639 cc Privacy Policy

1.1 639 cc respects the privacy of every Filipino player who uses our Platform. This Privacy Policy is designed to give you a clear, honest account of how we handle your personal information — from the moment you register a 639 cc account to the day you close it, and in certain cases beyond.

1.2 We operate in a regulated environment. PAGCOR's licensing requirements and the Anti-Money Laundering Act mean that collecting certain categories of personal data is not optional for us — it is a legal obligation. This policy explains which data falls into that category, and which data is collected on the basis of your consent or our legitimate operational interests.

1.3 By registering a 639 cc account, you acknowledge that you have read and understood this Privacy Policy. If you have questions at any point, our support team is available 24/7 via live chat on the Platform.

2.1 The data controller responsible for your personal information in connection with the 639 cc Platform is the registered operator of 639cc.app, which operates under PAGCOR's regulatory framework for online gaming in the Philippines.

2.2 For all data privacy matters — including requests to exercise your data subject rights, questions about this Policy, or notifications of a suspected data breach — you may contact our designated Data Privacy Officer at:

3.1 639 cc collects personal data in the following categories:

3.2 639 cc does not collect sensitive personal information as defined under RA 10173 — such as race, ethnicity, religious beliefs, or health data — unless such information is voluntarily disclosed in the context of a responsible gaming or self-exclusion request.

4.1 639 cc processes your personal data on the following legal bases under RA 10173:

• Contract performance: Processing your registration data, account data, and payment data is necessary to provide the gaming services you have requested.
• Legal obligation: KYC identity verification, AML transaction monitoring, and PAGCOR reporting are required by Philippine law (RA 9160 as amended, and PAGCOR directives).
• Legitimate interests: Technical data collection for fraud prevention, platform security, and service improvement — balanced against your privacy interests.
• Consent: Marketing communications, optional analytics cookies, and any processing beyond operational necessity is conducted only where you have given explicit consent, which you may withdraw at any time.

5.1 639 cc uses the personal data described in Section 3 for the following purposes:

• Account management: Creating, maintaining, and securing your 639 cc player account;
• Transaction processing: Facilitating deposits via GCash, Maya, BPI, BDO, Metrobank, InstaPay, PesoNet, and 7-Eleven CLiQQ, and processing withdrawal requests;
• Identity verification: Completing KYC checks as required by PAGCOR before processing withdrawal requests;
• Regulatory compliance: Monitoring transactions for AML/CTF purposes as required under RA 9160, and reporting to PAGCOR or other authorities as legally required;
• Fraud prevention: Detecting and investigating suspicious account activity, bonus abuse, or multi-account violations;
• Responsible gaming: Administering deposit limits, session controls, and self-exclusion requests;
• Customer support: Responding to queries, resolving disputes, and maintaining support records;
• Platform improvement: Analysing aggregated, anonymised usage data to improve game selection, interface design, and payment processing;
• Marketing: Sending promotional communications to players who have opted in — you may unsubscribe at any time.

6.1 639 cc may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• KYC and identity verification partners: Third-party providers engaged to verify identity documents submitted for KYC compliance. These providers are contractually bound to process data only for verification purposes.
• Payment processors: GCash (G-Xchange Inc.), Maya (PayMaya Philippines Inc.), GrabPay, BPI, BDO, Metrobank, InstaPay network participants, PesoNet network participants, and 7-Eleven CLiQQ — to the extent necessary to process your deposit or withdrawal transaction.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent authorities, where disclosure is required by law or a valid legal order.
• Technology service providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on 639 cc's behalf under strict data processing agreements.
• Game content studios: To the limited extent that game studios require session identifiers or transaction references to validate in-game outcomes — never including your identity or payment data.

6.2 All third-party service providers engaged by 639 cc are required to implement appropriate technical and organisational security measures and are prohibited from using your data for any purpose beyond the service for which they are engaged.

7.1 The primary data processing infrastructure supporting 639 cc is located within or proximate to the Philippines. However, some third-party service providers — particularly cloud infrastructure and game studio partners — may process data in other jurisdictions.

7.2 Where personal data is transferred outside the Philippines, 639 cc ensures that such transfers are made only to recipients who provide an adequate level of data protection, either through applicable data transfer agreements incorporating the standard contractual clauses recognised by the National Privacy Commission, or equivalent safeguards.

