635ph Privacy Policy

This Privacy Policy ("Policy") describes how 635ph ("635ph," "we," "our," or "us") collects, uses, stores, shares, and protects the personal data of individuals ("you," "your," or "Player") who access or use the 635ph website, mobile platform, games, sportsbook, and all associated services (collectively, the "Platform").

635ph is committed to protecting the privacy of every Filipino player on our platform. We recognise that trust is the foundation of a lasting relationship between a player and their gaming platform of choice — and that trust begins with being completely transparent about how your information is handled. This Policy is written in plain English so that every player across Manila, Cebu, Davao, and beyond can understand exactly what happens with their data.

By accessing the 635ph Platform, creating a player account, or otherwise using 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 any part of this Policy, please discontinue use of the Platform and contact our support team to request account closure.

This Policy should be read together with the 635ph Terms & Conditions, which are incorporated by reference and govern your overall use of the Platform.

635ph collects only the personal data that is necessary and proportionate to the purposes described in this Policy. The categories of personal data we collect are set out in the table below:

635ph does not collect sensitive personal information (as defined under the Philippine DPA) such as racial or ethnic origin, political opinions, religious beliefs, health records, or biometric data, except where identity verification procedures lawfully require documentary review of government-issued identification.

635ph collects personal data through the following channels:

• Direct Interactions: Data you provide when you register an account, complete KYC verification, make a deposit or withdrawal request, contact our support team, or participate in a promotion.
• Automated Technologies: When you use the 635ph Platform, we automatically collect certain technical data through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, device identifiers, and browsing behaviour within the Platform.
• Payment Providers: When you transact via GCash, PayMaya, BPI, BDO, or Metrobank, our payment processing partners transmit confirmation data to 635ph necessary to credit your account or process your withdrawal. Full payment credentials are never stored directly by 635ph.
• Identity Verification Partners: Where required for KYC compliance, 635ph may work with third-party identity verification providers who process copies of your identification documents on our behalf.
• Fraud Prevention and Security Partners: We may receive data about you from fraud detection services and security monitoring providers as part of our obligation to maintain a safe and compliant platform.

635ph processes your personal data only for specific, legitimate purposes. We do not use your data in ways that are incompatible with the purposes for which it was originally collected. The primary purposes for which 635ph uses your data are:

• Account Management: To create, maintain, and administer your 635ph player account, verify your identity, and provide you with access to our games and services.
• Payment Processing: To process deposits, execute withdrawal requests, and maintain accurate financial records of all transactions associated with your account.
• Regulatory Compliance: To satisfy our obligations under Philippine anti-money laundering laws, gaming regulations, and data protection legislation — including maintaining the records required by PAGCOR and other competent authorities.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, multi-accounting, bonus abuse, money laundering, and other prohibited conduct on the Platform.
• Responsible Gaming: To monitor player behaviour for indicators of problem gambling and to apply the responsible gaming tools and interventions required under our player protection obligations.
• Customer Support: To respond to your queries, resolve disputes, and improve the quality and efficiency of our support services.
• Platform Improvement: To analyse usage patterns, troubleshoot technical issues, and develop new features that enhance the 635ph experience for Filipino players.
• Marketing Communications: To send you promotional emails, SMS messages, or in-platform notifications about 635ph bonuses, new games, and special offers — but only where you have provided explicit consent and not withdrawn it.

Under the Philippine Data Privacy Act of 2012, 635ph is required to have a valid legal basis for each category of personal data processing we undertake. The legal bases on which 635ph relies are as follows:

• Contractual Necessity: Processing required to fulfil our contractual obligations to you as a registered 635ph player — including account management, payment processing, and service delivery.
• Legal Obligation: Processing necessary for compliance with applicable Philippine law, including anti-money laundering requirements, gaming regulations, and tax obligations.
• Legitimate Interests: Processing carried out for 635ph's legitimate business interests where those interests are not overridden by your data protection rights — such as fraud prevention, platform security, and responsible gaming monitoring.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

Where 635ph relies on legitimate interests as the legal basis for processing, we have carried out a balancing assessment to confirm that our interests do not override your fundamental rights and freedoms under the DPA.

