Privacy Policy

01 Introduction

639jl12 ("the Platform", "we", "us", "our") is a Philippines-focused online casino and sports betting service. We are committed to safeguarding the personal information of every player who registers, logs in, deposits, plays, or interacts with the 639jl12 Platform in any way.

This Privacy Policy has been prepared in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as well as the relevant guidelines issued by the National Privacy Commission (NPC) of the Philippines. Where applicable, we also observe the data governance requirements of the Philippine Amusement and Gaming Corporation (PAGCOR).

By accessing or using 639jl12 — including by completing the 639jl12 Login — you acknowledge that you have read, understood, and agreed to the data practices described in this Privacy Policy. This document should be read together with our Terms & Conditions and our Responsible Gaming Policy.

02 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for your personal information is 639jl12, operating the online gaming platform at 639jl12.net. All data collected through the Platform is processed under the authority and responsibility of 639jl12's designated Data Protection Officer (DPO).

If you have any questions, concerns, or requests regarding your personal data, you may contact our DPO directly at the email address provided in Section 15 of this Policy. We are committed to responding to all privacy-related inquiries within the timeframes required under Republic Act 10173.

03 Data We Collect

639jl12 collects personal data that is necessary, adequate, and relevant to the purposes described in this Policy. The categories of data we collect include:

3.1 Identity Data

• Full legal name as it appears on your government-issued ID
• Date of birth (used to verify you are aged 21 or above)
• Gender (optional, collected during KYC where relevant)
• Copies of valid Philippine government-issued identification documents (e.g., PhilSys national ID, passport, driver's license, SSS/GSIS card, PRC ID, voter's ID)
• Selfie or liveness-check photograph submitted during identity verification

3.2 Contact Data

• Philippine mobile number (used for OTP authentication and account communications)
• Email address registered to your 639jl12 account
• Residential address within the Philippines

3.3 Financial Data

• GCash or Maya mobile wallet details (account name and number)
• Bank account details where applicable (BPI, BDO, UnionBank, Metrobank)
• USDT TRC20 wallet address where used for cryptocurrency transactions
• Deposit and withdrawal transaction history, amounts, and timestamps
• Account balance and wagering history

3.4 Technical & Usage Data

• IP address and geolocation data (country, region) at the time of 639jl12 Login and gameplay
• Device type, operating system, browser type and version
• Session duration, pages visited, game titles played, and bet history
• Login timestamps and account activity logs

3.5 Communications Data

• Records of live chat, email, or support ticket exchanges with the 639jl12 customer support team
• Survey responses and feedback submissions
• Promotional opt-in preferences and marketing communication history

04 How We Collect Data

639jl12 collects your personal data through the following channels:

• Directly from you — during account registration, the 639jl12 Login process, KYC document submission, deposit and withdrawal requests, and customer support interactions.
• Automatically — through cookies, web beacons, server logs, and analytics tools when you browse or interact with the 639jl12 Platform.
• From third-party verification providers — identity verification services and payment processors (e.g., GCash, Maya, BPI) may share data with us as part of the transaction or KYC process.
• From PAGCOR and regulatory authorities — in circumstances where regulatory data sharing is required or mandated by law.

05 Purposes of Processing

We use the personal data we collect for the following specific and legitimate purposes:

639jl12 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your separate, explicit consent.

06 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 639jl12 processes your personal data on the following lawful bases:

• Contractual necessity — Processing is required to perform the contract we have with you (i.e., providing the 639jl12 gaming platform services) or to take steps at your request before entering into such a contract.
• Legal obligation — Processing is necessary to comply with our legal and regulatory obligations under Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
• Legitimate interests — Processing is necessary for purposes of fraud prevention, network and information security, and responsible gaming monitoring, where those interests are not overridden by your privacy rights.
• Consent — Where processing is based on consent (e.g., marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

07 Data Sharing & Third Parties

639jl12 does not sell, rent, or trade your personal data. We may share your data only in the following strictly limited circumstances:

• Payment processors — GCash, Maya, BPI, BDO, UnionBank, Coins.ph, and other payment service providers receive the minimum financial data necessary to process your transactions.
• Identity verification services — Third-party KYC providers process your identity documents solely for the purpose of verifying your age and identity in compliance with PAGCOR requirements.
• Game software providers — Providers such as Ezugi and Relax Gaming receive anonymized or pseudonymized session data necessary to deliver their game services within the 639jl12 Platform.
• PAGCOR and Philippine government authorities — We are legally obligated to provide player data to PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent authorities when required by law or court order.
• Professional advisors — Lawyers, auditors, and accountants engaged by 639jl12 under strict confidentiality obligations where necessary for legal, compliance, or financial audit purposes.

