1. Introduction
638jl ("638jl," "we," "us," "our") is committed to protecting the privacy and personal data of all individuals who access or use the 638jl Platform at 638jl.club ("Platform"). This Privacy Policy ("Policy") describes how 638jl collects, uses, discloses, retains, and protects personal information in connection with the operation of the Platform and the provision of online gaming services to Filipino players.
This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Republic of the Philippines ("DPA"), and its Implementing Rules and Regulations, as well as applicable issuances of the National Privacy Commission ("NPC"). By registering an account on 638jl, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.
This Policy forms part of and should be read together with the 638jl Terms & Conditions. Terms not defined in this Policy have the meanings given to them in the Terms & Conditions.
2. Data Controller
For the purposes of the DPA and this Policy, 638jl acts as the Personal Information Controller in respect of personal data collected from players and visitors through the Platform. 638jl is responsible for determining the purposes and means of processing your personal data and for ensuring that such processing complies with applicable Philippine data protection law.
Where 638jl engages third-party service providers who process personal data on its behalf — such as payment processors, KYC verification providers, and technology infrastructure partners — those providers act as Personal Information Processors and are bound by contractual obligations to handle data only as directed by 638jl and in accordance with appropriate security standards.
3. Personal Data We Collect
638jl collects personal data that is necessary for the operation of the Platform, the provision of gaming services, and compliance with applicable legal and regulatory obligations. The categories of personal data collected include:
- Registration Data: Full name, date of birth, username, email address, mobile number (Smart, Globe, or DITO), and chosen password (stored in hashed form only).
- Identity Verification (KYC) Data: Government-issued photo identification (e.g., PhilSys National ID, passport, driver's licence), selfie photograph, proof of address, and TIN where required for tax reporting purposes.
- Financial Data: GCash account details, Maya account details, bank account information (BPI, BDO, Metrobank, and others), transaction history, deposit amounts, withdrawal amounts, and cashier activity logs.
- Gaming Activity Data: Game session logs, bet history, win/loss records, bonus usage, promotional participation, and responsible gaming tool settings.
- Technical Data: IP address, device type, operating system, browser type and version, screen resolution, session duration, pages visited, and referring URL.
- Communications Data: Records of live chat interactions, email correspondence, and any support tickets submitted to the 638jl support team.
- Geolocation Data: Approximate geolocation derived from IP address, used to verify that access to the Platform originates from a permitted jurisdiction.
4. How We Collect Your Data
638jl collects personal data through the following channels and methods:
- Direct Submission: Data you provide when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion.
- Automated Collection: Technical and usage data collected automatically through server logs, cookies, pixel tags, and similar tracking technologies when you access and navigate the Platform.
- Third-Party Sources: Identity verification data obtained from KYC service providers for fraud prevention and regulatory compliance. Financial verification data received from payment processors when processing your deposits and withdrawals via GCash, Maya, InstaPay, or bank transfer.
- Regulatory Sources: Data received from PAGCOR or other Philippine regulatory authorities in connection with licensing compliance, problem gambling identification, or fraud reporting obligations.
5. How We Use Your Personal Data
638jl uses the personal data it collects for the following purposes:
- To create, maintain, verify, and manage your 638jl player account.
- To process deposits and withdrawals via GCash, Maya, and other accepted Philippine payment methods.
- To verify your identity and age (21+) in compliance with PAGCOR licensing requirements and Philippine AML law.
- To deliver, operate, and improve the games, features, and services available on the 638jl Platform.
- To detect, investigate, and prevent fraud, money laundering, cheating, and other prohibited conduct.
- To administer bonuses, promotions, and loyalty programme benefits.
- To provide customer support via live chat and email, including resolving account, payment, and gaming disputes.
- To send you transactional notifications (e.g., deposit confirmations, withdrawal processing updates, account security alerts) via email or SMS to your registered mobile number.
- To send you promotional communications where you have given consent to receive such communications.
- To monitor compliance with responsible gaming obligations and to implement player-requested account restrictions such as deposit limits, loss limits, cool-down periods, and self-exclusion.
- To comply with applicable legal, regulatory, and tax reporting obligations imposed by Philippine authorities including PAGCOR, the AMLC, and the BIR.
6. Legal Basis for Processing
638jl processes your personal data on the following legal bases under the DPA:
- Contractual Necessity: Processing required to perform the contract between you and 638jl — including account creation, payment processing, game delivery, and customer support.
- Legal Obligation: Processing required to comply with applicable Philippine law — including PAGCOR licensing conditions, AML obligations under RA 9160 as amended, KYC requirements, and tax reporting obligations.
- Legitimate Interest: Processing for fraud prevention, platform security, abuse detection, and improvement of 638jl services, where these interests are not overridden by your data protection rights.
- Consent: Processing for marketing and promotional communications, where your prior opt-in consent has been obtained. You may withdraw this consent at any time by contacting support.
7. Data Sharing & Disclosure
638jl does not sell, rent, or trade your personal data to third parties for independent marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:
- Payment Processors: GCash (G-Xchange Inc.), Maya (PayMaya Philippines), BancNet, and other payment network operators involved in processing your deposits and withdrawals.
- KYC & Fraud Prevention Providers: Identity verification and fraud screening services engaged by 638jl to fulfil regulatory KYC obligations.
