639 jili Privacy Policy

Scope & Data Controller

This Privacy Policy applies to all personal data collected and processed by 639 jili in connection with the operation of the online gaming platform accessible at 639jili.co (the "Platform"), including all associated services such as customer support, payment processing, promotional communications, and responsible gaming tools.

For the purposes of the Republic Act No. 10173 (Data Privacy Act of 2012 of the Philippines), 639 jili is the personal information controller in respect of data collected through the Platform. Where third-party service providers process your data on our behalf, they do so as personal information processors under data processing agreements that impose obligations consistent with RA 10173.

This policy applies to all registered members of 639 jili, prospective registrants who visit the Platform, and any individuals who contact 639 jili support. By registering for or using the 639 jili Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with any aspect of this policy, you should not use the Platform.

Data We Collect

639 jili collects personal data through the following means: directly from you during registration and account use; automatically through your interaction with the Platform; and from third-party service providers involved in identity verification or payment processing.

2.1 Data You Provide Directly

2.2 Data Collected Automatically

• Device and Browser Information: Device type, operating system, browser version, screen resolution, and device identifiers.
• IP Address and Geolocation: Your IP address is logged at login and during active sessions to verify your geographic location, detect fraud, and comply with PAGCOR's requirement that real-money gaming services be provided only to users within the Philippines.
• Session and Usage Data: Pages visited, games played, bet amounts, session duration, login timestamps, and navigation patterns within the Platform.
• Cookie Data: See Section 8 for a full description of cookies and tracking technologies used by 639 jili.

2.3 Data from Third Parties

639 jili may receive personal data from third-party identity verification providers engaged to assist with KYC compliance, from payment processors to confirm transaction status, and from fraud detection services. Where data is received from third parties, it is used solely for the purposes described in this policy and is subject to the same security standards as data collected directly.

How We Use Your Data

639 jili uses the personal data it collects for the following specific purposes:

• Account Creation and Management: To register your 639 jili account, authenticate your identity at login, and maintain your account profile and transaction history.
• Payment Processing: To facilitate deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and 7-Eleven, and to maintain accurate PHP balance records.
• Regulatory Compliance: To comply with PAGCOR's KYC requirements, the Philippine Anti-Money Laundering Act (AMLA), and other applicable laws, including reporting obligations to the Anti-Money Laundering Council (AMLC) where triggered by statutory thresholds.
• Fraud Prevention and Security: To detect and prevent fraudulent activity, unauthorised account access, money laundering, and other illegal conduct on the Platform.
• Customer Support: To resolve your queries, complaints, and technical issues efficiently and to maintain records of our support interactions for quality assurance purposes.
• Responsible Gaming: To administer deposit limits, session timers, cool-off periods, and self-exclusion requests, and to identify patterns of gaming behaviour that may indicate problem gambling requiring intervention.
• Platform Improvement: To analyse aggregated usage data to improve the functionality, performance, and user experience of the 639 jili Platform.
• Marketing Communications: With your consent, to send you information about promotions, new games, and offers available at 639 jili. You may withdraw marketing consent at any time through your account settings.

Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173) of the Philippines, 639 jili processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our obligations under the 639 jili Terms & Conditions, including operating your account, processing transactions, and providing gaming services.
• Legal Obligation: Processing is required to comply with PAGCOR regulatory requirements, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws.
• Legitimate Interests: Processing is necessary for the legitimate interests of 639 jili, such as fraud prevention, platform security, and improving our services, provided that these interests are not overridden by your fundamental rights and freedoms.
• Consent: For marketing communications and non-essential cookies, we rely on your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

Data Sharing & Disclosure

5.1 Service Providers

639 jili engages third-party service providers to assist with platform operations, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting services, analytics tools, customer support software providers, and fraud detection systems. All service providers are bound by data processing agreements that require them to process your data only on 639 jili's documented instructions and in accordance with RA 10173.

