4639club Privacy Policy

4639club operates the online gaming platform at 4639club.club ("the Platform"), providing casino games, sports betting, bingo, and related entertainment services to players in the Philippines. For the purposes of this Privacy Policy, 4639club is the data controller of the personal data described herein.

This Privacy Policy applies to all personal data collected by 4639club in connection with your use of the 4639club Platform, including data collected during account registration, identity verification, deposits and withdrawals, gameplay, customer support interactions, and promotional participation. It applies to all Filipino players and all other persons who interact with the 4639club Platform regardless of device or location.

4639club processes personal data in accordance with the Republic Act No. 10173, known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and, where applicable, in alignment with internationally recognised data protection principles including those contained in the General Data Protection Regulation ("GDPR").

4639club collects the following categories of personal data from players and prospective players:

• Full legal name as it appears on a Philippine government-issued ID;
• Date of birth (for mandatory age verification — must be 21 or older);
• Email address (primary communication and account recovery);
• Philippine mobile number (SMS OTP, 2FA, and account notifications);
• Residential address (for KYC verification and compliance purposes).

• Copy of Philippine government-issued ID (passport, driver's license, SSS ID, PhilHealth ID, UMID, or voter's ID);
• Selfie or live photo for facial verification where required;
• Proof of address document (utility bill, bank statement, or government-issued document bearing the registered address);
• Payment method verification documentation where applicable.

• GCash mobile number associated with deposit and withdrawal transactions;
• PayMaya account details used for transactions;
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) for bank transfer transactions;
• Partial payment card details (last four digits only; full card numbers are never stored by 4639club);
• Transaction history including deposits, withdrawals, bonus credits, and game wagers.

• IP address and approximate geographic location derived therefrom;
• Device type, operating system, and browser information;
• Session logs, login timestamps, and access records;
• Game play data including games played, bet amounts, outcomes, and session duration;
• Cookie identifiers and related tracking data (see Section 7).

• Records of live chat support interactions;
• Email correspondence with 4639club support;
• Responses to surveys, feedback forms, or promotional competitions.

4639club collects personal data through the following channels:

• Directly from you — when you register a 4639club Account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in a promotion;
• Automatically — through cookies, session logs, and technical tracking technologies when you visit or use the 4639club Platform (see Section 7);
• From third-party payment processors — GCash, PayMaya, and other payment providers may share transaction confirmation data with 4639club to facilitate deposit and withdrawal processing;
• From identity verification providers — 4639club uses third-party KYC service providers to verify the authenticity of identity documents and to screen against regulatory watchlists;
• From fraud prevention and anti-money-laundering services — as required by applicable compliance obligations.

4639club uses collected personal data for the following purposes:

4639club does not use personal data to make fully automated decisions that produce significant legal effects on players without human review. Responsible gaming alerts and fraud flags generated by automated systems are reviewed by 4639club personnel before action is taken on a Player's Account.

4639club processes personal data on the following legal bases under the Data Privacy Act of 2012 and applicable data protection law:

• Contractual necessity — processing required to create and manage your 4639club Account, process transactions, and provide gaming services pursuant to the 4639club Terms and Conditions;
• Legal obligation — processing required to comply with applicable laws and regulations, including KYC, AML, age verification, and PAGCOR-aligned responsible gaming requirements;
• Legitimate interests — processing for fraud prevention, platform security, responsible gaming monitoring, and analytics, where such interests do not override your fundamental privacy rights;
• Consent — where we send you marketing communications or place non-essential cookies on your device, we will do so only with your freely given, specific, and informed consent. You may withdraw consent at any time.

4639club may share personal data with the following categories of recipients:

• Payment service providers — GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and other payment processors, solely for the purpose of processing deposits and withdrawals;
• Identity verification providers — third-party KYC and AML screening service providers engaged to conduct mandatory identity and document verification;
• Game providers — JILI, Pragmatic Play, PG Soft, Evolution Gaming, and other game providers may receive anonymised session data for technical integration purposes; they do not receive personally identifiable player information beyond what is necessary for game service delivery;
• Regulatory and law enforcement authorities — where required by law, court order, or regulatory direction, including PAGCOR or the National Privacy Commission of the Philippines;
• Fraud prevention and security services — third-party fraud detection platforms engaged to protect the platform and players from financial crime;
• Technical infrastructure providers — cloud hosting, data storage, and IT security providers engaged under strict data processing agreements that require them to process data only on 4639club's documented instructions.

All third parties with whom 4639club shares personal data are required to maintain appropriate technical and organisational security measures and to use the data only for the specified purpose for which it was shared.

