4639club Privacy Policy

1.1   4639club is committed to protecting the privacy and personal data of every player and visitor who interacts with our Platform. We recognize that in the context of online gaming, players share sensitive financial and identity information with us, and we treat that information with the seriousness it deserves.

1.2   This Policy applies to all personal data processed by 4639club in connection with: (a) the registration and maintenance of player accounts; (b) the use of any game, service, or feature on the Platform; (c) transactions including deposits and withdrawals; (d) communications between you and 4639club; and (e) your general browsing of the 4639club website.

1.3   This Policy should be read alongside the 4639club Terms & Conditions, which are available at /terms-conditions, and the Responsible Gaming Policy at /responsible-gaming.

1.4   If you have questions about this Policy or wish to exercise your data rights, please refer to Section 14 (Contact & Complaints) for the appropriate contact details.

2.1   For the purposes of the Philippine Data Privacy Act of 2012 (R.A. 10173), 4639club is the Personal Information Controller (PIC) with respect to personal data collected from players and visitors of the Platform.

2.2   As Personal Information Controller, 4639club determines the purposes and means by which personal data is processed. Where 4639club engages third-party service providers to process personal data on its behalf, those providers act as Personal Information Processors (PIPs) under documented processing agreements that require them to maintain data protection standards consistent with this Policy and applicable Philippine law.

3.1   The categories of personal data 4639club collects, and the context in which each is collected, are described in the table below:

3.2   4639club does not intentionally collect special categories of sensitive personal information (such as health data, religious beliefs, or political opinions) unless specifically required for responsible gaming compliance (e.g., self-exclusion records) or as mandated by PAGCOR or applicable Philippine law.

4.1   Directly from you. The majority of personal data 4639club holds is provided directly by you during the account registration process, KYC verification, deposits and withdrawals, customer support interactions, and responsible gaming tool activations.

4.2   Automatically during Platform use. When you access the 4639club website or play games on the Platform, certain technical data is automatically collected by our systems and third-party analytics services. This includes your IP address, device identifiers, browser characteristics, and behavioural data related to your session and game activity.

4.3   From payment providers. When you complete a deposit or withdrawal via GCash, Maya, or any other supported payment method, the relevant payment provider shares transaction confirmation data and — where required for fraud prevention — limited account identifier data with 4639club.

4.4   From third-party identity verification services. Where 4639club uses a third-party KYC service to assist with identity and age verification, that provider may share verification outcomes and associated identity data with us.

4.5   From PAGCOR and other regulatory bodies. 4639club may receive data about players from PAGCOR or other Philippine regulatory authorities, for example in connection with exclusion registers or compliance directives.

5.1   4639club processes your personal data for the following purposes, each of which is supported by a lawful basis under the Philippine Data Privacy Act of 2012:

5.2   Where 4639club relies on your consent as the legal basis for processing (for example, for marketing communications), you may withdraw that consent at any time by contacting customer support or using the opt-out mechanism in the relevant communication. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

6.1   4639club does not sell, rent, or trade your personal data to third parties for their own commercial purposes.

6.2   4639club may share your personal data with the following categories of recipients, strictly for the purposes described in this Policy:

• Payment processors: GCash (GXI), Maya (Voyager Innovations), BPI, BDO, Metrobank, 7-Eleven, Coins.ph, and other payment infrastructure providers — for the purpose of processing deposits and withdrawals;
• KYC and identity verification providers: Third-party identity verification services engaged to assist with the KYC process required under PAGCOR regulations;
• Game content providers: Providers such as JILI, PG Soft, and Pragmatic Play receive limited technical session data necessary to deliver their games through the 4639club Platform;
• IT and platform infrastructure providers: Cloud hosting, CDN, and platform security vendors who process data as Personal Information Processors under contractual data processing obligations;
• Analytics providers: Aggregated or pseudonymised platform usage data may be shared with analytics providers for Platform improvement purposes; and
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities — where required by law, court order, or PAGCOR directive.

6.3   Where 4639club engages Personal Information Processors, those processors are bound by written agreements requiring them to process personal data only on 4639club's documented instructions, to implement appropriate security measures, and to comply with the Philippine Data Privacy Act.

7.1   The 4639club Platform uses cookies and similar tracking technologies to provide a functional, secure, and personalized experience. A cookie is a small text file stored on your device by your browser when you visit a website.

7.2   Categories of cookies used by 4639club:

• Strictly necessary cookies: Essential for the Platform to function — session authentication, security tokens, and load balancing. These cannot be disabled without preventing you from using the Platform;
• Functional cookies: Remember your preferences such as language settings and lobby layout configuration;
• Performance and analytics cookies: Collect aggregated data on how players use the Platform to help us identify improvements; and
• Fraud prevention cookies: Assist in detecting suspicious activity, duplicate account attempts, and other security threats.

