639jls Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") describes how 639jls ("the Company", "we", "us", or "our") collects, uses, stores, and protects the personal data of individuals ("you", "your", or "Player") who access or use the 639jls online gaming platform available at 639jls.net (the "Platform").

This Policy applies to all personal data processed in connection with your use of the Platform, including data collected during account registration, identity verification, gameplay, financial transactions, customer support interactions, and marketing communications.

By registering an account on 639jls or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform and contact us to close your account.

This Policy should be read together with our Terms & Conditions, which govern your use of the Platform.

2 Data Controller Information

639jls acts as the data controller in respect of personal data collected through the Platform. As data controller, 639jls determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.

639jls has designated a Data Protection Officer (DPO) responsible for overseeing compliance with data privacy obligations. You may contact the DPO for any privacy-related enquiries at the contact details provided in Section 14 of this Policy.

3 Data We Collect

639jls collects the following categories of personal data:

• Full legal name as it appears on your government-issued ID
• Date of birth and age verification information
• Mobile number and email address
• Residential address (province, city, barangay)
• Government-issued ID details (e.g., PhilSys ID number, passport number, driver's licence number)

• Username and encrypted password
• Account preferences and settings
• Responsible gaming limits and self-exclusion status
• Communication preferences and marketing consent records

• GCash or PayMaya account reference (masked)
• Bank account details for BPI, BDO, or Metrobank transfers (masked)
• Transaction history including deposits, withdrawals, and bonus credits
• Wallet balance and pending transaction records

• Game session history, bet amounts, and game outcomes
• Platform navigation and feature usage patterns
• Session duration and login timestamps
• Device type, operating system, and browser information

• IP address and approximate geolocation
• Cookie identifiers and session tokens
• Error logs and platform performance data

• Records of live chat, email, and support ticket interactions
• Feedback and survey responses
• Promotional communication engagement data (open rates, click-throughs)

4 How We Collect Data

639jls collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Data collected automatically when you use the Platform, including through cookies, session tracking, and server logs. See Section 8 for details on our cookie practices.
• Third-party sources: Data received from payment processors (GCash, PayMaya, BPI, BDO, Metrobank) in connection with financial transactions, and from identity verification service providers used for KYC compliance.
• Regulatory sources: Data received from PAGCOR or other Philippine regulatory authorities in connection with licensing compliance or investigations.

5 Legal Basis for Processing

639jls processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, anti-money laundering (AML) obligations, and tax reporting requirements.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving the Platform's features and performance.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 How We Use Your Data

639jls uses your personal data for the following purposes:

• Creating and managing your player account on the Platform
• Verifying your identity and age in compliance with PAGCOR regulations and AML requirements
• Processing deposits, withdrawals, and bonus credits
• Providing customer support and resolving disputes
• Detecting and preventing fraud, money laundering, and other prohibited conduct
• Monitoring gameplay activity for responsible gaming purposes and enforcing player-set limits
• Personalising your Platform experience and recommending relevant games
• Sending transactional communications (account confirmations, withdrawal notifications, security alerts)
• Sending promotional communications where you have opted in to receive them
• Complying with PAGCOR licensing conditions and other applicable Philippine regulatory requirements
• Analysing Platform usage to improve features, performance, and user experience
• Enforcing our Terms & Conditions and other Platform policies

639jls will not use your personal data for any purpose incompatible with those listed above without first obtaining your consent or establishing a separate legal basis for the new processing activity.

7 Data Sharing & Disclosure

639jls does not sell your personal data. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

We share financial data with payment service providers (GCash, PayMaya, BPI, BDO, Metrobank) solely to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable Philippine financial regulations.

We may share identity documents and personal details with third-party KYC verification service providers to fulfil our regulatory obligations. These providers process data only on our instructions and under strict confidentiality agreements.

639jls 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 where required by law, court order, or regulatory directive.

We engage third-party technology providers for cloud hosting, platform infrastructure, analytics, and customer support tooling. These providers act as data processors on our behalf and are contractually prohibited from using your data for their own purposes.

In the event of a merger, acquisition, or sale of all or part of 639jls's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Policy that result from it.

In all cases of data sharing, 639jls implements appropriate contractual safeguards to ensure that your personal data is handled with the same level of protection as described in this Policy.

8 Cookies & Tracking Technologies

639jls uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function, including session authentication, security tokens, and load balancing. These cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences such as language settings, responsible gaming limits, and display preferences to personalise your experience.
• Analytics cookies: Collect aggregated, anonymised data about how players use the Platform to help us identify areas for improvement. We use this data internally and do not share it with advertising networks.
• Marketing cookies: Used only where you have provided explicit consent to receive personalised promotional content. You may withdraw this consent at any time via your account settings.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies may prevent you from accessing certain features of the Platform, including your account login.

9 Data Retention

639jls retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following retention guidelines:

• Active account data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AML obligations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC verification documents: Retained for the period required by applicable PAGCOR and AMLC regulations, typically five (5) years from the end of the business relationship.
• Support and communications records: Retained for three (3) years from the date of the interaction, or longer if the matter is subject to ongoing dispute or legal proceedings.
• Marketing consent records: Retained for the duration of your consent plus three (3) years to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data disposal procedures. Where anonymisation is not technically feasible, data is securely destroyed.

10 Data Security

639jls implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• Encryption: All personal data is encrypted at rest using AES-256 encryption. All data in transit is protected by TLS 1.2 or higher.
• Access controls: Access to personal data is restricted to authorised personnel on a strict need-to-know basis. All staff with access to personal data undergo data privacy training.
• Network security: The Platform is protected by firewalls, intrusion detection systems, and regular vulnerability assessments.
• Incident response: 639jls maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the NPC and affected players within the timeframes required by Philippine law.
• Third-party audits: Our security practices are subject to periodic third-party security audits and penetration testing.

While 639jls takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately of any suspected unauthorised access to your account.

11 Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 639jls:

• Right to be informed: The right to be informed of how your personal data is collected, used, and processed — which this Policy fulfils.
• Right of access: The right to request a copy of the personal data we hold about you and information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your account settings.
• Right to erasure: The right to request deletion 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 for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact details in Section 14. We will respond to all verified data subject requests within thirty (30) days. In complex cases, we may extend this period by a further thirty (30) days with prior notice.

Please note that certain rights are subject to limitations where processing is required for legal compliance, fraud prevention, or the establishment, exercise, or defence of legal claims.

12 Children & Minors

The 639jls Platform is strictly intended for individuals aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. 639jls does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. Any winnings or balances associated with an underage account will be forfeited.

If you believe that a minor has registered on the Platform, please contact our support team immediately so that we can investigate and take appropriate action.

13 Changes to This Privacy Policy

639jls reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via the email address associated with their account and/or by displaying a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Policy periodically to stay informed about how 639jls protects your personal data. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy.

14 Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 639jls, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 via the chat widget on the Platform
• Response Time: We aim to respond to all privacy-related enquiries within five (5) business days

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.

For responsible gaming concerns, please visit our Responsible Gaming page.