39 gl Casino
Privacy Policy

01 Introduction and Scope

This Privacy Policy ("Policy") describes how 39 gl Casino ("39 gl," "we," "us," or "our") — the operator of the online gaming platform accessible at 39gl.club — collects, uses, discloses, stores, and protects the personal information of individuals ("you," "the Player," or "the User") who access, register with, or use the 39 gl platform and associated services.

This Policy applies to all personal data collected through the 39 gl website at 39gl.club, any mobile-optimized version of the Platform, customer support interactions, and any other channel through which 39 gl receives personal information from or about you.

39 gl is committed to protecting the privacy and security of your personal data in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (the "DPA"), its Implementing Rules and Regulations, and the circulars and advisories issued by the National Privacy Commission (NPC) of the Philippines. This Policy is intended to satisfy the transparency requirements of the DPA and to clearly communicate your rights as a data subject.

By registering for a 39 gl account or otherwise using the Platform, 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, you should discontinue use of the Platform.

02 Personal Data We Collect

39 gl collects various categories of personal data depending on your interaction with the Platform. The table below describes the main categories, specific data types, and the primary reason each is collected.

39 gl does not knowingly collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Specifically, 39 gl does not collect racial or ethnic origin, political opinions, religious beliefs, or biometric data except where biometric data is contained within a government-issued identity document submitted for KYC purposes.

03 How We Collect Your Data

39 gl collects personal data through the following channels:

3.1 Direct Collection

Data you provide directly during account registration (name, mobile number, date of birth), identity verification (government ID documents), financial transactions (payment method details), customer support interactions, and when responding to surveys or completing profile settings on the Platform.

3.2 Automated Collection

Technical data collected automatically when you access the 39 gl Platform — including your IP address, device identifiers, browser information, session duration, pages visited, and actions taken. This data is collected using standard web server logs, session tracking mechanisms, and cookies (described in Section 7 below).

3.3 Third-Party Sources

39 gl may receive personal data from third-party sources in limited circumstances, including:

• KYC and identity verification providers who process and verify your government-issued ID documents on 39 gl's behalf;
• Payment processors (GCash, Maya, BPI, BDO, Metrobank, and others) who confirm transaction status and may provide limited transaction metadata;
• Fraud detection service providers who may flag accounts or devices based on risk signals across their network;
• Regulatory authorities in the Philippines who may provide information relevant to compliance with applicable laws.

In all cases, 39 gl processes third-party-sourced data under the same standards and protections described in this Policy.

04 How We Use Your Personal Data

39 gl uses your personal data only for purposes that are directly relevant to providing, maintaining, improving, and securing the 39 gl Platform, or as required by law. Specific uses include:

• Account creation and authentication: Registering your account, verifying your mobile number via OTP, and authenticating you on each login to the 39 gl platform.
• Identity and age verification: Confirming that you meet the 21-year minimum age requirement and that your identity matches the information provided at registration, as required by PAGCOR standards and Philippine law.
• Financial transaction processing: Facilitating deposits from your GCash, Maya, or bank accounts, processing withdrawal requests, and maintaining accurate financial records of all transactions on your 39 gl account.
• Anti-money laundering (AML) compliance: Monitoring transactions and account activity for patterns consistent with money laundering or terrorist financing, and reporting suspicious activity to the Anti-Money Laundering Council (AMLC) as required by Philippine law.
• Fraud and abuse prevention: Detecting and preventing duplicate accounts, bonus abuse, collusion, the use of unauthorized automated tools, and other prohibited activities described in the 39 gl Terms & Conditions.
• Responsible gaming: Monitoring gameplay patterns for indicators of problem gambling, applying responsible gaming tools you have activated, and fulfilling 39 gl's obligations under its responsible gaming policy.
• Customer support: Responding to your inquiries, resolving disputes, and maintaining records of support interactions for quality and compliance purposes.
• Platform improvement: Analyzing aggregated, anonymized gameplay and usage data to identify areas for platform improvement, new game categories to introduce, and technical performance optimizations.
• Legal compliance: Meeting obligations under the Data Privacy Act of 2012, PAGCOR online gaming regulations, AMLC reporting requirements, and any other applicable Philippine law.
• Marketing communications (where consented): Sending you promotional offers, bonus notifications, and platform updates via SMS or email where you have opted in to receive such communications. You may opt out at any time.

