4639club Privacy Policy

1.1 This Privacy Policy governs the collection, processing, use, disclosure, storage, and protection of personal data by 4639club ("4639club," "we," "us," "our") in connection with the operation of the 4639club online gaming platform accessible at 4639club.app.

1.2 For the purposes of the Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, 4639club acts as the Personal Information Controller (PIC) in respect of the personal data of registered players and website visitors.

1.3 This policy applies to:

• All registered Players with an active or inactive 4639club account;
• All visitors to the 4639club.app website, regardless of whether they hold a registered account;
• All individuals who communicate with 4639club via support channels, email, or live chat.

1.4 This policy does not apply to the data practices of third-party game providers, payment processors, or other external services linked from or integrated with the 4639club platform. Those parties maintain their own privacy policies governing their respective data practices.

2.1 4639club collects the following categories of personal data:

2.2 Sensitive Personal Information. 4639club does not intentionally collect sensitive personal information as defined under RA 10173 (including race, ethnicity, health information, or political affiliations) except where it is strictly required by law — for example, where a Player's identity document reveals nationality for AML compliance purposes.

2.3 Passwords. Your account password is stored in hashed, salted form using industry-standard cryptographic methods. 4639club personnel cannot view or retrieve your plaintext password under any circumstances.

3.1 Directly from you, when you:

• Complete the account registration form on 4639club.app;
• Submit KYC verification documents;
• Make a deposit or withdrawal through the cashier;
• Contact 4639club support via live chat or email;
• Opt into marketing communications;
• Set responsible gaming limits or self-exclusion preferences;
• Participate in surveys, promotions, or competitions offered by 4639club.

3.2 Automatically, through the operation of the platform, including:

• Browser cookies and similar tracking technologies (see Section 6);
• Server logs that record IP addresses, timestamps, and platform activity;
• Game provider APIs that report game session data back to 4639club;
• Payment processor confirmations and transaction data.

3.3 From third parties, where necessary and lawful, including:

• Identity verification service providers used to authenticate KYC documents;
• Payment processors including GCash, Maya, BPI, BDO, Metrobank, 7-Eleven, Coins.ph, and USDT gateways — to confirm payment method ownership and transaction status;
• Fraud prevention and anti-money laundering screening services;
• PAGCOR or other regulatory bodies, where data is provided pursuant to a lawful regulatory request.

4.1 4639club processes personal data only where a lawful basis exists under RA 10173. The following table describes our processing purposes and corresponding legal bases:

4.2 Where 4639club relies on legitimate interest as a legal basis, we have assessed that our interests do not override your fundamental rights and freedoms as a data subject. You may object to processing on this basis at any time (see Section 9).

4.3 Where processing is based on consent — principally for marketing communications — you may withdraw that consent at any time without penalty. Withdrawal of marketing consent does not affect the lawfulness of processing based on consent before withdrawal, nor does it affect processing carried out on other legal bases.

5.1 4639club does not sell, rent, or trade your personal data to any third party for their own commercial or marketing purposes. Period.

5.2 4639club may share personal data with the following categories of third parties, strictly as necessary for the purposes described in Section 4:

• Game Providers: Licensed game studios (e.g. Pragmatic Play, PG Soft, Jili) receive session identifiers and game activity data necessary to operate the games you play. These providers are bound by contractual data processing obligations.
• Payment Processors: GCash, Maya, BPI, BDO, Metrobank, 7-Eleven, Coins.ph, and USDT gateway operators receive the transaction data necessary to process deposits and withdrawals. Each is a regulated entity subject to applicable Philippine financial laws.
• KYC and Identity Verification Providers: Third-party identity verification services may process copies of your identification documents for the purpose of age and identity verification. These providers operate under strict confidentiality and data processing agreements.
• Fraud and AML Screening Services: Automated fraud detection and anti-money laundering screening providers may receive account and transaction data to identify and flag suspicious activity.
• IT and Infrastructure Providers: Cloud hosting, database, and security infrastructure providers may process technical data in the course of providing services to 4639club. All are subject to contractual data security obligations.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities may receive personal data where 4639club is legally required or ordered to disclose it. 4639club will not disclose data to law enforcement authorities in the absence of a valid legal obligation, court order, or regulatory direction.

5.3 In the event of a business restructuring, merger, acquisition, or sale of assets, personal data held by 4639club may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained.

