638club Privacy Policy

1. Data Controller

For the purposes of this Privacy Policy and the Philippine Data Privacy Act of 2012 (RA 10173), the data controller responsible for your personal information is 638club, operating the platform accessible at 638club.vip.

638club processes personal data within the PAGCOR regulatory framework and is subject to the oversight of the National Privacy Commission (NPC) of the Philippines. Any questions regarding the processing of your personal data by 638club should be directed to our Data Protection Officer using the contact details provided at the end of this Policy.

2. Personal Data We Collect

638club collects the following categories of personal data from players who register and use the platform:

Identity Data

• Full legal name as it appears on a government-issued ID;
• Date of birth (used to verify the 21+ age requirement);
• Government-issued identification number (e.g., PhilSys ID, passport, driver's licence, UMID);
• Photograph or scan of identity documents where required for KYC verification.

Contact Data

• Email address;
• Mobile phone number;
• Residential address (barangay, city/municipality, province, postal code).

Financial Data

• GCash or PayMaya mobile wallet number;
• Bank account details (BPI, BDO, Metrobank, or other BSP-registered banks) where used for deposit or withdrawal;
• Transaction history on the 638club platform including deposits, withdrawals, and wager records.

Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session duration, login timestamps, and navigation patterns within the 638club platform;
• Game history, bet amounts, and outcomes;
• Cookies and similar tracking technologies as described in Section 10.

3. How We Collect Your Data

638club collects personal data through the following means:

• Direct collection — information you provide when registering your 638club account, completing KYC verification, contacting customer support, or participating in promotions;
• Automated collection — data collected automatically as you use the 638club platform, including device data, session data, and game activity logs;
• Third-party sources — identity verification data received from KYC service providers, fraud prevention databases, and payment processors to comply with PAGCOR anti-money laundering obligations;
• Cookies and tracking technologies — as described in Section 10 of this Policy.

4. Purposes of Processing

638club processes your personal data for the following purposes:

• Account creation and management — to register and maintain your 638club account, verify your identity, and authenticate your access;
• Transaction processing — to process deposits, withdrawals, and bonus payments in Philippine Peso via GCash, PayMaya, and bank channels;
• Regulatory compliance — to fulfil obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine law;
• Age verification — to confirm that all players are aged 21 years and above as required under Philippine gaming regulations;
• Fraud prevention and security — to detect, investigate, and prevent fraudulent activity, money laundering, and unauthorized account access;
• Responsible gaming — to monitor gaming patterns that may indicate problem gambling and to facilitate self-exclusion and limit-setting tools;
• Customer support — to respond to your enquiries, resolve disputes, and improve the 638club service;
• Marketing communications — to send you promotional offers and updates where you have provided consent and with an option to unsubscribe at any time;
• Platform improvement — to analyse usage patterns and improve the 638club user experience.

5. Legal Basis for Processing

638club processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity — processing necessary to perform the contract between you and 638club when you register an account and use the platform;
• Legal obligation — processing required to comply with PAGCOR regulations, AMLA obligations, NPC requirements, and other applicable Philippine law;
• Legitimate interests — processing for fraud prevention, platform security, and responsible gaming monitoring, balanced against your privacy interests;
• Consent — processing for marketing communications and non-essential cookies, where you have provided clear, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

638club does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share personal data only in the following circumstances and strictly on a need-to-know basis:

• Payment processors — GCash (GXI), Maya Philippines (PayMaya), BPI, BDO, Metrobank, and other payment service providers, solely to process financial transactions you initiate;
• KYC and identity verification providers — third-party identity verification services engaged by 638club to perform document checks as required by PAGCOR;
• Game providers — game platform providers such as JILI Technology, PG Soft, and Pragmatic Play receive limited game-session data necessary to deliver their games within the 638club platform;
• Regulatory and law enforcement authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government authorities where required by law or regulatory directive;
• Professional advisers — legal counsel, auditors, and compliance consultants engaged by 638club, under strict confidentiality obligations;
• Business successors — in the event of a merger, acquisition, or sale of assets, subject to the acquiring entity assuming the obligations of this Privacy Policy.

