Privacy Policy — 639ji

01 Who We Are and How to Reach Us

This Privacy Policy is issued by 639ji ("639ji," "we," "us," "our"), the operator of the online casino and sports betting platform accessible at 639ji.net. 639ji operates under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR) and is committed to protecting the privacy and personal data of every registered player and site visitor.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, 639ji is the Personal Information Controller in respect of the personal data described in this policy.

This policy applies to all personal data collected through your use of the 639ji website, any associated mobile-optimized interface, our customer support channels, and any other service we provide in connection with the 639ji platform.

02 Personal Data We Collect

639ji collects personal information only to the extent necessary to operate the platform, verify player identities, process financial transactions, and comply with applicable Philippine law and PAGCOR regulations. The categories of data we collect are set out in the table below.

03 How We Use Your Personal Data

639ji uses the personal data we collect for the following purposes, each of which is supported by a lawful basis described in Section 4:

• Account creation and management: To register your account, verify your identity, and provide you with access to the 639ji platform.
• Age and identity verification: To confirm that you meet the minimum age requirement of 21 years as mandated by PAGCOR and Philippine gambling law, and that you are who you say you are.
• Payment processing: To process deposits through GCash, PayMaya, BPI, BDO, and Metrobank, and to facilitate withdrawal requests to your verified payment method.
• Regulatory compliance and AML obligations: To monitor transactions for suspicious activity in accordance with the Anti-Money Laundering Act (AMLA) and report to the AMLC as legally required. PAGCOR-licensed operators are subject to mandatory AML reporting obligations.
• Fraud prevention and platform security: To detect, investigate, and prevent cheating, multi-accounting, bonus abuse, and other prohibited conduct outlined in our Terms and Conditions.
• Customer support: To respond to your inquiries, resolve disputes, and manage your account-related requests.
• Responsible gaming: To monitor gaming patterns that may indicate problem gambling behavior and to administer the self-exclusion, deposit limit, and cooling-off tools available in your account settings.
• Platform improvement and analytics: To understand how players use 639ji, diagnose technical issues, and improve the overall user experience. Analytics data is processed in aggregated, de-identified form wherever possible.
• Direct communications: To send you transactional emails (deposit confirmations, withdrawal status updates, account security alerts) and, where you have opted in, promotional communications about 639ji offers.

04 Legal Basis for Processing

Under the Philippine Data Privacy Act, 639ji relies on the following legal grounds to process your personal information:

1. Contractual necessity: Processing required to fulfil the agreement between you and 639ji — i.e., operating your account, processing bets, and paying out winnings.
2. Legal obligation: Processing required for compliance with PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine legislation.
3. Legitimate interests: Processing necessary for 639ji's legitimate business interests, such as fraud prevention, platform security, and responsible gaming monitoring — provided those interests are not overridden by your fundamental rights.
4. Consent: Where none of the above grounds applies, we will seek your explicit consent before processing. Consent-based processing applies primarily to optional marketing communications. You may withdraw consent at any time by updating your account communication preferences.

05 Data Sharing and Disclosure

639ji does not sell, rent, or trade your personal data. We share your information only in the limited circumstances described below:

• Regulatory and government authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government bodies, where disclosure is required by law or pursuant to a valid legal order.
• Payment processors: GCash (G-Xchange Inc.), PayMaya (Voyager Innovations), BPI, BDO, and Metrobank — to the extent necessary to process your deposit and withdrawal transactions. These processors operate under their own privacy policies and applicable Bangko Sentral ng Pilipinas (BSP) regulations.
• Game content providers: Providers such as JILI, Pragmatic Play, and PG Soft may receive limited session and stake data necessary to operate the games you play. These providers are contractually bound to use such data only for game operation purposes.
• IT and infrastructure service providers: Cloud hosting, security monitoring, and analytics vendors who process data on our behalf under strict data processing agreements that comply with the Data Privacy Act.
• Professional advisors: Legal, audit, and compliance professionals engaged by 639ji, subject to professional confidentiality obligations.

