Privacy Policy – 639 cc Casino

1 Who We Are

"639 cc", "639 cc Casino", "we", "us", or "our" refers to the operator of the online gaming platform accessible at 639cc.club, operating under applicable Philippine gaming regulations. 639 cc is the data controller responsible for your personal information collected through the Platform. Our designated Data Protection Officer (DPO) can be contacted as described in Section 15.

2 Personal Data We Collect

To provide our gaming services, comply with regulatory requirements, and protect the integrity of the Platform, 639 cc collects the following categories of personal data:

3 How We Collect Your Data

639 cc collects personal data through the following means:

• Direct interactions: Data you provide when registering, completing KYC, making deposits/withdrawals, contacting support, or participating in promotions;
• Automated technologies: Cookies, web beacons, server logs, and similar technologies that automatically record technical and usage data when you interact with the Platform;
• Third-party verification providers: Identity verification services and payment processors who confirm the accuracy of information you provide;
• Regulatory databases: Publicly available regulatory databases used for AML screening and sanctions checking as required by Philippine law.

4 Purposes of Data Processing

639 cc processes your personal data for the following purposes:

• Creating, verifying, and managing your 639 cc Account;
• Processing deposits, withdrawals, and related financial transactions via GCash, Maya, BDO, BPI, Metrobank, and other payment methods;
• Verifying your identity and age in compliance with PAGCOR regulations and Philippine law;
• Providing customer support and resolving disputes;
• Detecting, investigating, and preventing fraud, money laundering, and other prohibited activities;
• Personalising your experience on the Platform and recommending relevant games;
• Sending service-related communications including transaction confirmations, security alerts, and policy updates;
• Complying with our obligations under Philippine gaming and data protection law;
• Conducting internal analytics to improve platform performance and player experience.

5 Legal Basis for Processing

639 cc processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules:

• Contractual necessity: Processing required to fulfil our obligations under the Terms & Conditions you agreed to when registering;
• Legal obligation: Processing required to comply with PAGCOR regulations, AML laws, KYC requirements, and other applicable Philippine legislation;
• Legitimate interests: Processing for fraud prevention, platform security, and internal analytics, balanced against your privacy rights;
• Consent: For optional processing such as marketing communications, where we have obtained your explicit consent.

6 Data Sharing & Disclosure

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

• Payment processors: GCash, Maya, BDO, BPI, Metrobank, and other payment service providers, strictly for transaction processing;
• Game providers: Third-party game studios (e.g., Pragmatic Play, PG Soft, Jili) receive anonymised or pseudonymised session data for game integrity purposes;
• Identity verification providers: Third-party KYC services used to verify the identity and age of Players;
• Regulatory authorities: PAGCOR, the National Privacy Commission, AMLC, or other Philippine government bodies when required by law;
• Professional advisors: Legal, audit, and compliance professionals bound by confidentiality obligations;
• Business transfers: In the event of a merger, acquisition, or sale of assets, Player data may be transferred to the successor entity subject to equivalent privacy protections.

All third parties with whom 639 cc shares data are required to handle that data in accordance with applicable Philippine data protection law and our data processing agreements.

7 Cookies & Tracking Technologies

639 cc uses cookies and similar tracking technologies to operate and improve the Platform. The cookies we use fall into the following categories:

• Strictly necessary cookies: Essential for the Platform to function — login sessions, security tokens, and load balancing. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, game lobby layout, and recently played games.
• Analytics cookies: Collect anonymised usage data to help us understand how players navigate the Platform so we can improve it. No individual player is identified.

You can manage cookies through your browser settings. Disabling non-essential cookies will not prevent you from using the Platform, though some preference features may not function correctly.

8 Data Retention

639 cc retains your personal data for as long as your Account is active and for a period thereafter as required by applicable law. Specific retention periods include:

• Account and KYC data: Retained for a minimum of 5 years after Account closure, as required by PAGCOR AML regulations;
• Transaction records: Retained for 7 years in compliance with Philippine financial recordkeeping requirements;
• Gaming history: Retained for 3 years after the last gaming session for dispute resolution purposes;
• Support communications: Retained for 2 years after the resolution of the relevant enquiry.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised.

9 Security Measures

639 cc implements comprehensive technical and organisational security measures to protect your personal data, including:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• AES-256 encryption for data stored at rest;
• Hashed and salted password storage — plaintext passwords are never retained;
• Role-based access controls ensuring only authorised personnel can access personal data;
• Regular penetration testing and security audits by independent third parties;
• Incident response procedures including mandatory breach notification to the National Privacy Commission within 72 hours of discovery.

10 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights regarding your personal data held by 639 cc:

• Right to be informed: The right to be told what data we collect and how we use it — which this Privacy Policy fulfils;
• Right of access: The right to request a copy of the personal data 639 cc holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to erasure: The right to request deletion of your personal data, subject to our legal retention obligations;
• Right to object: The right to object to processing based on legitimate interests, particularly for direct marketing;
• Right to data portability: The right to receive your personal data in a structured, machine-readable format;
• Right to complain: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer as described in Section 15. We will respond within 15 business days of receiving a verifiable request.

11 Children & Minors

639 cc Casino is strictly prohibited to persons under the age of 21. We do not knowingly collect personal data from individuals under 21 years of age. If we become aware that a minor has registered an Account, we will immediately suspend the Account, delete the associated personal data, and return any deposited funds to the payment source. If you believe a minor has accessed the Platform, please contact us immediately via Live Chat.

12 International Data Transfers

Some of 639 cc's third-party service providers — including game studios and analytics platforms — may process data in countries outside the Philippines. Where such international transfers occur, 639 cc ensures that appropriate safeguards are in place, including contractual data protection clauses equivalent to Philippine Data Privacy Act standards, prior to any transfer. 639 cc does not transfer data to jurisdictions without adequate data protection frameworks without implementing compensating controls.

13 Third-Party Services & Links

The 639 cc Platform integrates third-party game providers, payment processors, and analytics tools. These third parties operate under their own privacy policies. 639 cc is not responsible for the privacy practices of third-party services accessed through the Platform. We encourage you to review the privacy policies of any third-party payment provider you use in connection with your 639 cc account, such as GCash or Maya.

14 Amendments to This Policy

639 cc reserves the right to update or amend this Privacy Policy at any time. Material changes will be communicated to registered Players via email notification or a prominent notice on the Platform at least 14 days before the amendment takes effect. The "Last Updated" date at the top of this page reflects the most recent revision. Your continued use of the Platform following any amendment constitutes your acceptance of the revised Privacy Policy.

15 Contact & Data Protection Officer

For all privacy-related enquiries, data access requests, or concerns, please contact 639 cc's Data Protection Officer using the following channels:

• Email: [email protected] (plain text — not a clickable link) with subject line "Privacy / Data Request"
• Live Chat: Available 24/7 via the chat widget on the Platform

We aim to acknowledge all privacy enquiries within 3 business days and to resolve them within 15 business days. For unresolved complaints, you may contact the National Privacy Commission of the Philippines.