639 Club Privacy Policy

This Privacy Policy ("Policy") applies to 639 Club and governs the collection, use, storage, disclosure, and protection of personal information provided by or collected from users ("you," "your") who access or use the 639 Club platform at 639club.vu, including all associated services, features, and content.

639 Club recognises the importance of data privacy and is committed to treating your personal information with the care and respect it deserves. This Policy is intended to be transparent, plain-language, and genuinely informative — not a bureaucratic exercise. We want every Filipino player who chooses 639 Club to understand exactly what happens with their data.

By registering an account, making a deposit, or otherwise using the 639 Club platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. If you do not agree to this Policy, you must not use the 639 Club platform.

639 Club collects only the personal data that is necessary to provide our services, comply with our regulatory obligations, and protect the integrity of the platform. The categories of personal data we collect include:

Identity and Contact Data

• Full legal name as it appears on your Philippine government-issued identification document.
• Date of birth (used to verify that you meet the 21+ age requirement).
• Philippine mobile number (used for account verification, OTP authentication, and support communications).
• Email address (used for account notifications and correspondence).
• Residential address (collected as part of Know Your Customer verification).

Identity Verification Data

• Copies of government-issued Philippine identification documents (e.g., PhilSys ID, passport, driver's licence, UMID, SSS ID, PRC ID) submitted during KYC verification.
• Selfie or photo verification where required by our compliance process.

Financial and Transaction Data

• GCash account number, PayMaya account details, and bank account information associated with your registered 639 Club payment methods.
• Records of all deposits, withdrawals, bonus transactions, and gaming wagers made through your 639 Club account.

Technical and Usage Data

• IP address, device type, operating system, and browser information collected automatically when you access the 639 Club platform.
• Session logs, login timestamps, game activity records, and platform navigation data.
• Cookie and tracking data as described in Section 9 of this Policy.

639 Club collects personal data through the following means:

• Directly from you: When you register a 639 Club account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion.
• Automatically: Through cookies, server logs, and similar tracking technologies when you access the 639 Club platform via any device or browser.
• From third parties: Identity verification data may be cross-referenced with government databases or third-party KYC service providers strictly for compliance purposes. Payment data is processed through regulated payment intermediaries including GCash and PayMaya.

639 Club does not purchase personal data from data brokers or other commercial data sources.

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

• Account management: To create, maintain, and administer your 639 Club account, including processing deposits, withdrawals, and bonus transactions.
• Identity and age verification: To comply with Philippine regulatory requirements, including the 21+ age restriction mandated by PAGCOR for online gaming.
• Platform security: To detect, investigate, and prevent fraud, money laundering, unauthorised account access, and other prohibited conduct.
• Regulatory compliance: To fulfil 639 Club's obligations under Philippine law, including Anti-Money Laundering Act (AMLA) reporting requirements and PAGCOR compliance obligations.
• Customer support: To respond to your enquiries, resolve disputes, and provide assistance related to your 639 Club account.
• Service improvement: To analyse usage patterns on the 639 Club platform for the purpose of improving game offerings, platform performance, and user experience.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where this is permitted under applicable law. You may opt out of marketing communications at any time through your account settings.
• Responsible gaming: To identify patterns that may indicate problem gambling behaviour and to administer responsible gaming tools such as deposit limits and self-exclusion requests.

639 Club processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012 (RA 10173):

• Contractual necessity: Processing required to perform the contract between you and 639 Club, including account management and transaction processing.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, AMLA obligations, and tax reporting.
• Legitimate interests: Processing for fraud prevention, platform security, and improvement of 639 Club services, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and the use of non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

639 Club does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients, strictly as necessary:

• Payment processors: GCash (GXI), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, and 7-Eleven Cliqq — solely to process your authorised transactions.
• KYC and identity verification providers: Third-party services engaged to assist with identity verification and document authentication as required by PAGCOR compliance obligations.
• Regulatory and law enforcement authorities: 639 Club may be required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other Philippine government authorities pursuant to a lawful order, subpoena, or regulatory requirement.
• Technology and infrastructure providers: Cloud hosting, security, and platform service providers engaged by 639 Club under strict data processing agreements that prohibit independent use of your data.

