This Privacy Policy explains how 4639club collects, uses, stores, discloses, and protects the personal information of players and visitors in compliance with Republic Act No. 10173 (Data Privacy Act of 2012) of the Philippines and applicable PAGCOR regulations. Your privacy matters to us — please read this document carefully.
4639club ("4639club", "we", "us", "our") operates the online gaming platform accessible at https://4639club.vip and any associated subdomains or mobile interfaces. In the course of providing gaming services to registered players and visitors in the Philippines, 4639club necessarily collects and processes personal information.
This Privacy Policy ("Policy") describes the categories of personal data we collect, the purposes for which we process that data, the parties with whom we may share it, the security measures we apply to protect it, how long we retain it, and the rights available to you as a data subject under Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations.
By registering an account on the 4639club platform, depositing funds, accessing any game, or otherwise using the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data processing practices described herein. This Policy should be read together with the 4639club Terms & Conditions and Responsible Gaming Policy.
For the purposes of the Data Privacy Act of 2012 and this Policy, the data controller responsible for your personal information is:
4639club
Platform: https://4639club.vip
Regulatory Authority: Philippine Amusement and Gaming Corporation (PAGCOR)
Data Protection Contact: [email protected]
The data controller determines the purposes and means of processing personal data collected through the 4639club platform. Where 4639club engages third-party service providers to process data on its behalf, those parties act as data processors under documented agreements that bind them to equivalent data protection standards.
The categories of personal data that 4639club collects and processes in connection with platform operations are set out in the table below:
| Category | Data Elements | Collection Point |
|---|---|---|
| Identity Data | Full name, date of birth, gender, nationality, government-issued ID type and number | Registration; KYC verification |
| Contact Data | Philippine mobile number, email address, residential address | Registration; account settings |
| Financial Data | GCash account number, PayMaya account number, bank account details (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records | Payment processing; KYC verification |
| Gaming Activity Data | Game sessions, bet history, win/loss records, bonus usage, session durations | Platform use; responsible gaming monitoring |
| Technical Data | IP address, device type, browser type and version, operating system, screen resolution, geolocation (approximate) | Automatic collection via platform access |
| Usage Data | Pages visited, links clicked, referral sources, session timestamps, navigation patterns | Cookies; server logs |
| Communications Data | Live chat transcripts, support email correspondence, feedback submissions | Customer support interactions |
| Verification Documents | Copies of government-issued IDs, utility bills, selfie verification images submitted for KYC purposes | KYC / AML compliance procedures |
4639club does not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance purposes. We do not collect biometric data, health information, religious affiliation, or political opinion data.
The majority of personal data we hold is provided directly by you during:
When you access the 4639club platform, certain technical and usage data is collected automatically through cookies, server logs, and similar technologies. This automated collection includes IP address, device identifiers, browser and operating system information, session timing, and navigation data. See Section 11 for the full cookies and tracking policy.
In limited circumstances, 4639club may receive personal data about you from third parties, including:
4639club processes your personal data for the following specific, legitimate purposes:
| Purpose | Description |
|---|---|
| Account Management | Creating, maintaining, and administering your 4639club player account, including authentication and security. |
| Identity Verification (KYC) | Verifying your identity and age (21+ requirement) in compliance with PAGCOR licensing conditions and Philippine AML regulations. |
| Payment Processing | Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other accepted payment methods. |
| Regulatory Compliance | Meeting obligations under PAGCOR licensing conditions, Philippine AML laws, and other applicable legislation including mandatory reporting requirements. |
| Responsible Gaming | Monitoring gaming activity to identify problematic gambling patterns and administering self-exclusion, deposit limit, and session time limit tools. |
| Fraud & Security | Detecting and preventing unauthorized account access, payment fraud, bonus abuse, multi-accounting, and other platform security threats. |
| Customer Support | Providing assistance through live chat and email, investigating complaints, and maintaining support records. |
| Platform Improvement | Analyzing aggregated usage data to improve platform performance, game selection, user experience, and localization for Philippine players. |
| Marketing Communications | Sending promotional offers, bonus notifications, and platform updates where you have provided consent. You may withdraw consent at any time. |
Under the Data Privacy Act of 2012 and its Implementing Rules, 4639club processes personal data on the following legal bases:
4639club engages third-party service providers who process data strictly on our behalf and under documented agreements that require them to maintain confidentiality and data protection standards equivalent to those in this Policy. These include:
4639club is legally required to share certain data with regulatory authorities including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies where mandated by law. Such sharing is limited to what is strictly required for the applicable regulatory purpose.
4639club may disclose your personal data where required to do so by a court order, subpoena, or other legally binding demand from a Philippine government authority. Where legally permissible, we will notify you before making such a disclosure.
In the event of a merger, acquisition, or sale of substantially all of 4639club's business assets, personal data held by 4639club may be transferred to the acquiring entity. You will be notified of any such transfer and any change to this Privacy Policy that may result.
Some of 4639club's service providers and game providers are located or operate infrastructure outside the Philippines. Where personal data is transferred internationally, 4639club implements appropriate safeguards to ensure that your data receives protection equivalent to that provided under Philippine law, including:
Where required by the National Privacy Commission, 4639club maintains records of cross-border data transfers and the safeguards applied to each.
4639club retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and PAGCOR regulations. The following retention schedule applies:
Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be linked to an identifiable individual. Where deletion is not immediately technically feasible (such as backup systems), data is isolated from active use pending deletion at the next scheduled cycle.