All third parties with whom 638club shares personal data are contractually required to maintain the confidentiality and security of that data and to process it only for the purposes for which it was shared.

7. Data Retention

638club retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulation. Specific retention periods include:

• Account and identity data — retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR and AMLA requirements;
• Financial transaction records — retained for a minimum of five (5) years as required under the Anti-Money Laundering Act;
• Game history and wagering records — retained for a minimum of three (3) years;
• Customer support communications — retained for two (2) years from the date of the interaction;
• Marketing consent records — retained for the period during which you remain subscribed and for one (1) year thereafter.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 638club's data disposal procedures.

8. Security Measures

638club implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 638club platform;
• Encryption at rest for sensitive personal and financial data stored on 638club servers;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Regular security assessments, vulnerability scanning, and penetration testing;
• Incident response procedures and breach notification protocols aligned with NPC requirements.

While 638club takes reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your 638club login credentials and for reporting any suspected unauthorized account access to 638club support immediately.

9. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 638club:

• Right to be informed — to be notified of how your personal data is collected, used, and processed;
• Right of access — to request a copy of the personal data 638club holds about you;
• Right to rectification — to request correction of inaccurate or incomplete personal data;
• Right to erasure or blocking — to request deletion or blocking of personal data where processing is no longer necessary or lawful, subject to applicable legal retention requirements;
• Right to data portability — to receive your personal data in a structured, commonly used format where technically feasible;
• Right to object — to object to processing based on legitimate interests or for direct marketing purposes;
• Right to withdraw consent — to withdraw consent for processing based on consent, without affecting prior processing;
• Right to lodge a complaint — to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe 638club has violated your data privacy rights.

To exercise any of these rights, contact 638club's Data Protection Officer using the contact details in Section 14. 638club will respond to verified requests within fifteen (15) working days.

10. Cookies & Tracking Technologies

638club uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit 638club.vip.

638club uses the following categories of cookies:

• Strictly necessary cookies — required for the platform to function, including session authentication and security tokens. These cannot be disabled;
• Functional cookies — used to remember your preferences such as language and display settings;
• Analytics cookies — used to understand how players interact with the 638club platform, helping us improve navigation, game discoverability, and platform performance. Data is aggregated and anonymised;
• Marketing cookies — used, with your consent, to personalise promotional content within the 638club platform based on your gaming activity and preferences.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using the 638club platform but may affect certain features and personalisation.

11. Minors & Age Restriction

If you believe a minor has created an account on the 638club platform, please notify us immediately at the contact details in Section 14. 638club takes its obligations regarding minors seriously and will act without delay on credible reports.

12. International Data Transfers

638club primarily processes personal data within the Philippines. Where personal data is transferred to or accessed from outside the Philippines — for example, by game providers or technology infrastructure providers with servers in other countries — 638club ensures that appropriate safeguards are in place, including contractual data processing agreements that require the recipient to maintain standards equivalent to those required by the Philippine Data Privacy Act.

638club will not transfer your personal data to a country or territory that the National Privacy Commission has determined does not provide an adequate level of data protection, without your explicit consent or without appropriate contractual safeguards in place.

13. Changes to This Privacy Policy

638club reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, 638club will notify registered players via email or through a prominent notice on the 638club platform prior to the changes taking effect.

The most current version of this Privacy Policy will always be accessible at 638club.vip/privacy-policy. The "Last Updated" date at the top of this Policy indicates when it was most recently revised. Continued use of the 638club platform following notification of changes constitutes your acknowledgement of the revised Policy.

14. Contact & Data Protection Officer

For questions, requests to exercise your data rights, or concerns regarding this Privacy Policy or 638club's data practices, please contact our Data Protection Officer:

If you are not satisfied with 638club's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).