4639club Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 4639club ("we," "us," "our," or "the Platform") collects, uses, stores, discloses, and protects the personal information of users ("you," "your," or "Player") who access or use the 4639club website at 4639club.org and all associated services.

4639club is committed to protecting the privacy and security of your personal data. This Policy is drafted in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines.

By registering an account, accessing the Platform, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform immediately.

This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, which together form the complete agreement governing your use of 4639club.

2. Personal Data We Collect

4639club collects personal data that is necessary to provide our services, verify your identity, process financial transactions, and comply with applicable legal and regulatory obligations. The categories of personal data we collect include:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification number (e.g., SSS, PhilHealth, driver's license, or passport number).
• Contact Data: Email address, Philippine mobile number, and residential address (including city, province, and postal code).
• Account Data: Username, encrypted password, account preferences, and communication settings.
• Financial Data: Payment method details (e.g., GCash account number, PayMaya account, BPI or BDO account details), transaction history, deposit and withdrawal records, and account balance information.
• Gaming Data: Game history, betting activity, session duration, wagering patterns, and bonus usage records.
• Technical Data: IP address, device type, browser type and version, operating system, time zone, and other technical identifiers collected automatically when you access the Platform.
• Usage Data: Information about how you navigate and interact with the 4639club website, including pages visited, features used, and time spent on the Platform.
• Communications Data: Records of your correspondence with our customer support team, including chat logs, emails, and support ticket history.
• Verification Documents: Copies of government-issued identification documents submitted for Know Your Customer (KYC) and Anti-Money Laundering (AML) compliance purposes.

We collect this data directly from you during registration and account use, automatically through cookies and tracking technologies, and from third-party payment processors and identity verification services where applicable.

3. How We Use Your Personal Data

4639club uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your 4639club player account, including processing your registration and verifying your identity.
• Service Delivery: To provide access to our gaming products, process deposits and withdrawals, and deliver the features and functionality of the Platform.
• Identity Verification and KYC: To verify your identity and age (21+) in compliance with Philippine regulatory requirements and to prevent underage gambling.
• Financial Processing: To process deposits, withdrawals, and bonus payments, and to maintain accurate financial records of all transactions conducted on your account.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal or prohibited conduct.
• Legal and Regulatory Compliance: To comply with applicable Philippine laws and regulations, including AML obligations, data retention requirements, and any lawful requests from regulatory authorities or law enforcement agencies.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer self-exclusion and responsible gaming tools where requested.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the 4639club Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may opt out at any time.

4. Legal Basis for Processing

4639club processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you have agreed to, including providing gaming services and processing financial transactions.
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including AML, KYC, and data retention obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities, such as marketing communications and non-essential cookies, we rely on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing and Disclosure

4639club does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: Third-party payment service providers (including GCash, PayMaya, BPI, BDO, and Metrobank) to process deposits and withdrawals on your behalf.
• Identity Verification Providers: Third-party KYC and AML compliance service providers engaged to verify your identity and screen against sanctions lists.
• Technology and Infrastructure Providers: Cloud hosting, data storage, and IT service providers who process data on our behalf under strict data processing agreements.
• Regulatory Authorities: Government agencies, regulatory bodies, and law enforcement authorities in the Philippines where disclosure is required by law or in response to a lawful request.
• Professional Advisors: Legal counsel, auditors, and other professional advisors where necessary for the conduct of our business operations.

All third parties with whom we share personal data are required to maintain appropriate security measures and to process your data only for the specified purposes and in accordance with our instructions.

6. Data Retention

4639club retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

In general, account data and transaction records are retained for a minimum of five (5) years following the closure of your account, in compliance with Philippine AML regulations. Identity verification documents are retained for the period required by applicable law.

Where personal data is no longer required for any lawful purpose, it will be securely deleted or anonymized in accordance with our data retention schedule.

7. Your Data Rights

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

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed.
• Right of Access: The right to request a copy of the personal data we hold about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to our legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer via email at: [email protected]. We will respond to all verified requests within thirty (30) days.

8. Cookies and Tracking Technologies

4639club uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and deliver relevant content. The types of cookies we use include:

• Essential Cookies: Necessary for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Analytics Cookies: Used to collect aggregated, anonymized data about how users interact with the Platform, helping us improve performance and usability.
• Preference Cookies: Used to remember your settings and preferences, such as language and display options.
• Marketing Cookies: Used to deliver relevant promotional content, subject to your consent.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform.

9. Data Security

4639club implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to, SSL/TLS encryption for data in transit, encrypted storage of sensitive data at rest, access controls and authentication requirements for internal systems, regular security assessments and vulnerability testing, and staff training on data protection obligations.

While we take all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 4639club will notify you and the National Privacy Commission in accordance with applicable legal requirements.

10. Children's Privacy

The 4639club Platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you believe that a minor has registered on the Platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

11. Third-Party Links

The 4639club Platform may contain links to third-party websites or services. This Privacy Policy applies solely to the 4639club Platform and does not cover the privacy practices of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit, as 4639club has no control over and accepts no responsibility for their content or privacy practices.

12. Updates to This Privacy Policy

4639club reserves the right to update or modify this Privacy Policy at any time. When changes are made, the revised Policy will be posted on this page with an updated "Last Updated" date. We may also notify you of significant changes via email or through a notice on the Platform.

Your continued use of the 4639club Platform following the posting of any changes constitutes your acceptance of the updated Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]

We aim to respond to all data privacy inquiries within fifteen (15) business days. For formal complaints or requests to exercise your data rights, you may also submit a written request to our registered address in the Philippines.

// end_of_document · 4639club Privacy Policy · effective 2026-01-01