635ph does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. Period. Your data is shared only in the following limited and controlled circumstances:

• Payment Processors: GCash, PayMaya, BPI, BDO, and Metrobank receive only the transactional data necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and applicable Philippine financial regulations.
• Identity Verification Providers: Third-party KYC verification services receive identity document data solely for the purpose of verifying your identity in compliance with our regulatory obligations. These providers are bound by data processing agreements with 635ph.
• Fraud Prevention and Security Services: We share limited technical and account data with security monitoring providers to detect and prevent fraud, money laundering, and other prohibited activities.
• Regulatory and Law Enforcement Authorities: 635ph is legally obligated to disclose relevant personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities when required by law, court order, or regulatory mandate.
• Business Transfers: In the event of a merger, acquisition, or sale of all or a substantial portion of 635ph's assets, your personal data may be transferred to the acquiring entity. You will be notified in advance of any such transfer and of any changes to this Privacy Policy that result from it.

635ph retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. Our retention periods are as follows:

• Active Account Data: Retained for the full duration of your account's active status plus a minimum of five (5) years following account closure, in compliance with Philippine AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• KYC and Identity Documents: Retained for five (5) years following account closure or the end of the business relationship, whichever is later.
• Support Communications: Live chat transcripts and support emails are retained for three (3) years for dispute resolution and quality assurance purposes.
• Marketing Consent Records: Records of your marketing consent and opt-out history are retained indefinitely to demonstrate compliance with consent obligations.
• Technical Logs: Server and access logs are retained for twelve (12) months for security and fraud investigation purposes, then securely deleted.

When your personal data is no longer required and the applicable retention period has expired, 635ph securely destroys or anonymises that data in accordance with our internal data disposal procedures.

635ph uses cookies and similar tracking technologies (such as web beacons and local storage) on the Platform. This section explains what cookies we use and why.

What are cookies? Cookies are small text files placed on your device when you visit a website. They allow the website to recognise your device across sessions and store certain preferences or information about your interactions.

635ph uses the following categories of cookies:

• Strictly Necessary Cookies: These are essential for the Platform to function. They include session authentication cookies that keep you logged in, security tokens that protect against cross-site request forgery, and load-balancing cookies. These cookies cannot be disabled without breaking the Platform.
• Functional Cookies: These remember your preferences — such as your preferred language or display settings — to personalise your experience on the Platform.
• Analytics Cookies: We use first-party analytics tools to understand how players navigate the Platform, which pages are most visited, and where technical issues occur. This data is aggregated and anonymised where possible and is used solely to improve the 635ph experience.

You can control cookie settings through your browser preferences. Blocking strictly necessary cookies may prevent you from using certain features of the 635ph Platform. Blocking functional or analytics cookies will not prevent you from using the Platform but may affect your experience.

635ph treats the security of your personal data as a non-negotiable operational priority. We implement a comprehensive set of technical and organisational security measures designed to protect your data against unauthorised access, disclosure, alteration, loss, or destruction.

Our security infrastructure includes, but is not limited to, the following measures:

• Encryption in Transit: All data transmitted between your device and the 635ph Platform is encrypted using Transport Layer Security (TLS) protocol. Our platform enforces HTTPS across all pages and API endpoints.
• Encryption at Rest: Sensitive personal data stored in our databases — including identity documents, financial reference data, and authentication credentials — is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within 635ph's internal systems is strictly controlled on a need-to-know basis. All staff with access to player data undergo background screening and regular data protection training.
• Multi-Factor Authentication: 635ph supports and encourages the use of two-factor authentication (2FA) on all player accounts to provide an additional layer of account security beyond your password.
• Intrusion Detection and Monitoring: Our infrastructure is monitored 24/7 for anomalous activity, intrusion attempts, and suspicious patterns. Security incidents are escalated immediately to our dedicated security response team.
• Regular Security Audits: 635ph conducts periodic internal and third-party security audits of its platform and data handling procedures to identify and remediate vulnerabilities proactively.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 635ph. We are committed to honouring these rights promptly and without unnecessary barriers.