8.1 639 cc retains personal data for as long as your account is active, and thereafter for the periods required by applicable law:

• Identity and KYC documents: Retained for a minimum of five (5) years after account closure, as required under RA 9160 (Anti-Money Laundering Act);
• Financial transaction records: Retained for a minimum of five (5) years from the date of transaction;
• Gaming activity logs: Retained for three (3) years from the date of the relevant session;
• Customer support communications: Retained for two (2) years from the date of the final interaction;
• Marketing consent records: Retained for as long as consent is active, or for one (1) year following withdrawal of consent.

8.2 At the end of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data disposal procedures.

9.1 639 cc uses the following categories of cookies and similar tracking technologies:

• Strictly necessary cookies: Required to maintain your login session, remember game state, and prevent fraudulent session duplication. These cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences — such as language settings, responsible gaming configurations, and game lobby filters — so you don't have to re-enter them on each visit.
• Analytics cookies: Collect aggregated, anonymised data about how players navigate the Platform. This helps us understand which features are used most, identify usability issues, and improve the 639 cc experience over time. These cookies do not identify you individually.

9.2 You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your 639 cc account.

9.3 639 cc does not use third-party advertising cookies or tracking pixels that profile you for external advertising networks.

10.1 639 cc implements the following technical and organisational measures to protect your personal data:

• Encryption in transit: All data exchanged between your device and the 639 cc Platform is encrypted using TLS 1.2 or higher (256-bit SSL);
• Encryption at rest: Sensitive personal data stored on 639 cc servers is encrypted at rest;
• Access controls: Personal data is accessible only to 639 cc personnel whose roles require it, and access is logged and auditable;
• Password security: Account passwords are stored as one-way cryptographic hashes — 639 cc cannot recover your password, only reset it;
• OTP authentication: Sensitive account actions (login from new device, password reset, withdrawal initiation) require SMS OTP verification to your registered Philippine mobile number;
• Penetration testing: 639 cc's security posture is subject to periodic independent security assessments.

10.2 Notwithstanding the above, no internet-based transmission or storage system is completely secure. In the event of a personal data breach that poses a risk to your rights, 639 cc will notify you and the National Privacy Commission within 72 hours of becoming aware of the breach, as required under RA 10173.

11.1 Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by 639 cc:

11.2 To exercise any of these rights, please contact our Data Privacy Officer at support@639cc.app with the subject line "Data Privacy Request" and your registered mobile number. We will respond within 15 calendar days.

12.1 The 639 cc Platform is intended solely for adults aged 21 and above in the Philippines. 639 cc does not knowingly collect or process personal data from individuals below the age of 21.

12.2 If 639 cc becomes aware that a registered account belongs to an individual under 21 years of age, the account will be immediately suspended, any balance will be held pending investigation, and the personal data associated with that account will be securely deleted once the investigation is concluded, subject to any applicable legal retention obligations.

12.3 If you believe a person under the age of 21 has registered on the 639 cc Platform, please contact us immediately at support@639cc.app.

13.1 The 639 cc Platform does not contain links to external third-party websites in its main navigation or game lobby. To the extent that any content on the Platform references an external resource, 639 cc has no control over the privacy practices of that external resource and accepts no responsibility for their data handling.

13.2 Payment providers accessed in connection with deposits and withdrawals — such as GCash or Maya — operate under their own privacy policies. 639 cc encourages you to review those policies when using those services.

14.1 639 cc may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or the services we offer. The "Effective Date" at the top of this document indicates when the current version took effect.

14.2 Where updates are material — meaning they affect how we use your data in a way that is less favourable to you, or introduce new categories of processing — we will notify you via the mobile number registered on your account at least seven (7) days before the changes take effect, where practicable.

14.3 Your continued use of the 639 cc Platform after an updated Privacy Policy takes effect constitutes acceptance of the revised policy. If you do not agree to the updated terms, you may close your account by contacting support@639cc.app.

15.1 For all privacy-related queries, requests to exercise your data subject rights, or concerns about how 639 cc handles your personal information, please contact our Data Privacy Officer:

15.2 If you are not satisfied with 639 cc's response to a data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. The NPC is the independent regulatory body responsible for enforcing RA 10173. Contact information for the NPC is available on their official website.