639 jl Privacy Policy

639 jl is committed to safeguarding the privacy and personal data of every Player who uses our Platform. We understand that trust is the foundation of any lasting relationship — and that trust begins with being transparent about how we handle your information.

This Policy applies to all personal data collected through the 639 jl website, mobile-optimized platform, customer support channels, and any other touchpoints through which you interact with 639 jl. It applies to all registered Players, prospective users, and visitors to the Platform.

This Policy should be read together with our Terms & Conditions, which govern your overall use of the 639 jl Platform.

For the purposes of the Data Privacy Act of 2012 and this Policy, the data controller responsible for your personal information is:

• Platform Name: 639 jl
• Website: 639-jl.app
• Operating Jurisdiction: Republic of the Philippines
• Data Protection Officer (DPO) Contact: [email protected]

Our designated Data Protection Officer (DPO) is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO directly for any privacy-related inquiries, requests, or complaints.

639 jl collects the following categories of personal data, depending on how you interact with the Platform:

639 jl collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and server logs. See Section 7 for full details on our cookie practices.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-money laundering (AML) screening services; payment confirmation data from payment processors such as GCash, PayMaya, BDO, BPI, and Metrobank.
• Publicly available sources: In limited circumstances, 639 jl may supplement your profile with information from publicly available Philippine government databases for identity verification purposes.

639 jl processes your personal data only for specific, legitimate purposes and on a valid legal basis under the Data Privacy Act of 2012. The table below outlines our primary processing activities:

Where 639 jl relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

639 jl does not sell, rent, or trade your personal data. We may share your information only in the following limited circumstances and only to the extent necessary for the stated purpose:

• Service Providers: Trusted third-party vendors who assist in operating the 639 jl Platform, including payment processors (GCash, PayMaya, BDO, BPI, Metrobank), KYC verification providers, cloud hosting providers, and customer support software providers. All service providers are contractually bound to process your data only on our instructions and in compliance with applicable data protection laws.
• Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government agencies where disclosure is required by law or regulation.
• Law Enforcement: Philippine law enforcement agencies where disclosure is required by a valid court order, subpoena, or other legal process.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of 639 jl's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.
• With Your Consent: In any other circumstances where you have given explicit prior consent to the disclosure.

639 jl uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The types of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies and security tokens. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, game lobby layout, and responsible gaming limits you have set.
• Analytics Cookies: Help us understand how Players use the Platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and bot traffic on the 639 jl Platform.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 639 jl Platform. 639 jl does not use third-party advertising cookies or behavioral tracking cookies for cross-site advertising purposes.

639 jl 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 Philippine law and regulation. Our general retention periods are as follows:

• Account and Identity Data: Retained for the duration of your active account relationship with 639 jl, plus a minimum of five (5) years following account closure, in compliance with AMLC record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine anti-money laundering regulations.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, for dispute resolution and quality assurance purposes.
• Technical and Usage Data: Retained for up to thirteen (13) months in identifiable form, after which it is anonymized or deleted.
• Marketing Preferences: Retained until you withdraw consent or close your account, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 639 jl's data disposal procedures.

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

• Encryption: All data transmitted between your device and the 639 jl Platform is encrypted using TLS 1.2 or higher. Sensitive data stored on our servers is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. All 639 jl staff with access to personal data are subject to confidentiality obligations and regular data privacy training.
• Infrastructure Security: Our Platform is hosted on secure, audited cloud infrastructure with firewalls, intrusion detection systems, and regular vulnerability assessments.
• Two-Factor Authentication: 639 jl supports and encourages the use of two-factor authentication (2FA) for all Player accounts to reduce the risk of unauthorized access.
• Incident Response: 639 jl maintains a documented data breach response plan. In the event of a personal data breach, we will notify affected Players and the National Privacy Commission within the timeframes required by RA 10173.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 639 jl. To exercise any of these rights, please contact our Data Protection Officer at [email protected].

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

If 639 jl becomes 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. If you are a parent or guardian and believe that your child has provided personal information to 639 jl, please contact us immediately at [email protected].

In certain circumstances, 639 jl may transfer your personal data to service providers or infrastructure located outside the Republic of the Philippines — for example, to cloud hosting providers or technology partners operating in other jurisdictions.

Where such transfers occur, 639 jl ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under Philippine law. These safeguards may include:

• Contractual clauses requiring the recipient to process data in accordance with RA 10173 standards.
• Transfers only to jurisdictions recognized by the NPC as providing an adequate level of data protection.
• Binding corporate rules where applicable.

You may request further information about the specific safeguards in place for any cross-border transfer by contacting our Data Protection Officer.

639 jl 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. The date of the most recent revision is always displayed at the top of this page.

When material changes are made to this Policy, 639 jl will notify registered Players via email or through a prominent notice on the Platform prior to the changes taking effect. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

Your continued use of the 639 jl Platform following the publication of any amendments constitutes your acceptance of the revised Privacy Policy.

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

• DPO Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 through the 639 jl Platform
• Response Time: We aim to acknowledge all privacy requests within 72 hours and resolve them within 30 calendar days

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines.

For responsible gaming concerns, please visit our Responsible Gaming page or contact our support team directly.