6.1 4639club uses cookies and similar tracking technologies (including local storage and session storage) to operate the platform, remember your preferences, analyse usage, and support security features.

6.2 The following categories of cookies may be set by 4639club:

6.3 Most modern browsers allow you to control cookies through browser settings — including blocking all cookies, blocking third-party cookies, or deleting existing cookies. Blocking strictly necessary cookies may impair your ability to log in or use core platform features. Browser help documentation explains how to manage cookie settings on each browser.

6.4 Session cookies expire when you close your browser. Persistent cookies remain on your device for a defined period or until you delete them.

7.1 4639club implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Encryption: 256-bit SSL/TLS encryption on all data transmitted between your device and 4639club servers; encryption of sensitive data at rest;
• Access Controls: Role-based access restrictions ensure that 4639club personnel can only access personal data strictly required for their role;
• Password Security: Passwords are stored in hashed and salted form using modern cryptographic algorithms;
• Two-Factor Authentication: Players are encouraged to enable OTP-based 2FA for their accounts;
• Penetration Testing: The platform undergoes periodic security testing by qualified security professionals;
• Incident Response: 4639club maintains a documented data breach response procedure, including notification obligations under RA 10173.

7.2 Data Breach Notification. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 4639club will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, where feasible. Where the breach is likely to result in a high risk to affected individuals, 4639club will also notify affected players directly without undue delay.

7.3 While 4639club takes all reasonable precautions to secure personal data, no transmission of data over the internet is entirely without risk. Players are also responsible for maintaining the security of their own accounts — including using a strong, unique password and enabling 2FA.

8.1 4639club retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations.

8.2 The following indicative retention periods apply:

8.3 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be associated with any identifiable individual.

9.1 Under the Data Privacy Act of 2012 (RA 10173), you have the following rights in respect of your personal data held by 4639club:

10.1 The 4639club platform is strictly restricted to individuals aged 21 years and older, in accordance with PAGCOR online gaming regulations. 4639club does not knowingly collect personal data from anyone under the age of 21.

10.2 Age verification is required as part of the KYC process. Where 4639club discovers that personal data has been collected from an individual who is under 21 years of age, that data will be deleted promptly and the associated account will be permanently closed.

10.3 If you are a parent or guardian and believe that a minor may have registered on the 4639club platform using false age information, please contact us immediately at [email protected] with the subject line "Minor Account Report."

11.1 In the course of operating the 4639club platform, personal data may be transferred to and processed in countries outside the Philippines — for example, where 4639club's cloud infrastructure provider or a licensed game studio operates data centres in another jurisdiction.

11.2 Where such transfers occur, 4639club ensures that appropriate safeguards are in place in accordance with RA 10173 and NPC regulations on cross-border data flows. These safeguards may include:

• Contractual data processing agreements that impose equivalent privacy protections to those required under Philippine law;
• Transfers to jurisdictions that have been assessed to provide an adequate level of data protection;
• Other approved transfer mechanisms consistent with NPC guidance.

11.3 Players in the Philippines whose data is transferred cross-border retain all of the data subject rights described in Section 9 of this policy, regardless of where their data is processed.

12.1 4639club reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or regulatory requirements. The "Last Updated" date at the top of this page will reflect the date of the most recent revision.

12.2 Where changes to this policy are material — meaning they significantly affect your rights or how your personal data is used — 4639club will provide advance notice via email to registered Players and/or via a prominent notice on the platform before the changes take effect.

12.3 Your continued use of the 4639club platform following notification of any change to this policy constitutes acceptance of the revised policy. If you do not accept the revised policy, you should close your account before the revised policy takes effect.

13.1 4639club has designated a Data Protection Officer (DPO) in accordance with RA 10173. The DPO is responsible for overseeing 4639club's compliance with data protection obligations and serving as the primary point of contact for data subjects and the National Privacy Commission.

13.2 To contact the 4639club Data Protection Officer, or to submit any privacy-related query or data rights request, please use the following:

• Email: [email protected] (Subject: "Privacy / DPO")
• Live Chat: 24/7 via the chat feature on 4639club.app

13.3 For complaints regarding 4639club's handling of personal data that cannot be resolved directly, you may contact the National Privacy Commission (NPC) of the Philippines. The NPC's contact details and complaint procedures are available on the NPC's official government website.

13.4 4639club is committed to responding to all data-related queries promptly. Privacy requests will receive an acknowledgement within five (5) business days and a substantive response within thirty (30) calendar days of receipt.