Privacy Policy

1. Introduction and Scope

This Privacy Policy applies to all personal data collected by 639ji Casino ("639ji," "we," "us," or "our") through the website located at https://639ji.cam, mobile applications, and any associated services (collectively, the "Platform"). By creating an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal data as described herein.

639ji operates as a Philippine Amusement and Gaming Corporation (PAGCOR) licensed online casino operator and is subject to the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and all relevant National Privacy Commission (NPC) circulars and issuances. We are committed to transparency, accountability, and the protection of your personal information.

2. Data Controller Information

639ji Casino is the data controller responsible for the processing of your personal information. For data privacy inquiries, requests, or complaints, you may contact our Data Protection Officer (DPO):

• Data Protection Officer: 639ji Casino DPO
• Email: [email protected]
• Mailing Address: 639ji Casino, Business Address (Philippines)

Our DPO is responsible for ensuring compliance with the Data Privacy Act and serves as the primary contact for data subjects exercising their privacy rights.

3. Personal Data We Collect

639ji collects various categories of personal data to provide our online casino services, comply with legal obligations, and enhance your user experience. The specific data collected depends on your interactions with the Platform.

3.1 Information You Provide Directly

When you register for a 639ji account, make deposits or withdrawals, or communicate with Customer Support, you voluntarily provide the following personal data:

• Identity Information: Full legal name, date of birth, gender, nationality, government-issued identification number (driver's license, passport, UMID, postal ID);
• Contact Information: Email address, mobile phone number, residential address, postal code;
• Financial Information: GCash mobile number, PayMaya account details, bank account numbers, payment card details (partially redacted), transaction history;
• Account Credentials: Username, password (stored in encrypted form), security questions and answers;
• Communication Records: Live chat transcripts, email correspondence, customer support tickets, feedback submissions.

3.2 Information Collected Automatically

When you access the 639ji Platform, we automatically collect certain technical and behavioral data through cookies, web beacons, and similar tracking technologies:

• Device Information: IP address, device type (smartphone, tablet, computer), operating system (Android, iOS, Windows), browser type and version, screen resolution, device identifiers (IMEI, MAC address);
• Usage Data: Pages visited, games played, betting patterns, session duration, referral sources, clickstream data, error logs;
• Location Data: Approximate geographic location derived from IP address (country, region, city) — we do not collect precise GPS coordinates;
• Cookies and Tracking: Session cookies, persistent cookies, authentication tokens, preference settings, analytics data (see Section 10 for cookie management).

3.3 Information from Third Parties

639ji may receive personal data about you from third-party sources to verify your identity, prevent fraud, and comply with anti-money laundering (AML) regulations:

• Identity Verification Services: Data from Philippine government databases, credit bureaus, and identity verification providers to confirm age, identity, and address;
• Payment Processors: Transaction confirmation data from GCash, PayMaya, banks, and other payment service providers;
• Game Providers: Gameplay data, bet histories, and session information from third-party game studios (Pragmatic Play, Evolution Gaming, NetEnt, etc.);
• Fraud Prevention Services: Risk scores, device fingerprints, and behavioral analytics from fraud detection platforms.

4. How We Use Your Personal Data

639ji processes your personal data for the following lawful purposes, based on contractual necessity, legal obligations, legitimate interests, and your explicit consent where required:

4.1 Account Management and Service Delivery

• Creating and maintaining your 639ji player account;
• Authenticating your identity and preventing unauthorized access;
• Processing deposits, withdrawals, and financial transactions;
• Providing access to casino games, sports betting markets, and platform features;
• Tracking your gameplay, bet history, and account balance;
• Delivering customer support and responding to inquiries;
• Administering bonuses, promotions, and loyalty rewards.

4.2 Legal and Regulatory Compliance

• Age Verification: Confirming that all players are at least 21 years old as required by PAGCOR regulations;
• Know Your Customer (KYC): Verifying player identities to prevent fraud, money laundering, and terrorist financing in compliance with the Anti-Money Laundering Act (AMLA);
• Responsible Gaming: Monitoring gambling behavior to detect problem gambling patterns and enforcing self-exclusion requests;
• Audit and Reporting: Maintaining records for PAGCOR audits, tax reporting to the Bureau of Internal Revenue (BIR), and compliance with Philippine gaming laws;
• Dispute Resolution: Preserving evidence for account investigations, fraud claims, and legal proceedings.

4.3 Security and Fraud Prevention

• Detecting and preventing fraudulent transactions, account takeovers, and unauthorized access;
• Identifying multi-accounting violations and bonus abuse;
• Monitoring for suspicious betting patterns, collusion, and cheating;
• Protecting against cyber attacks, data breaches, and system vulnerabilities;
• Blocking access from restricted jurisdictions where online gambling is prohibited.