4639club applies a combination of technical and organizational security measures to protect your personal data against unauthorized access, loss, alteration, or disclosure. These measures include:
4639club uses cookies and similar tracking technologies on the platform. Cookies are small text files placed on your device that enable platform functionality and help us understand how the platform is used.
You can manage cookie preferences through your browser settings. Most modern browsers allow you to block, delete, or selectively accept cookies. Please note that disabling strictly necessary cookies will impair your ability to use the 4639club platform, including account login and payment functionality. Disabling other cookie types will not affect your ability to play but may reduce personalization and platform performance.
As a data subject under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by 4639club:
You have the right to request confirmation of whether 4639club processes personal data about you and, if so, to obtain a copy of that data along with information about how it is processed.
You have the right to request correction of inaccurate or incomplete personal data held about you. Some corrections can be made directly through your account settings; others require contacting support.
You have the right to request deletion of your personal data in certain circumstances, including where it is no longer necessary for the purposes for which it was collected. This right is subject to legal retention obligations — for example, AML-mandated financial records must be retained for five years.
You have the right to object to processing of your personal data for direct marketing purposes, including profiling for marketing. You may also object to processing based on legitimate interests where your individual circumstances justify it.
You have the right to receive a copy of personal data you have provided to 4639club in a structured, commonly used, machine-readable format, and to request transmission of that data to another controller where technically feasible.
You have the right to request restriction of processing in certain circumstances — for example, while a request for correction is being assessed, or where you have objected to processing and a determination on that objection is pending.
Where processing is based on your consent (for example, marketing communications), you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.
To exercise any of these rights, please contact the 4639club Data Protection team at [email protected]. 4639club will respond to data rights requests within thirty (30) days, or within the extended period permitted by law where complexity justifies it. Identity verification may be required before your request is processed. If you believe 4639club has not handled your personal data appropriately, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.
In accordance with PAGCOR regulations and Philippine law, 4639club enforces strict age verification as part of the account registration and KYC process. All users must confirm they are 21 or older at registration, and documentary proof of age may be required before withdrawal processing is approved.
If you are a parent or guardian and believe that a person under your care has registered a 4639club account without authorization, please contact us immediately at [email protected]. We will investigate promptly and take the necessary action.
The 4639club platform integrates games and content from third-party providers including Pragmatic Play, NetEnt, PG Soft, Play'n GO, Jili Games, CQ9 Gaming, and others. While these games are delivered through the 4639club platform, the underlying game engines are operated by their respective providers under their own licensing and data processing arrangements.
4639club implements contractual protections requiring game providers to handle any data accessed through game delivery in accordance with applicable privacy standards. However, 4639club is not responsible for the independent privacy practices of game providers. The minimum data passed to game providers is technical session data required to deliver the game — providers do not receive your full identity or financial data through the game integration.
The 4639club platform does not contain links to external third-party websites for navigational purposes. All navigation within the platform remains internal.
4639club processes gaming activity data specifically for the purpose of responsible gaming monitoring. This processing is a core obligation under PAGCOR licensing and reflects 4639club's genuine commitment to player wellbeing. Responsible gaming data processing includes:
This processing is conducted on the legal basis of legal obligation and legitimate interests. Responsible gaming data is not used for marketing purposes. For full details of the tools available and how to use them, see the Responsible Gaming page.
4639club reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, regulatory requirements, or platform operations. Where changes are material, we will notify registered players via the email address on file or through a prominent notice displayed on the platform prior to the changes taking effect.
The effective date and last updated date at the top of this Policy reflect the version currently in force. Previous versions of this Policy are available on request by contacting 4639club support. Continued use of the 4639club platform following the effective date of any updated Policy constitutes acceptance of the revised terms.
If you have any questions, concerns, or requests relating to this Privacy Policy or to 4639club's data processing practices, please contact us through the following channels:
Data Protection Queries
Email: [email protected] (mark subject: "Privacy / Data Request")
Live Chat: Available 24/7 from the 4639club platform
4639club aims to acknowledge all data-related requests within five (5) business days and to resolve them fully within thirty (30) calendar days, or within the extended period permitted by the DPA for complex requests.
If you are dissatisfied with 4639club's response to a data rights request or complaint, you have the right to refer the matter to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.
Six core commitments that define how we handle player data across every part of the 4639club platform.
Every data transmission between your device and 4639club — including login, payment processing, and personal information updates — is protected by SSL/TLS encryption. Your data travels securely across all connections.
4639club never sells, rents, or trades your personal data to third parties for marketing purposes. Data sharing is limited to service delivery, regulatory compliance, and fraud prevention — nothing beyond what this Policy explicitly describes.
All data processing at 4639club is conducted in compliance with Republic Act No. 10173 (Data Privacy Act of 2012) and supervised by the National Privacy Commission of the Philippines. Your rights under Philippine law are fully respected.
You can access, correct, delete, export, or restrict your 4639club data at any time by contacting the support team. Rights requests are acknowledged within five business days and resolved within thirty calendar days.
4639club collects only the personal data strictly necessary for account management, payment processing, regulatory compliance, and responsible gaming. Data minimization is applied at every stage of the platform's operation.
Personal data at 4639club is subject to defined retention periods based on regulatory requirements and operational necessity. Data is securely deleted or anonymized as soon as the applicable retention period expires.
PAGCOR-licensed. DPA-compliant. GCash and PayMaya accepted. Over 1,000 games available to Philippine players aged 21 and above.