- Technology Infrastructure Providers: Cloud hosting, CDN, and database services that store or transmit Platform data under appropriate data processing agreements.
- Game Content Providers: Game studios (e.g., JILI, PG Soft, Pragmatic Play) may receive anonymised session data necessary for game delivery and technical support; they do not receive personally identifiable information.
- Regulatory Authorities: PAGCOR, AMLC, NPC, BIR, and other Philippine government agencies, where disclosure is required by law, court order, or regulatory demand.
- Professional Advisers: Legal counsel, auditors, and accountants engaged by 638jl under professional confidentiality obligations.
8. Cookies & Tracking Technologies
The 638jl Platform uses cookies and similar tracking technologies to enhance user experience, maintain sessions, and collect analytics data. The types of cookies used include:
- Strictly Necessary Cookies: Required for the Platform to function, including session authentication cookies that keep you logged in during your 638jl session.
- Performance Cookies: Used to measure page load times, error rates, and user interaction patterns to improve Platform performance — particularly important for optimising the experience on Philippine mobile data connections.
- Analytics Cookies: Used to understand aggregated user behaviour, game popularity, and navigation patterns to guide product improvement decisions.
- Preference Cookies: Used to remember your language, display, and notification preferences across sessions.
You may manage or disable non-essential cookies through your browser settings. Note that disabling strictly necessary cookies may impair the functionality of the 638jl Platform, including the login process.
9. Data Retention
638jl retains personal data for as long as is necessary for the purposes described in this Policy, subject to the following minimum retention periods required by applicable law:
- Account and KYC Records: Retained for a minimum of 5 years following account closure, as required by PAGCOR licensing conditions and AML regulations.
- Financial Transaction Records: Retained for a minimum of 5 years from the date of the transaction, in compliance with AMLC reporting obligations.
- Gaming Activity Logs: Retained for a minimum of 3 years to support dispute resolution and regulatory audit requirements.
- Support Communications: Retained for a minimum of 2 years to facilitate follow-up and audit trail purposes.
- Technical and Log Data: Retained for up to 12 months for security monitoring and fraud detection purposes.
Upon expiry of the applicable retention period, 638jl will securely delete or anonymise your personal data, unless further retention is required by a specific legal obligation or ongoing regulatory investigation.
10. Security Measures
638jl implements technical and organisational security measures appropriate to the risk level associated with processing player personal data on an online gaming platform. These measures include:
- TLS/SSL encryption for all data in transit between your device and the 638jl Platform.
- AES-256 encryption for personal data at rest in 638jl databases.
- Hashed and salted storage of account passwords — plain-text passwords are never stored or accessible to 638jl staff.
- Role-based access controls restricting employee access to personal data to the minimum required for their job function.
- Regular penetration testing and security audits of Platform infrastructure.
- Two-factor authentication (2FA) available to all players to protect their 638jl login credentials.
While 638jl takes data security seriously, no online system is entirely immune to risk. In the event of a data breach affecting your personal data, 638jl will notify the NPC and affected individuals in accordance with NPC Circular 16-03 within the required notification period.
11. Your Data Subject Rights
As a data subject under the Philippine Data Privacy Act, you have the following rights in respect of your personal data held by 638jl:
- Right to be Informed: The right to know whether 638jl holds personal data about you and the general purposes for which it is processed — which this Policy fulfils.
- Right of Access: The right to request a copy of the personal data 638jl holds about you.
- Right to Rectification: The right to request correction of inaccurate or incomplete personal data in your 638jl account.
- Right to Erasure: The right to request deletion of your personal data, subject to 638jl's legal retention obligations described in Section 9.
- Right to Restrict Processing: The right to request that 638jl limit the processing of your personal data in certain circumstances.
- Right to Data Portability: The right to receive your personal data in a structured, commonly used format for transfer to another service, where technically feasible.
- Right to Object: The right to object to processing based on legitimate interests, including direct marketing.
- Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission if you believe your data protection rights have been violated.
To exercise any of the above rights, please contact 638jl via live chat or email at [email protected]. Requests will be acknowledged within 3 business days and resolved within 30 days, in accordance with NPC guidelines.
12. Children and Minors
The 638jl Platform is strictly intended for individuals who are 21 years of age or older. 638jl does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete such data and close the associated account.
If you believe that a minor has accessed or registered on the 638jl Platform, please notify us immediately via live chat or at [email protected] so that appropriate action can be taken without delay.
13. Changes to This Privacy Policy
638jl reserves the right to update or modify this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, Platform features, or data processing practices. Material changes will be notified to registered players via the Platform's announcement section and, where appropriate, by email to the registered address on file. The "Last Updated" date at the top of this page will be revised to reflect the effective date of the updated Policy.
Your continued use of the 638jl Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the changes. If you do not accept the updated Policy, you must cease using the Platform and contact support to close your account.
14. Contact & Data Privacy Officer
For questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 638jl, please contact us through the following channels:
- Live Chat: Available 24/7 directly on the 638jl Platform — fastest response channel.
- Email: [email protected] — responses within 24 hours.
Data privacy requests submitted via email should include your registered username, the nature of your request, and a brief description of the personal data concerned, to enable us to locate and process your request efficiently.