4.4 Marketing and Communication

With your consent, 639ji may use your contact information to send promotional communications, including:

• Personalized bonus offers and exclusive promotions;
• Email newsletters featuring new games, tournaments, and platform updates;
• SMS notifications about special events, jackpot wins, and limited-time offers;
• Push notifications through mobile apps (if you have opted in).

You may opt out of marketing communications at any time by clicking "Unsubscribe" in emails, replying "STOP" to SMS messages, or adjusting notification settings in your account preferences. Opting out of marketing does not affect transactional messages related to your account (e.g., withdrawal confirmations, security alerts).

4.5 Platform Improvement and Analytics

• Analyzing user behavior and gameplay patterns to improve platform performance;
• Conducting A/B testing to optimize user experience and interface design;
• Developing new features, games, and services based on player preferences;
• Monitoring platform stability, load times, and error rates;
• Generating aggregated, anonymized statistics for business intelligence and strategic planning.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 639ji processes your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our agreement with you (i.e., providing online casino services as outlined in the Terms and Conditions);
• Legal Obligation: Processing is required to comply with Philippine laws, including PAGCOR licensing requirements, AMLA regulations, and tax reporting obligations;
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, security, and platform improvement, provided these interests do not override your fundamental rights;
• Consent: Processing is based on your explicit, informed, and freely given consent for marketing communications, cookies, and optional data sharing;
• Vital Interests: In rare cases, processing may be necessary to protect your life or physical safety or that of another person (e.g., emergency situations).

6. Data Sharing and Disclosure

639ji does not sell, rent, or trade your personal data to third parties for their marketing purposes. However, we may share your personal information with the following categories of recipients under strict confidentiality agreements:

6.1 Service Providers and Business Partners

• Payment Processors: GCash, PayMaya, BDO, BPI, Metrobank, and other financial institutions to process deposits and withdrawals;
• Game Providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, and other licensed game studios to deliver casino games and track gameplay;
• Identity Verification Services: Third-party KYC providers to confirm your age, identity, and address;
• Cloud Service Providers: Amazon Web Services (AWS), Google Cloud, or similar platforms for secure data hosting and storage;
• Customer Support Tools: Live chat software, ticketing systems, and CRM platforms to manage support inquiries;
• Marketing and Analytics: Email service providers, SMS gateways, and analytics platforms (Google Analytics, Mixpanel) to deliver communications and analyze user behavior.

6.2 Regulatory and Law Enforcement Authorities

639ji is legally required to disclose personal data to Philippine government agencies and law enforcement in the following circumstances:

• PAGCOR: Sharing player data, transaction records, and audit reports as required by our gaming license;
• AMLC (Anti-Money Laundering Council): Reporting suspicious transactions and providing KYC documentation to combat money laundering and terrorist financing;
• BIR (Bureau of Internal Revenue): Disclosing winnings and payout information for tax compliance purposes;
• NPC (National Privacy Commission): Responding to data breach notifications, privacy complaints, and compliance audits;
• Courts and Law Enforcement: Providing evidence in response to valid court orders, subpoenas, or criminal investigations.

6.3 Business Transfers

In the event of a merger, acquisition, asset sale, or bankruptcy involving 639ji, your personal data may be transferred to the acquiring entity. We will notify you of any such transfer and ensure that the receiving party agrees to handle your data in accordance with this Privacy Policy and applicable Philippine law.

7. Data Security Measures

639ji employs industry-standard technical and organizational measures to protect your personal data from unauthorized access, disclosure, alteration, or destruction:

7.1 Technical Security Controls

• Encryption: All data transmissions between your device and our servers use TLS 1.3 encryption. Passwords are hashed using bcrypt with salt, and sensitive financial data is encrypted at rest using AES-256;
• Firewalls and Intrusion Detection: Multi-layered firewall protection and real-time intrusion detection systems monitor for suspicious activity;
• Access Controls: Role-based access controls (RBAC) ensure that only authorized personnel can access personal data on a need-to-know basis;
• Two-Factor Authentication (2FA): Optional 2FA for player accounts and mandatory 2FA for administrative access;
• Regular Security Audits: Independent third-party security audits and penetration testing conducted quarterly.

7.2 Organizational Security Policies

• Employee Training: All 639ji staff undergo mandatory data privacy and security training upon hiring and annually thereafter;
• Confidentiality Agreements: Employees, contractors, and service providers sign strict non-disclosure agreements (NDAs) covering personal data handling;
• Incident Response Plan: A documented data breach response plan ensures rapid detection, containment, and notification in the event of a security incident;
• Data Minimization: We collect only the personal data necessary for specified purposes and delete data that is no longer required.

7.3 Limitations of Security

While 639ji employs robust security measures, no system is completely impervious to attack. You are responsible for maintaining the confidentiality of your login credentials and notifying us immediately if you suspect unauthorized account access. 639ji is not liable for security breaches resulting from your failure to protect your password or use of shared/public devices without logging out.