5.2 Regulatory and Law Enforcement Authorities

639 jili may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), Philippine law enforcement agencies, or other competent authorities where required to do so by applicable law, court order, or regulatory requirement. We will inform you of such disclosures where we are legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or a substantial part of 639 jili's business, your personal data may be transferred to the successor entity. We will notify you of any such transfer and any resulting changes to this Privacy Policy before the transfer takes effect.

5.4 With Your Consent

639 jili may share your personal data with other third parties where you have given your explicit and specific consent to such sharing. This applies, for example, to referral programme mechanics where you have opted in to share limited account information with a referring party.

Data Retention

639 jili retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following specific retention periods:

• Active Account Data: Retained for the full duration of your account's existence and for a period of five (5) years following account closure, in accordance with PAGCOR's record-keeping requirements and Philippine anti-money laundering regulations.
• Transaction Records: All deposit, withdrawal, and wagering records are retained for a minimum of five (5) years from the date of the transaction, as required by AMLA implementing rules.
• KYC Documents: Identity verification documents are retained for five (5) years following the end of the business relationship, consistent with RA 9160 (Anti-Money Laundering Act) requirements.
• Support Interaction Records: Customer support correspondence is retained for three (3) years to allow for complaint escalation and quality review.
• Marketing Data: Retained until you withdraw marketing consent, following which it is deleted within 30 days.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to an identified individual. Where technical constraints prevent immediate deletion, data is restricted from further processing until deletion can be completed.

Security Measures

639 jili implements technical, organisational, and physical security measures designed to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• 256-Bit SSL/TLS Encryption: All data in transit between your device and 639 jili servers is encrypted using industry-standard SSL/TLS encryption. This applies to login sessions, payment transmissions, and document uploads.
• Password Hashing: Your 639 jili account password is never stored in plain text. Passwords are hashed using a cryptographically secure one-way hashing algorithm before storage.
• Two-Factor Authentication (2FA): SMS OTP-based two-factor authentication is available to all 639 jili members and is required for high-value withdrawal requests.
• Access Controls: Access to personal data within 639 jili's organisation is restricted on a need-to-know basis. Staff with access to personal data are bound by confidentiality obligations and receive regular data privacy training.
• Intrusion Detection Systems: 639 jili employs real-time monitoring systems to detect unusual login patterns, potential data exfiltration, and other security anomalies.
• Segregated Data Storage: Player personal data and financial data are stored in logically segregated environments with independent access controls.

Cookies & Tracking Technologies

639 jili uses cookies and similar tracking technologies on the Platform. Cookies are small text files stored on your device by your browser. They allow the Platform to recognise your device across sessions and provide core functionality.

8.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in to your 639 jili account and security cookies that help detect fraudulent activity. These cookies cannot be disabled without affecting the Platform's core functionality.
• Functional Cookies: Remember your preferences, such as language settings and game view configurations. These improve your experience but are not essential to Platform operation.
• Analytics Cookies: Help 639 jili understand how members use the Platform — which pages are visited most, how long sessions last, and where users encounter difficulties. This data is used in aggregated, anonymised form to improve the Platform. You may opt out of analytics cookies through your browser settings.
• Session Cookies: Temporary cookies that expire when you close your browser. These are used to maintain your login state during a single gaming session.

8.2 Managing Cookies

You can manage cookie preferences through your browser's settings. Disabling strictly necessary cookies will impair your ability to use the 639 jili Platform, as session authentication relies on them. Disabling functional or analytics cookies will not prevent you from using the Platform but may result in a reduced experience. Browser-level cookie management instructions vary by browser — consult your browser's help documentation for guidance specific to your device.

Minors & Age Verification

639 jili collects date of birth information at registration and may request government-issued identification documents to verify that a player meets the 21-year minimum age requirement. Where 639 jili has reason to believe that a registered account is being used by a person under the age of 21, the account will be immediately suspended pending investigation, and any real-money balance may be held pending age verification.

639 jili does not knowingly collect or process the personal data of individuals under 21 years of age. If you believe that 639 jili has inadvertently collected data from a person under 21, please contact our Data Privacy Officer at the contact details in Section 13. We will take immediate steps to delete the relevant data and suspend the associated account.