05 Legal Basis for Processing

Under the Data Privacy Act of 2012, every processing of personal data must be grounded in a lawful criterion. 39 gl processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract with you — i.e., providing the gaming and related services described in the 39 gl Terms & Conditions. This covers account management, payment processing, and gameplay provision.
• Legal obligation: Processing necessary to comply with Philippine legal obligations, including PAGCOR regulatory requirements, the Anti-Money Laundering Act, and the Data Privacy Act of 2012 itself. This covers KYC verification, AML transaction monitoring, and regulatory reporting.
• Legitimate interests: Processing necessary for 39 gl's legitimate interests where these do not override your rights — including fraud prevention, platform security, responsible gaming monitoring, and internal analytics using anonymized data.
• Consent: Processing based on your freely given, specific, informed consent — this applies primarily to marketing communications and any non-essential data processing for which no other lawful basis applies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

06 Sharing Your Data with Third Parties

39 gl does not sell, rent, lease, or trade your personal data to third parties for their own commercial purposes. Data sharing is limited to the categories and recipients described below, all of whom are subject to contractual obligations requiring them to protect your personal data to a standard consistent with the DPA.

6.1 Service Providers

39 gl engages service providers who process personal data on 39 gl's behalf as data processors under the DPA. These include: payment gateway operators (GCash/GXI, Maya/Voyager Innovations, BancNet, InstaPay participants), KYC and identity verification service providers, cloud hosting and IT infrastructure providers, customer support platform providers, and fraud detection and cybersecurity service providers. All such providers are contractually bound to process data only as instructed by 39 gl and to implement appropriate security measures.

6.2 Regulatory and Law Enforcement Authorities

39 gl will disclose personal data to PAGCOR, AMLC, the National Privacy Commission, law enforcement agencies, or courts of competent jurisdiction when required to do so by applicable Philippine law, regulatory directive, court order, or lawful request. In such cases, 39 gl will disclose only the minimum information required and will notify you of the disclosure where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 39 gl's business, your personal data may be transferred to the acquiring entity as part of the transaction. In such circumstances, 39 gl will notify affected players before data is transferred and will ensure that any acquiring entity agrees to process personal data in accordance with this Privacy Policy or an equivalent standard.

07 Cookies and Tracking Technologies

39 gl uses cookies and similar technologies (collectively "Cookies") on the Platform to enable core functionality, improve performance, and — where you have consented — to support analytics and personalization.

7.1 Types of Cookies Used

• Essential Cookies: Strictly necessary for the Platform to function. These include session authentication cookies that maintain your login state, security cookies that prevent CSRF attacks, and cookies that remember your responsible gaming settings. These cannot be disabled without breaking core platform functionality.
• Functional Cookies: Enhance the Platform experience by remembering your preferences — such as your preferred language setting or last-visited game category. These are not strictly necessary but improve usability.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform — pages visited, features used, session duration — to help 39 gl improve the product. These are activated only where you have provided consent.
• Security and Fraud-Detection Cookies: Help 39 gl identify and respond to fraudulent or abusive activity, including account takeover attempts and bot activity. These are essential for Platform security.

7.2 Managing Cookies

You may manage non-essential cookie preferences through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when cookies are set. Please note that disabling essential cookies will impair your ability to use the 39 gl Platform and may prevent login functionality from working correctly.

39 gl does not use third-party advertising cookies or cross-site tracking cookies for targeted advertising purposes.

08 Data Retention

39 gl retains personal data for no longer than is necessary for the purposes for which it was collected, or as required by applicable Philippine law. The following retention guidelines apply:

• Account and identity data: Retained for the duration of your active account relationship with 39 gl, and for a period of five (5) years following account closure, as required for AML compliance under Republic Act No. 9160 (Anti-Money Laundering Act) and its amendments.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLC record-keeping requirements and standard financial audit obligations.
• KYC verification documents: Retained for the period required by PAGCOR regulatory guidelines and Philippine AML law, typically five (5) years from account closure or the last transaction date, whichever is later.
• Gameplay and session logs: Retained for a period of two (2) years, primarily to support dispute resolution. Aggregated anonymized data derived from gameplay logs may be retained indefinitely for analytical purposes.
• Customer support correspondence: Retained for two (2) years from the date of the last interaction, or longer where the correspondence relates to an active or potential dispute.
• Marketing consent records: Retained until you withdraw consent and for a reasonable period thereafter to demonstrate compliance with the DPA consent requirements.