8. Data Retention

639ji retains your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, and resolve disputes. Specific retention periods include:

• Active Account Data: Retained for the duration of your account and five (5) years after account closure, as required by PAGCOR regulations and AMLA compliance;
• Transaction Records: Retained for ten (10) years after the transaction date to comply with BIR tax audit requirements;
• KYC Documentation: Retained for five (5) years after account closure or last transaction, whichever is later;
• Communication Records: Customer support chat logs and email correspondence retained for three (3) years;
• Marketing Data: Deleted within ninety (90) days of opt-out or account closure, unless required for legal compliance;
• Anonymous Analytics: Aggregated, anonymized data may be retained indefinitely for statistical and business intelligence purposes.

After the applicable retention period expires, personal data is securely deleted or anonymized in accordance with 639ji's data destruction policy.

9. Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights regarding your personal data. To exercise these rights, contact our Data Protection Officer at [email protected].

9.1 Right to Access

You have the right to request a copy of the personal data 639ji holds about you. We will provide this information in a commonly used electronic format within fifteen (15) business days of your request, subject to identity verification.

9.2 Right to Rectification

If you believe any personal data we hold about you is inaccurate, incomplete, or outdated, you may request correction. You can update most information directly through your Account Settings page.

9.3 Right to Erasure (Right to be Forgotten)

You may request deletion of your personal data when:

• The data is no longer necessary for the purposes for which it was collected;
• You withdraw consent (where processing was based on consent) and no other legal basis applies;
• You object to processing based on legitimate interests and no overriding legitimate grounds exist;
• The data was unlawfully processed.

Important: We cannot delete data that must be retained for legal compliance (PAGCOR licensing, AMLA, tax reporting) or to establish, exercise, or defend legal claims. In such cases, we will restrict processing instead.

9.4 Right to Object

You may object to processing of your personal data based on legitimate interests, including profiling and direct marketing. If you object to marketing, we will cease such processing immediately. For other objections, we will assess whether compelling legitimate grounds override your interests.

9.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format (e.g., CSV, JSON) and transmit it to another data controller without hindrance, where technically feasible.

9.6 Right to Lodge a Complaint

If you believe 639ji has violated your data privacy rights, you may file a complaint with the National Privacy Commission (NPC):

• NPC Website: https://www.privacy.gov.ph
• Email: [email protected]
• Hotline: (02) 8234-2228

10. Cookies and Tracking Technologies

639ji uses cookies, web beacons, and similar tracking technologies to enhance your experience, analyze platform performance, and deliver personalized content.

10.1 Types of Cookies We Use

• Essential Cookies: Necessary for platform functionality, including authentication, session management, and security. These cookies cannot be disabled.
• Performance Cookies: Collect anonymous data on page load times, error rates, and user navigation patterns to optimize platform performance.
• Functional Cookies: Remember your preferences, language settings, and previous interactions to personalize your experience.
• Marketing Cookies: Track your activity across websites to deliver targeted advertisements and measure campaign effectiveness. These cookies require your consent.

10.2 Managing Cookie Preferences

You can control cookie settings through your browser preferences. Most browsers allow you to block or delete cookies, though this may impact platform functionality. To opt out of targeted advertising cookies, visit the Digital Advertising Alliance Philippines opt-out page.

11. Children's Privacy

The 639ji Platform is strictly intended for individuals aged 21 years or older. We do not knowingly collect personal data from minors. If we discover that we have inadvertently collected data from an individual under 21, we will immediately delete the account and all associated data, report the incident to PAGCOR, and forfeit any deposits to responsible gaming programs as required by law.

Parents or guardians who believe their child has accessed 639ji should contact our Data Protection Officer immediately.

12. International Data Transfers

639ji primarily stores and processes data within the Philippines. However, some service providers (e.g., cloud hosting, analytics platforms) may be located outside the Philippines. In such cases, we ensure that:

• Data transfers comply with the NPC's rules on cross-border data transfer;
• Adequate safeguards are in place, such as Standard Contractual Clauses (SCCs) or certification under recognized data protection frameworks;
• The recipient country provides an adequate level of data protection as determined by the NPC or offers equivalent legal protections.

13. Changes to This Privacy Policy

639ji reserves the right to modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes, we will notify you by:

• Posting a notice on the Platform homepage;
• Sending an email to your registered email address;
• Displaying a pop-up notification upon your next login.

The "Last Updated" date at the top of this document indicates when changes were last made. We encourage you to review this Privacy Policy periodically. Continued use of the Platform after modifications constitutes acceptance of the revised Privacy Policy.

14. Contact Information

For questions, requests, or concerns regarding this Privacy Policy or your personal data, please contact:

• Data Protection Officer: 639ji Casino DPO
• Email: [email protected]
• Live Chat: Available 24/7 through the Platform

We will respond to all privacy-related inquiries within fifteen (15) business days in accordance with NPC guidelines.