06 Cookies and Tracking Technologies

639ji uses cookies and similar tracking technologies when you access the platform. Cookies are small text files stored on your device that help us provide a better, more personalized experience. The types of cookies we use are:

• Strictly necessary cookies: Required for the platform to function — including session management (keeping you logged in), security token validation, and load balancing. These cannot be disabled without breaking core platform functionality.
• Functional cookies: Remember your preferences such as language settings, preferred game categories, and display options so you don't have to reconfigure them each visit.
• Analytics cookies: Collect anonymized data about how players navigate the platform — including which pages are most visited and where players encounter errors. This data is used in aggregate form to improve the platform.
• Session security cookies: Monitor for suspicious activity within a session, including unusual IP switching and multiple simultaneous sessions, to protect your account from unauthorized access.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect your experience on the 639ji platform. For detailed information on how to manage cookies in your specific browser, refer to your browser's help documentation.

07 Data Retention

639ji retains your personal data for as long as your account is active and for such additional periods as are required to fulfil the purposes described in this policy or to comply with legal obligations. Our standard retention periods are as follows:

• Account and identity data: Retained for the lifetime of your account 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 each transaction, as required under the Anti-Money Laundering Act.
• Customer support communications: Retained for two (2) years from the date of the last communication in a support interaction, or longer if the interaction relates to an unresolved dispute.
• Technical and session data: Retained for up to twelve (12) months in identifiable form, after which it is either deleted or anonymized for aggregate analytics purposes.

08 Data Security Measures

639ji implements a layered set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Key measures include:

• TLS/SSL encryption on all data in transit between your browser or device and our servers.
• AES-256 encryption for sensitive data fields at rest in our databases.
• Role-based access controls limiting access to personal data to only those employees and contractors with a legitimate operational need.
• Multi-factor authentication on all internal systems that process personal data.
• Regular security audits and penetration testing conducted by qualified third-party security professionals.
• Incident response procedures aligned with the Data Privacy Act's 72-hour breach notification requirement to the National Privacy Commission.

While we apply industry best practices, no online system can guarantee absolute security. You also play a role in protecting your data — please use a strong, unique password for your 639ji account, enable two-factor authentication, and never share your login credentials with anyone.

09 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 639ji. To exercise any of these rights, contact our Data Protection Officer at [email protected] with "Data Subject Request" in the subject line. We will respond within fifteen (15) business days of receiving a complete, verifiable request.

10 Children and Minors

639ji's platform is strictly for adults aged 21 years and older, consistent with PAGCOR's minimum age requirement for casino-style gambling in the Philippines. 639ji does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been submitted by or on behalf of a person under the age of 21, we will immediately close the associated account, permanently delete all personal data collected in connection with that account, and forfeit any balance in accordance with our Terms and Conditions and PAGCOR regulations.

11 Cross-Border Data Transfers

Certain service providers engaged by 639ji — particularly cloud infrastructure and game content providers — may process or store data on servers located outside the Philippines. Where such cross-border transfers occur, 639ji ensures that appropriate safeguards are in place as required by the Data Privacy Act, including:

• Written data processing agreements requiring the recipient to apply data protection standards equivalent to those required under Philippine law.
• Transfers only to jurisdictions or entities that have been assessed as providing an adequate level of data protection.
• Standard contractual clauses or binding corporate rules where required.

639ji does not transfer your personal data internationally for purposes other than those described in this policy. Your data will never be transferred to jurisdictions without adequate legal protection in place.

12 Changes to This Privacy Policy

639ji reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. When material changes are made — meaning changes that significantly affect how we collect or use your personal data — we will notify you by email to your registered address at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page will always reflect the most recent revision. We encourage you to review this policy periodically to stay informed about how 639ji protects your information. Your continued use of the platform after the effective date of any revised policy constitutes your acceptance of the updated terms.

For minor clarifications or edits that do not affect your rights or how we process your data, changes may take effect immediately upon publication without prior notice.

13 Contact and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 639ji, please reach out to our Data Protection Officer. We are committed to addressing all privacy-related inquiries promptly and transparently.

When submitting a data subject request, please include your registered 639ji username and a brief description of your request or concern. For access, correction, or erasure requests, we may need to verify your identity before processing your request — this is to protect you against unauthorized requests made in your name.

For general account support — including deposit and withdrawal inquiries, game issues, and responsible gaming tool activation — our customer support team is available seven days a week via live chat on the platform (8:00 AM – 10:00 PM PST daily).