC verification partners and payment processors in connection with account verification and transaction processing.

4. How We Use Your Personal Data

639 Club uses your personal data for the following purposes:

• To create, manage, and maintain your 639 Club player account;
• To verify your identity and confirm your eligibility to use the platform (including age verification of 21+);
• To process deposit and withdrawal transactions through GCash, Maya, bank transfer, and other supported payment channels;
• To provide and improve the gaming services, game lobby, and platform features available on 639 Club;
• To detect, investigate, and prevent fraud, money laundering, collusion, and other prohibited conduct;
• To send service-related communications, including account notifications, security alerts, and platform update notices;
• To send promotional communications where you have not opted out, including bonus offers, new game announcements, and special promotions;
• To fulfill 639 Club's legal and regulatory obligations under Philippine gaming and data privacy laws;
• To respond to customer support inquiries and resolve disputes;
• To analyze usage patterns for platform optimization and responsible gaming monitoring.

5. Legal Basis for Processing

639 Club processes your personal data on the following legal grounds as recognized under Republic Act No. 10173:

• Contractual Necessity: Processing required to perform the 639 Club service contract, including account management, transaction processing, and KYC verification;
• Legal Obligation: Processing required to comply with Philippine gaming regulations, anti-money laundering requirements, and tax obligations;
• Legitimate Interests: Processing carried out to prevent fraud, ensure platform security, and improve service quality, where such interests are not overridden by your privacy rights;
• Consent: Processing for promotional communications and optional data uses, where you have provided explicit consent. You may withdraw consent at any time by contacting 639 Club support.

6. Data Sharing & Disclosure

6.1  639 Club does not sell, rent, or trade your personal data to third-party marketing organizations under any circumstances.

6.2  639 Club may share your personal data with the following categories of recipients strictly for the purposes described in this Policy:

• Payment Processors: GCash, Maya, InstaPay partner banks (BPI, BDO, Metrobank), and other payment service providers for transaction processing;
• Identity Verification Partners: Third-party KYC service providers for document verification and age confirmation;
• Game Content Providers: Licensed third-party game studios may receive anonymized session data for game performance analytics;
• Regulatory Authorities: Philippine gaming regulators, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and law enforcement agencies where disclosure is required by law or court order;
• Professional Advisors: Legal, audit, and financial advisors engaged by 639 Club, subject to confidentiality obligations.

6.3  All third parties with whom 639 Club shares personal data are required to maintain appropriate data security measures and may only use the data for the specific purpose for which it was shared.

7. Data Retention

7.1  639 Club retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law. Under Philippine anti-money laundering regulations, transaction records must be retained for a minimum of five (5) years from the date of the transaction.

7.2  Account data and KYC documents will be retained for a minimum of five (5) years following account closure, and for longer periods where required by a court order, regulatory investigation, or other legal obligation.

7.3  After the applicable retention period expires, 639 Club will securely delete or anonymize your personal data so that it can no longer be attributed to you as an individual.

8. Data Security

8.1  639 Club implements the following technical and organizational security measures to protect your personal data:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 639 Club servers;
• AES-256 encryption for sensitive personal and financial data stored in our databases;
• Multi-factor authentication requirements for 639 Club staff accessing production systems;
• Regular third-party security audits and penetration testing;
• Strict internal access controls limiting data access to authorized personnel with a legitimate business need.

8.2  In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 639 Club will notify the National Privacy Commission within 72 hours of discovery and will notify affected players without undue delay, as required under the Data Privacy Act of 2012.

9. Cookies & Tracking Technologies

9.1  639 Club uses cookies and similar tracking technologies to maintain your logged-in session, remember your platform preferences, and analyze how players use the platform for the purpose of improving the service.

9.2  The following categories of cookies are used by 639 Club:

• Essential Cookies: Required for the platform to function, including session authentication and security tokens. These cannot be disabled.
• Analytics Cookies: Used to collect aggregated, anonymized data on how players navigate the platform, enabling 639 Club to identify and improve problematic user experience areas.
• Preference Cookies: Store your language, display, and game lobby preferences to provide a consistent experience across sessions.

9.3  You may control non-essential cookies through your browser settings. Disabling essential cookies may impair the functionality of the 639 Club platform, including the ability to log in.

10. Your Data Privacy Rights

Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by 639 Club:

To exercise any of the above rights, please contact the 639 Club Data Protection Officer by email at [email protected]. 639 Club will respond to verified requests within thirty (30) days.

11. Children's Privacy

11.1  639 Club's gaming services are strictly intended for individuals aged twenty-one (21) years and above. The platform does not knowingly collect personal data from individuals under the age of 21.

11.2  If 639 Club discovers that personal data has been collected from an individual who is under 21 years of age, the account will be closed immediately, all data associated with the underage individual will be deleted as soon as permissible under applicable law, and any real-money balance will be returned to the payment method used for deposit.

11.3  If you believe that a person under 21 has registered an account with 639 Club, please contact our support team immediately at [email protected].

12. International Data Transfers

12.1  639 Club's primary data processing infrastructure is located in jurisdictions with adequate data protection standards. Where personal data is transferred outside the Philippines, 639 Club ensures that appropriate safeguards are in place, including data processing agreements that incorporate the standard contractual clauses recognized by the National Privacy Commission.

12.2  Personal data relating to Philippine players will not be transferred to jurisdictions that do not offer an adequate level of data protection without your express consent, except where required by Philippine law or court order.

13. Third-Party Links

The 639 Club platform may contain links to game provider pages, payment processor portals, and other third-party services. This Privacy Policy applies solely to data collected by 639 Club. 639 Club is not responsible for the privacy practices of any third-party website or service. We encourage you to review the privacy policies of any third-party service you access through the 639 Club platform.

14. Updates to This Privacy Policy

14.1  639 Club may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or the features of the 639 Club platform. The date of the most recent revision is always displayed at the top of this page.

14.2  Where changes are material, 639 Club will provide registered players with advance notice through in-app notification or by SMS to the registered mobile number. Continued use of the 639 Club platform after the effective date of any revised Policy constitutes acceptance of those changes.

15. Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or 639 Club's handling of your personal data, please contact our Data Protection Officer:

Please note: the email address above is displayed as plain text for reference. To contact us, please use the in-app live chat or type the address into your email client manually.