08 Data Retention

639jl12 retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our standard retention periods are:

• Account data and KYC documents: Retained for the duration of your active account relationship with 639jl12, plus a minimum of five (5) years following account closure, as required under Philippine AML regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in line with PAGCOR and AMLC record-keeping requirements.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless a longer retention period is required for legal proceedings.
• Technical and usage logs: Retained for up to twelve (12) months for security and fraud detection purposes, after which they are anonymized or deleted.
• Marketing preferences and consent records: Retained for the duration of your account and for one (1) year following withdrawal of consent, to demonstrate compliance.

At the end of each applicable retention period, personal data is securely deleted or permanently anonymized so that it can no longer be linked to you as an individual.

09 Data Security

639jl12 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• SSL/TLS encryption on all data transmissions between your device and 639jl12 servers, ensuring that your 639jl12 Login credentials and financial data cannot be intercepted in transit.
• Encryption at rest for all sensitive personal and financial data stored on our servers.
• Role-based access controls ensuring that only authorized 639jl12 personnel with a legitimate need can access your personal data.
• Two-factor authentication (2FA) available for all player accounts to protect against unauthorized 639jl12 Login attempts.
• Regular penetration testing and security audits conducted by independent cybersecurity professionals.
• Incident response procedures designed to detect, contain, and notify affected players and the National Privacy Commission (NPC) of any personal data breach within the timeframe required by law.

10 Cookies & Tracking Technologies

639jl12 uses cookies and similar tracking technologies on the Platform to enhance your experience, maintain session continuity across your 639jl12 Login, and support security functions. The types of cookies we use include:

• Strictly necessary cookies — Required for the Platform to function. These include session cookies that keep you logged in during a gaming session and security tokens that protect against cross-site request forgery (CSRF). These cannot be disabled.
• Functional cookies — Remember your preferences (e.g., language, game settings) to personalize your experience across sessions.
• Analytics cookies — Used internally to understand how players navigate the 639jl12 Platform, which games are most popular, and where technical issues arise. Data collected is aggregated and does not identify you personally.
• Security cookies — Used to detect and prevent fraudulent activity and unauthorized account access.

639jl12 does not use third-party advertising or tracking cookies that share your data with external advertisers. You may manage non-essential cookie preferences through your browser settings; however, disabling strictly necessary cookies may impair Platform functionality including your ability to complete the 639jl12 Login process.

11 Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 639jl12. To exercise any of these rights, contact our DPO at the details in Section 15.

We will respond to all valid privacy rights requests within fifteen (15) business days of receipt, in accordance with the timelines prescribed by the National Privacy Commission. In complex cases, we may extend this period by a further fifteen (15) business days with prior notification.

If you believe your privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission of the Philippines through its official channels.

12 Minors & Age Policy

639jl12 is strictly an adult platform. Under Philippine law, participation in casino-style online gambling is limited to individuals who are at least 21 years of age. We do not knowingly collect, store, or process personal data belonging to anyone under the age of 21.

All accounts undergo mandatory age verification as part of the KYC process before deposits or gameplay are permitted. Where 639jl12 discovers or has reasonable grounds to believe that a player is under the age of 21, the account will be immediately suspended, all personal data will be securely deleted, and any deposited funds will be returned to the originating payment method without delay.

13 International Data Transfers

639jl12 operates primarily within the Philippines and stores the majority of player data on servers located in or near Philippine jurisdiction. In limited circumstances, personal data may be processed or accessed by service providers located outside the Philippines — for example, certain game software providers or cloud infrastructure partners.

Where international data transfers occur, 639jl12 ensures that adequate safeguards are in place to protect your personal data, including:

• Data processing agreements with all third-party recipients that impose obligations equivalent to those under the Philippine Data Privacy Act of 2012.
• Transfer to countries or organizations recognized by the National Privacy Commission as providing adequate data protection standards.
• Contractual clauses approved by the NPC where no adequacy recognition is in place.

At no point will your personal data be transferred to a jurisdiction that does not provide at minimum an equivalent level of protection to that afforded under Philippine law.

14 Policy Amendments

639jl12 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. When material changes are made, we will notify you via:

• A prominent notice on the 639jl12 Platform upon your next login.
• A notification sent to the email address or mobile number registered to your account.
• An updated "Last Reviewed" date at the top of this page.

Your continued use of the 639jl12 Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with the changes, you should stop using the Platform and contact support to close your account.

15 Contact & Data Protection Officer

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or need to report a privacy concern, please contact our Data Protection Officer directly. Our DPO is responsible for overseeing 639jl12's compliance with the Data Privacy Act of 2012 and all NPC-issued guidelines.

For complaints that cannot be resolved directly with 639jl12, you may escalate to the National Privacy Commission of the Philippines via their official government website and contact channels.