7.3   You can control non-essential cookies through your browser settings. Disabling cookies may affect Platform functionality — in particular, session-based features that require the strictly necessary cookies described in Clause 7.2 may not function if all cookies are blocked.

7.4   4639club does not use cookies to serve third-party advertising or to track your browsing activity outside of the 4639club Platform.

8.1   4639club implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• TLS/SSL encryption for all data in transit between your device and our servers;
• Encryption of sensitive data fields (including identity documentation and financial account data) at rest;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Audit logging of access to sensitive player records;
• Regular security assessments and penetration testing of the Platform;
• Security awareness training for all 4639club staff who handle personal data; and
• Incident response procedures for detecting, reporting, and responding to personal data breaches in accordance with NPC notification requirements.

8.2   In the event of a personal data breach that is likely to give rise to a risk to the rights and freedoms of affected players, 4639club will notify the National Privacy Commission (NPC) and, where appropriate, affected players, in accordance with the timelines prescribed under R.A. 10173 and its Implementing Rules.

8.3   While 4639club implements robust security measures, no method of electronic transmission or storage is completely secure. You also bear responsibility for the security of your own 4639club account credentials. See Section 4 of the Terms & Conditions for account security obligations.

9.1   4639club retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable Philippine law.

9.2   The following retention periods apply as a general guide, subject to overriding legal or regulatory requirements:

• Account and identity data: Retained for the duration of the active account relationship, and for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA requirements;
• KYC documentation: Retained for the same period as account and identity data;
• Customer support records: Retained for three (3) years from the date of the interaction, or for the duration of any open dispute, whichever is later;
• Marketing consent records: Retained until you withdraw your consent plus a further two (2) years for record-keeping purposes; and
• Technical and log data: Typically retained for six (6) to twelve (12) months for Platform security and debugging purposes.

9.3   Where personal data is no longer required and there is no legal obligation to retain it, 4639club will securely delete or irreversibly anonymize that data using appropriate technical methods.

10.1   Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by 4639club:

10.2   To exercise any of the rights listed above, please submit a written request to the 4639club Data Protection Officer via the contact details in Section 14. We will respond to your request within fifteen (15) business days of receipt, consistent with our obligations under R.A. 10173.

10.3   4639club may be required to verify your identity before processing a data rights request to ensure we do not disclose personal data to an unauthorized person. We will ask for reasonable proof of identity for this purpose.

10.4   Certain rights may be limited where 4639club has an overriding legal obligation — for example, transaction records required to be retained under the AMLA cannot be erased on request.

11.1   4639club does not knowingly collect, use, or process personal data from individuals under twenty-one (21) years of age. The collection of any such data would be contrary to the PAGCOR minimum age requirement and the 4639club Terms & Conditions.

11.2   Where 4639club discovers or has reason to believe that personal data belonging to a person under 21 years of age has been collected, we will take immediate steps to delete that data and close the associated account in accordance with our Terms & Conditions.

11.3   If you believe that 4639club may have inadvertently collected personal data from a minor, please contact us immediately via the details in Section 14 so that appropriate action can be taken.

12.1   In connection with the operation of the 4639club Platform, some personal data may be processed or stored on servers or by service providers located outside the Philippines — for example, in connection with cloud hosting infrastructure or game content delivery.

12.2   Where personal data is transferred outside the Philippines, 4639club takes steps to ensure that appropriate safeguards are in place consistent with the requirements of R.A. 10173 and the National Privacy Commission's guidelines on cross-border data transfers. These safeguards include requiring contractual data protection obligations on the receiving party.

12.3   By registering a 4639club account, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside the Philippines in the circumstances described above, subject to the safeguards set out in this Section.

13.1   4639club may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR requirements. The revised Policy will be published on this page with an updated effective date.

13.2   Where a material change to this Policy affects the way we process your personal data, we will endeavor to notify registered players via the contact details on file or by posting a prominent notice on the Platform prior to the change taking effect.

13.3   Continued use of the 4639club Platform following the effective date of any revised Privacy Policy constitutes your acknowledgment of and agreement to the updated Policy. We encourage you to review this page periodically. The current version of this Policy is always accessible at https://4639club.net/privacy-policy.

14.1   If you have questions about this Privacy Policy, wish to exercise your data rights, or have a concern about how your personal data has been handled, please contact the 4639club Data Protection Officer:

14.2   If you are not satisfied with 4639club's response to your complaint or data rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the supervisory authority for data protection under R.A. 10173. The NPC's contact details and complaint procedures are published on the NPC website.

14.3   This Privacy Policy is effective as of January 1, 2026 and supersedes all prior versions.