Any third party that processes personal data on behalf of 639 Club is contractually bound to handle such data in accordance with this Policy and applicable Philippine data protection law.

639 Club implements appropriate technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 639 Club servers.
• Encryption at rest for sensitive data including identity documents and financial information.
• SMS OTP two-factor authentication for account access and sensitive account actions.
• Automated fraud and anomaly detection systems that monitor for suspicious login activity and unusual transaction patterns.
• Strict access controls limiting employee access to personal data on a need-to-know basis.
• Regular security assessments and vulnerability testing of the 639 Club platform.

While 639 Club takes all reasonable steps to protect your data, no online platform can guarantee absolute security. In the event of a personal data breach that is likely to result in risk to your rights, 639 Club will notify you and the National Privacy Commission as required by RA 10173 and its implementing rules.

639 Club retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. The following general retention periods apply:

• Account and transaction records: Retained for a minimum of five (5) years from the date of account closure, as required for AMLC compliance and financial audit purposes.
• KYC and identity verification documents: Retained for the duration of your 639 Club account and for five (5) years following account closure.
• Customer support correspondence: Retained for three (3) years from the date of the relevant interaction.
• Marketing preferences and consent records: Retained until you withdraw consent or close your 639 Club account, plus an additional twelve (12) months for audit purposes.

Where personal data is no longer required, 639 Club securely disposes of or anonymises it in a manner that prevents unauthorised reconstruction.

639 Club uses cookies and similar tracking technologies on its platform for the following purposes:

• Essential cookies: Required for the platform to function, including maintaining your logged-in session, remembering language preferences, and enabling secure transactions. These cannot be disabled without affecting platform functionality.
• Performance cookies: Used to collect anonymised data about how users interact with the 639 Club platform — including page load times and navigation paths — to improve performance and user experience.
• Functionality cookies: Used to remember your preferences, such as your preferred game lobby view or last-used payment method, to personalise your 639 Club experience.
• Analytics cookies: Used to understand aggregate user behaviour on the 639 Club platform for the purpose of product development and feature prioritisation.

Non-essential cookies are only set with your consent, which you can manage through your browser settings or the cookie preference centre on the 639 Club platform. Disabling certain cookies may affect the functionality of specific platform features.

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by 639 Club:

• Right to be informed: The right to be told how your personal data is being collected and processed — which this Policy fulfils.
• Right of access: The right to request a copy of the personal data 639 Club holds about you.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected or updated in your 639 Club account.
• Right to erasure: The right to request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to object: The right to object to certain types of processing, including direct marketing communications.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.

To exercise any of the above rights, please contact the 639 Club support team. We will respond to valid requests within thirty (30) days. In certain circumstances, 639 Club may be required to retain data notwithstanding an erasure request, where retention is mandated by Philippine law.

The 639 Club platform is strictly intended for adults. In the Philippines, participation in real-money online gaming is restricted to individuals who are 21 years of age or older, as mandated by PAGCOR. 639 Club does not knowingly collect personal data from individuals under the age of 21.

If 639 Club discovers or is notified that personal data has been collected from an individual under 21, we will immediately close the relevant account, return any deposited funds to the originating payment method (minus any bonuses), and securely delete all associated personal data.

If you believe that a minor has created a 639 Club account, please contact our support team immediately.

639 Club reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, platform features, or applicable law. Where changes are material, 639 Club will provide reasonable notice via the platform or by notification to your registered contact details. The "Last Updated" date at the top of this Policy will always reflect the most recent revision.

Your continued use of the 639 Club platform following any update to this Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically.

If you have questions, concerns, or requests relating to this Privacy Policy or 639 Club's data processing practices, please contact our customer support team. Under RA 10173, 639 Club has designated a Data Privacy Officer responsible for ensuring compliance with this Policy and applicable Philippine data protection law.

Email: [email protected]

Our customer support team is available daily from 8:00 AM to 12:00 MN (Philippine Standard Time). We will acknowledge your request within seventy-two (72) hours and provide a substantive response within thirty (30) days.

If you believe your data privacy rights have been violated, you also have the right to lodge a complaint with the National Privacy Commission of the Philippines.