• Right to Be Informed: The right to know whether 635ph holds personal data about you, and to receive clear information about how it is being used — which is the primary purpose of this Privacy Policy.
• Right to Access: The right to request a copy of the personal data that 635ph holds about you. We will provide this within thirty (30) days of receiving a valid request.
• Right to Rectification: The right to request correction of any personal data held by 635ph that is inaccurate, incomplete, or out of date. Many basic details (such as your contact number or email address) can be updated directly from your account settings.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent (and no other legal basis applies), or where the data has been processed unlawfully. Note that this right is subject to our legal obligation to retain certain records under Philippine AML and gaming regulations.
• Right to Object: The right to object to the processing of your personal data for marketing purposes at any time. You may also object to processing based on legitimate interests on grounds relating to your particular situation.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where processing is based on consent or contract and is carried out by automated means.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that 635ph has processed your personal data in breach of the DPA.

The 635ph Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine regulations governing casino-style online gaming. 635ph does not knowingly collect, store, or process personal data from individuals under the age of 21.

If 635ph becomes aware, through any means, that a player is under 21 years of age, the account will be immediately suspended, all funds will be returned to the payment method used for deposit (net of any bonuses), and all personal data associated with the account will be securely deleted as soon as our legal record-keeping obligations permit.

635ph's primary operations, data storage infrastructure, and player data are maintained within, or in jurisdictions that provide an adequate level of data protection equivalent to or exceeding the standards required under the Philippine Data Privacy Act of 2012.

In certain cases, it may be necessary for 635ph to transfer your personal data to third-party service providers or infrastructure partners located outside the Philippines — for example, in connection with cloud hosting, identity verification, or fraud prevention services. When such transfers occur, 635ph ensures that appropriate safeguards are in place, including:

• Contractual data processing agreements that impose DPA-equivalent data protection obligations on the receiving party.
• Transfer only to jurisdictions that the NPC has recognised as providing an adequate level of data protection, or where specific contractual protections have been put in place.
• Strict limitation of transferred data to only what is necessary for the specific processing purpose.

By using the 635ph Platform and accepting this Privacy Policy, you acknowledge and consent to the transfer of your personal data in accordance with the safeguards described in this section.

635ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory guidance from the National Privacy Commission.

When material changes are made to this Policy, 635ph will provide notice via a prominent announcement on the Platform and, where appropriate, by email to your registered address. The "Effective Date" at the top of this Policy will be updated to reflect the date on which the revised Policy takes effect.

Your continued use of the 635ph Platform following the effective date of any amended Privacy Policy constitutes your acceptance of the revised terms. If you do not accept the revised Policy, you should discontinue use of the Platform and contact our support team to arrange account closure.

We encourage all 635ph players to review this Privacy Policy periodically to stay informed about how we are protecting your data.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 635ph handles your personal data, please contact us. Our Filipino support team and Data Protection Officer are available to assist you 24 hours a day, 7 days a week.

For complaints that have not been resolved to your satisfaction through our internal process, you have the right to escalate your concern to the National Privacy Commission of the Philippines (NPC), which serves as the supervisory authority for data protection matters under RA 10173.

635ph takes all privacy complaints seriously. Every complaint received is logged, acknowledged within 72 hours, and investigated thoroughly by a qualified member of our compliance team. We are committed to resolving all legitimate privacy concerns fairly and in a timely manner — because at 635ph, the trust of every Filipino player is something we work to earn every single day.