639jl Casino Privacy Policy

639jl Casino ("639jl," "we," "us," or "our") collects personal information from you in the course of providing our online gaming services. The categories of personal data we collect include:

1.1 Information You Provide Directly

• Registration data: Full legal name, date of birth, gender, nationality, Philippine mobile number, email address, and residential address.
• Identity verification (KYC) documents: Government-issued photo ID (e.g., PhilSys ID, passport, driver's license, UMID, SSS ID, voter's ID), proof of address, and selfie photographs where required.
• Financial information: GCash account details, Maya account details, bank account numbers (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), and debit card details used for deposits and withdrawals. We do not store full card numbers — only masked references.
• Communications: Messages, complaints, and feedback you send to our customer support team via live chat or email.

1.2 Information Collected Automatically

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage data: Pages visited, games played, session duration, betting history, deposit and withdrawal history, bonus usage, and click-stream data.
• Location data: General geographic location derived from your IP address, used to verify that you are accessing the Platform from a permitted jurisdiction.
• Cookies and tracking technologies: As described in Section 7 of this Privacy Policy.

1.3 Information from Third Parties

We may receive information about you from third-party identity verification providers, payment processors, fraud prevention services, and PAGCOR or other regulatory bodies where required by law.

639jl uses the personal data we collect for the following purposes:

• Account management: To create, verify, maintain, and secure your 639jl account, including processing your 639jl login and authenticating your identity.
• Service delivery: To provide access to our games, process deposits and withdrawals, credit bonuses, and deliver customer support.
• Legal and regulatory compliance: To fulfill our obligations under the Philippine Data Privacy Act, Anti-Money Laundering Act (AMLA), PAGCOR regulations, and other applicable laws, including KYC verification, transaction monitoring, and suspicious activity reporting.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the Platform.
• Responsible gaming: To monitor gaming patterns and identify players who may be at risk of problem gambling, and to enforce self-exclusion and deposit limit requests.
• Platform improvement: To analyze usage patterns, conduct A/B testing, and improve the functionality, performance, and user experience of the 639jl Platform.
• Marketing communications: To send you promotional offers, bonus notifications, and updates about 639jl — but only where you have given your consent or where we have a legitimate interest to do so. You may opt out of marketing communications at any time.
• Legal claims: To establish, exercise, or defend legal claims in connection with the Platform or your account.

Under the Philippine Data Privacy Act of 2012 (RA 10173), 639jl 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 639jl gaming services you have registered for, including processing your 639jl login, managing your account, and handling transactions.
• Legal obligation: Processing is required to comply with our legal obligations under Philippine law, including AMLA, PAGCOR regulations, and tax laws.
• 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 freedoms.
• Consent: For marketing communications and non-essential cookies, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

639jl does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

• Service providers and processors: Third-party companies that provide services on our behalf, including payment processors (GCash, Maya, banks), identity verification providers, cloud hosting providers, customer support platforms, and analytics services. These providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection laws.
• Game providers: Third-party game studios whose games are available on the 639jl Platform may receive limited technical data (such as player session tokens) necessary to deliver their games. They do not receive your full personal profile.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where disclosure is required by law, court order, or regulatory directive.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of 639jl's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.
• Professional advisers: Lawyers, auditors, and insurers where necessary for the conduct of our business, subject to confidentiality obligations.

All third parties with whom we share personal data are required to implement appropriate technical and organizational security measures to protect your data.

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

Specifically:

• Active account data: Retained for the duration of your account's existence on the 639jl Platform.
• Transaction and gaming records: Retained for a minimum of five (5) years following the date of the transaction, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure or the last transaction, whichever is later.
• Customer support communications: Retained for three (3) years from the date of the communication.
• Marketing consent records: Retained until you withdraw consent, plus an additional period as required to demonstrate compliance.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with our data disposal procedures. Where data cannot be immediately deleted due to technical constraints, it will be isolated and protected from further processing until deletion is possible.

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 639jl:

• Right to be informed: The right to be informed whether personal data pertaining to you is being, or has been, processed by 639jl.
• Right of access: The right to access your personal data held by 639jl, including the purposes for which it is being processed and the recipients to whom it has been disclosed.
• Right to rectification: The right to correct inaccurate or incomplete personal data. You may update most of your account information directly through your 639jl account settings.
• Right to erasure or blocking: The right to request the deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: The right to object to the processing of your personal data, including for direct marketing purposes.
• Right to data portability: The right to receive a copy of 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 National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within fifteen (15) business days. We may need to verify your identity before processing your request.

639jl uses cookies and similar tracking technologies (such as web beacons and local storage) to operate and improve the Platform. Cookies are small text files stored on your device when you visit the 639jl website.

We use the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that maintain your 639jl login state, security tokens, and load-balancing cookies. These cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences (such as language settings and display preferences) to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how players use the Platform (pages visited, session duration, error reports) to help us improve performance. We use privacy-respecting analytics tools that do not share data with advertising networks.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

639jl does not use third-party advertising or retargeting cookies. You can manage or delete cookies through your browser settings. Note that disabling strictly necessary cookies may prevent you from accessing certain features of the Platform, including the 639jl login page.

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

• TLS encryption for all data transmitted between your device and the 639jl Platform
• AES-256 encryption for sensitive data stored at rest
• Multi-factor authentication options for player accounts
• Regular penetration testing and vulnerability assessments conducted by independent security firms
• Strict access controls limiting employee access to personal data on a need-to-know basis
• Comprehensive staff training on data privacy and security obligations
• Incident response procedures in place to detect, report, and respond to personal data breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 639jl will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with the requirements of the Philippine Data Privacy Act.

Updates to This Privacy Policy

639jl reserves the right to update or modify this Privacy Policy at any time. When we make material changes, we will notify you by posting a prominent notice on the Platform and, where appropriate, by sending a notification to your registered email address. The date of the most recent revision is always indicated at the top of this page. Your continued use of the 639jl Platform following the posting of changes constitutes your acceptance of the revised Privacy Policy.

Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 639jl handles your personal data, please contact our Data Protection Officer: