Privacy Policy

639jl ("we," "us," or "our") is committed to protecting the personal data of every user who interacts with our platform. This Privacy Policy has been prepared in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC).

This policy describes in clear terms how 639jl collects, processes, stores, shares, and protects personal information in connection with your use of the 639jl gaming platform — whether you access it through our website or our mobile application. It also outlines the rights you hold as a data subject under Philippine law and how you can exercise those rights.

639jl acts as the data controller for all personal information collected through the platform. We are responsible for ensuring that your data is handled lawfully, fairly, and transparently at all times. Where we engage third-party service providers to process data on our behalf, we ensure that appropriate data processing agreements are in place.

This Privacy Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which form part of the overall agreement between you and 639jl.

639jl collects personal data that is necessary for the operation of the platform, the provision of gaming services, and compliance with our legal and regulatory obligations. The categories of personal data we collect include:

639jl does not collect sensitive personal information — such as racial or ethnic origin, political opinions, religious beliefs, or health data — unless it is strictly necessary for a specific legal or regulatory purpose, and only with your explicit consent where required.

639jl collects personal data through the following means:

• Direct interactions: Data you provide when you register an account on 639jl, complete identity verification, make a deposit or withdrawal, contact our support team , submit a complaint, or respond to a survey or promotion.
• Automated technologies: Data collected automatically when you access the 639jl platform, including cookies, web beacons, log files, and similar tracking technologies that record your device information, IP address, browsing behavior, and session activity.
• Third-party sources: Data received from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank in connection with your financial transactions. We may also receive data from identity verification service providers as part of our KYC process.
• Publicly available sources: In limited circumstances, 639jl may verify information you have provided against publicly available records, including government databases, for the purpose of identity verification and fraud prevention.

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

• Account management: To create, maintain, and administer your 639jl account, including verifying your identity and age (21+ requirement) as part of our registration and KYC process.
• Service delivery: To provide you with access to 639jl's games — including Golden Leopard, Ganesh Gold, Zuma Dragon, Drill That Gold, Win Drop, Tower, and sports betting markets — and to process your bets, deposits, and withdrawals.
• Financial processing: To facilitate secure transactions through GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels, and to maintain accurate financial records.
• Legal and regulatory compliance: To fulfill our obligations under Philippine law, including anti-money laundering (AML) requirements, Know Your Customer (KYC) regulations, and any reporting obligations to relevant authorities.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal conduct on the 639jl platform.
• Responsible gaming: To monitor gaming patterns and identify users who may be at risk of problem gambling, and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion requests.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance related to your 639jl account or gaming experience.
• Platform improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the 639jl platform.
• Marketing communications: To send you promotional offers, bonus notifications, and updates about new games or features on 639jl — but only where you have given your explicit consent to receive such communications. You may withdraw this consent at any time.

639jl will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, 639jl processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary for the performance of the contract between you and 639jl — specifically, to provide you with access to the platform, process your transactions, and manage your account.
• Legal obligation: Processing is required for 639jl to comply with applicable Philippine laws and regulations, including AML obligations, KYC requirements, and any directives from PAGCOR or other regulatory bodies.
• Legitimate interests: Processing is necessary for 639jl's legitimate business interests, including fraud prevention, platform security, and improving our services, provided that these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — 639jl relies on your freely given, specific, informed, and unambiguous consent. You have the right to withdraw this consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

639jl does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to the extent necessary to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and age verification service providers who assist 639jl in confirming the identity and eligibility of registered users.
• Technology and infrastructure providers: Cloud hosting, data storage, cybersecurity, and platform maintenance providers who process data on 639jl's behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: Government agencies, law enforcement bodies, PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC), where disclosure is required by law or in response to a lawful request.
• Professional advisors: Legal counsel, auditors, and other professional advisors who require access to data in the course of providing services to 639jl, subject to professional confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of 639jl's business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

639jl uses cookies and similar tracking technologies on our website and mobile application to enhance your experience, maintain session security, and analyze platform usage. The types of cookies we use include:

• Strictly necessary cookies: These cookies are essential for the 639jl platform to function correctly. They enable core features such as account login, session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Performance and analytics cookies: These cookies collect anonymized information about how users interact with the 639jl platform — such as which pages are visited most frequently and how long sessions last. This data helps us improve the platform's performance and user experience.
• Functional cookies: These cookies remember your preferences and settings — such as your preferred language or display options — to provide a more personalized experience on 639jl.
• Marketing cookies: With your consent, these cookies track your activity on 639jl to enable us to deliver relevant promotional content and offers. You may opt out of marketing cookies at any time through your account settings.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 639jl platform. For more information on how to manage cookies, refer to your browser's help documentation.

639jl 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 general data retention periods are as follows:

• Account data: Retained for the duration of your active account relationship with 639jl, and for a minimum of five (5) years following account closure, in accordance with AML and regulatory record-keeping requirements.
• Transaction records: Financial transaction data is retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC and identity documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a specific legal obligation or ongoing investigation.
• Support communications: Customer support records are retained for up to three (3) years from the date of the last interaction, for dispute resolution and quality assurance purposes.
• Marketing data: Retained until you withdraw your consent to receive marketing communications, after which it will be deleted or anonymized within a reasonable period.
• Technical and usage data: Log files and session data are typically retained for up to twelve (12) months, unless a longer retention period is required for security or fraud investigation purposes.

When personal data is no longer required, 639jl will securely delete or anonymize it in accordance with our internal data disposal procedures.

639jl implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the 639jl platform is encrypted using industry-standard Transport Layer Security (TLS) protocols. Sensitive data stored on our servers is encrypted at rest.
• Access controls: Access to personal data within 639jl is restricted on a strict need-to-know basis. Employees and contractors who handle personal data are subject to confidentiality obligations and receive regular data protection training.
• Firewalls and intrusion detection: 639jl's infrastructure is protected by enterprise-grade firewalls and intrusion detection systems that monitor for and respond to suspicious activity in real time.
• Secure payment processing: All financial transactions on 639jl are processed through PCI-DSS compliant payment gateways. 639jl does not store full payment card details on its servers.
• Regular security assessments: 639jl conducts periodic security audits and vulnerability assessments to identify and address potential weaknesses in our systems.
• Incident response: In the event of a personal data breach that poses a risk to your rights and freedoms, 639jl will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected users without undue delay.

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by 639jl. To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 14.

639jl will respond to all data rights requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further two months, in which case we will notify you of the extension and the reasons for it. There is no fee for exercising your data rights, unless requests are manifestly unfounded or excessive.

If you are not satisfied with how 639jl has handled your personal data or responded to a data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

The 639jl platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. 639jl does not knowingly collect personal data from individuals under the age of 21.

If 639jl becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any winnings accumulated by an underage user will be forfeited.

If you are a parent or guardian and believe that your child has registered on 639jl or provided personal data to us, please contact our support team immediately so that we can take appropriate action.

The 639jl platform may contain references to third-party services — such as payment providers like GCash and PayMaya — that operate under their own privacy policies. When you interact with these third-party services, your personal data is subject to their respective privacy practices, which are outside of 639jl's control.

639jl is not responsible for the privacy practices or content of any third-party services. We encourage you to review the privacy policies of any third-party providers you interact with in connection with your use of 639jl.

639jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered users through a notice posted on the 639jl platform, an in-app notification, or an email to your registered address.

The updated Privacy Policy will take effect on the date specified in the notice. The "Last Updated" date at the top of this page will always reflect when the most recent revision was made. We encourage you to review this policy periodically to stay informed about how 639jl protects your personal data.

Your continued use of the 639jl platform following the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with the revised policy, you should discontinue use of the platform and may request account closure.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 639jl handles your personal data, please contact our Data Protection Officer. We are committed to addressing all privacy-related inquiries promptly and transparently.