4639club uses cookies and similar tracking technologies to operate and improve the platform. The following categories of cookies are used:

• Strictly necessary cookies — essential for the platform to function. They manage login sessions, security tokens, and player account state. These cookies cannot be disabled without preventing access to the platform.
• Functional cookies — remember your preferences such as language, display settings, and responsible gaming tool configurations.
• Analytics cookies — collect anonymised and aggregated data about how players use the 4639club Platform to help us improve performance, navigation, and game discovery. Used only with your consent.
• Marketing cookies — used to deliver relevant promotional content to you within the 4639club Platform. Used only with your consent. 4639club does not place third-party advertising cookies that track you across other websites.

You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging into and using the 4639club platform.

4639club retains personal data for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal and regulatory retention obligations:

• Account and identity data — retained for the duration of the active Account and for a minimum of five (5) years following Account closure, in compliance with AML and PAGCOR record-keeping requirements;
• KYC documents — retained for a minimum of five (5) years from the date of verification, as required by applicable AML regulations;
• Transaction records — retained for a minimum of five (5) years from the date of each transaction;
• Customer support communications — retained for a minimum of two (2) years from the date of the interaction;
• Technical and usage logs — retained for up to twelve (12) months for security and fraud prevention purposes, after which they are deleted or anonymised;
• Marketing consent records — retained for the period during which marketing communications are sent and for a reasonable period thereafter as evidence of consent.

Following the expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be attributed to an individual player.

4639club implements appropriate technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the 4639club Platform;
• Encryption of sensitive data at rest, including KYC documents and financial information;
• Role-based access controls limiting internal access to personal data to personnel who require it to perform their job functions;
• Regular security assessments, penetration testing, and vulnerability scanning of platform infrastructure;
• Multi-factor authentication for internal system access by 4639club personnel;
• Data breach detection and response procedures, including timely notification to affected players and the National Privacy Commission of the Philippines where a breach meets the statutory notification threshold.

No online platform can guarantee absolute security. In the event of a personal data breach affecting your rights and freedoms, 4639club will notify you as required by applicable law.

Under the Data Privacy Act of 2012 of the Philippines and applicable data protection law, you have the following rights in relation to your personal data held by 4639club:

• Right to be informed — to receive clear information about how your personal data is collected and used, as set out in this Privacy Policy;
• Right to access — to request a copy of the personal data 4639club holds about you;
• Right to rectification — to request the correction of inaccurate or incomplete personal data;
• Right to erasure — to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 4639club's legal retention obligations;
• Right to object — to object to the processing of your personal data for direct marketing purposes or based on legitimate interests;
• Right to data portability — to receive your personal data in a structured, commonly used, machine-readable format where technically feasible;
• Right to withdraw consent — where processing is based on consent, to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal;
• Right to lodge a complaint — to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph) if you believe 4639club has processed your personal data in breach of applicable law.

To exercise any of these rights, please contact 4639club's support team via the in-platform live chat or by email at [email protected]. 4639club will respond to all data subject requests within thirty (30) days of receipt.

If you are a parent or guardian and believe that your child under the age of 21 has registered a 4639club Account or provided personal data to 4639club, please contact us immediately via live chat or at [email protected]. We will take prompt action to close the Account and delete any associated data.

Where 4639club transfers personal data to third-party service providers located outside the Philippines — for example, to cloud infrastructure providers or international KYC platforms — such transfers are made only where the receiving country provides an adequate level of data protection or where appropriate contractual safeguards (such as standard contractual clauses) are in place to protect the data. 4639club does not transfer personal data to jurisdictions without adequate data protection safeguards.

The 4639club Platform integrates third-party services including payment gateways (GCash, PayMaya, BPI, BDO, Metrobank), game providers, and support tools. These third parties operate their own privacy policies, which govern how they process personal data shared with them by 4639club in the performance of their services. 4639club does not control the privacy practices of third-party service providers beyond the contractual obligations imposed by 4639club's data processing agreements.

The 4639club Platform does not contain links to external websites operated by third parties unrelated to 4639club's gaming services. If you navigate to any external site, this Privacy Policy does not apply to data processed by that site.

4639club reserves the right to update this Privacy Policy from time to time to reflect changes in applicable law, regulatory requirements, or 4639club's data processing practices. When material changes are made, 4639club will notify registered players via a prominent notice on the Platform or by email to the registered address. The updated Privacy Policy will take effect upon publication. We encourage you to review this Privacy Policy periodically. Your continued use of the 4639club Platform following publication of an updated Privacy Policy constitutes your acknowledgement of the changes.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 4639club, please contact us:

• Live Chat: Available 24/7 on the 4639club Platform (Philippine Standard Time)
• Email: [email protected]

4639club acknowledges all data-related enquiries within 24 hours and aims to resolve them fully within thirty (30) days. Where a complaint cannot be resolved to your satisfaction, you have the right to escalate the matter to the National Privacy Commission of the Philippines.