Parents and guardians who believe a minor in their household may have accessed the 639 jili Platform should contact support immediately. Parental control software and device-level access restrictions can help prevent underage access to online gaming platforms.

Your Data Rights

Under the Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights in relation to your personal data held by 639 jili. You may exercise any of these rights by contacting the 639 jili Data Privacy Officer (see Section 13):

• Right to Be Informed: You have the right to know what personal data 639 jili holds about you, how it is used, and with whom it is shared. This Privacy Policy fulfils our primary disclosure obligation, and you may request additional specific information at any time.
• Right of Access: You may request a copy of the personal data that 639 jili holds about you. We will provide this within fifteen (15) business days of receiving a verified request.
• Right to Rectification: You have the right to have inaccurate or incomplete personal data corrected. Many basic account details can be updated directly in your 639 jili account settings. For corrections to KYC documents or other sensitive data, please contact support.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to our legal obligations to retain certain data under PAGCOR regulations and AMLA requirements.
• Right to Object: You may object to the processing of your personal data where processing is based on legitimate interests, including objecting to direct marketing communications. Objections to marketing will be actioned within five (5) business days.
• Right to Data Portability: Where technically feasible, you may request a copy of your personal data in a structured, machine-readable format for transfer to another service provider.
• Right to Lodge a Complaint: If you are dissatisfied with how 639 jili has handled your personal data, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, submit your request in writing to the 639 jili Data Privacy Officer using the contact details in Section 13. We may require you to verify your identity before processing your request. We will respond to all verified requests within fifteen (15) business days.

Cross-Border Data Transfers

639 jili's primary data processing infrastructure is located within or operated for the Philippine market. However, certain service providers engaged by 639 jili — including cloud hosting, analytics, and fraud detection providers — may process data on servers located outside the Philippines.

Where personal data is transferred outside the Philippines, 639 jili ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under RA 10173, including by entering into data transfer agreements with receiving parties that impose substantively equivalent data protection obligations.

639 jili does not transfer your personal data to jurisdictions that do not offer adequate data protection standards without implementing the safeguards described above.

Data Breach Procedure

Despite our security measures, no data transmission or storage system can be guaranteed to be completely secure. In the event of a personal data breach affecting 639 jili, we will take the following steps:

• Contain the breach and assess the nature, scope, and impact of the incident;
• Notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of a breach that is likely to result in a risk to the rights and freedoms of affected individuals, in accordance with RA 10173 implementing rules;
• Notify affected individuals directly — via their registered mobile number — where the breach is likely to result in high risk to their rights and freedoms, including the nature of the breach, the data categories involved, the likely consequences, and the measures 639 jili is taking;
• Document the breach and maintain records for NPC reporting and internal review purposes.

If you believe your 639 jili account or data may have been compromised, please contact 639 jili support immediately via live chat or at [email protected].

Data Privacy Officer

639 jili has appointed a Data Privacy Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. The DPO is the primary point of contact for data subjects wishing to exercise their rights under RA 10173 and for inquiries regarding the processing of personal data by 639 jili.

You may contact the 639 jili Data Privacy Officer at:

The NPC contact for complaints is the National Privacy Commission of the Philippines, which can be reached through its official government channels. 639 jili will cooperate fully with any NPC investigation into privacy complaints submitted by our users.

Changes to This Privacy Policy

639 jili may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. When we make material changes to this policy, we will notify you by sending an SMS notification to your registered mobile number and by posting a prominent notice on the 639 jili Platform at least seven (7) days before the changes take effect.

The "Effective Date" displayed at the top of this page indicates when the current version of the Privacy Policy became operative. Your continued use of the 639 jili Platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes.

If you disagree with any changes to this Privacy Policy, you must discontinue use of the Platform and contact 639 jili support to arrange account closure. Previous versions of the 639 jili Privacy Policy are available upon request from our Data Privacy Officer.