At the end of the applicable retention period, personal data is securely deleted, destroyed, or anonymized in a manner that prevents reconstruction of the original data. Anonymized datasets from which you cannot be identified are not subject to retention limits.

09 Data Security Measures

39 gl implements a layered set of technical, organizational, and procedural security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Key measures include:

• Encryption in transit: All data transmitted between your device and 39 gl servers is protected using TLS (Transport Layer Security) with current industry-standard cipher suites. Unencrypted HTTP connections are not accepted.
• Encryption at rest: Personal data stored in 39 gl databases is encrypted at rest using AES-256 or equivalent encryption standards.
• Access controls: Access to systems containing personal data is restricted based on role and operational necessity. Multi-factor authentication is required for administrative access. Access logs are maintained and reviewed.
• Network security: 39 gl's infrastructure is protected by firewalls, intrusion detection systems, and regular penetration testing by independent security professionals.
• Data minimization: Only staff members with a documented business need can access personal data, and only to the extent necessary for their specific function.
• Incident response: 39 gl maintains a documented data breach response procedure. In the event of a personal data breach, 39 gl will notify affected individuals and the National Privacy Commission within the timeframes prescribed by the DPA where the breach is likely to result in risk to your rights and freedoms.

10 Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 39 gl. To exercise any of these rights, contact the 39 gl Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request."

39 gl will respond to all valid data subject rights requests within fifteen (15) business days of receipt. Where a request requires additional time due to complexity or volume, 39 gl will notify you within the initial period and provide an estimated completion date. Identity verification may be required before processing any data subject rights request to protect against fraudulent access to your personal data by third parties.

11 Children's Privacy and Age Restriction

The 39 gl Platform is strictly restricted to individuals who are twenty-one (21) years of age or older, in compliance with PAGCOR regulations governing online casino gaming in the Philippines. 39 gl does not knowingly collect personal data from individuals below the age of 21.

If 39 gl becomes aware that it has inadvertently collected personal data from a minor — whether through false information provided at registration or through a failure in the age verification process — it will take immediate steps to:

• Suspend and close the relevant account;
• Delete all personal data associated with that account;
• Investigate how the minor accessed the Platform and implement measures to prevent recurrence.

Parents or guardians who believe that a minor may have registered with 39 gl or provided personal data to the Platform should contact 39 gl support immediately at [email protected]. Requests of this nature are treated as a priority.

12 International Data Transfers

Some of the third-party service providers engaged by 39 gl — including cloud infrastructure providers, KYC verification platforms, and game software providers — may process or store personal data in jurisdictions outside the Philippines. When 39 gl transfers personal data outside the Philippines, it does so only where:

• The recipient country has been assessed as providing an adequate level of data protection by the National Privacy Commission or under applicable international standards;
• Appropriate safeguards are in place in the form of contractual data processing agreements that impose DPA-equivalent obligations on the receiving party; or
• The transfer is necessary for the performance of a contract with you (for example, where a game software provider's servers are located outside the Philippines).

Details of specific international data transfers and the safeguards in place may be requested from the 39 gl Data Protection Officer at [email protected].

13 Changes to This Privacy Policy

39 gl reserves the right to update or amend this Privacy Policy at any time to reflect changes in data processing practices, applicable law, regulatory requirements, or Platform functionality. Material changes to this Policy will be communicated to registered Players via the mobile number or email address associated with their 39 gl account, and/or through a prominent notice displayed on the Platform, no less than seven (7) days before the changes take effect.

Your continued use of the 39 gl Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree with the revised Policy, you must discontinue use of the Platform and may request account closure in accordance with the Terms & Conditions.

The effective date of the current version of this Policy is shown in the "Last Updated" field at the top of this document. The most current version is always available at 39gl.club/privacy-policy.

14 Contact and Data Protection Officer

39 gl has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have questions, concerns, or requests relating to your personal data, or if you wish to exercise your data subject rights, please contact the 39 gl DPO using the details below:

If you are not satisfied with 39 gl's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines, which is the supervisory authority responsible for the enforcement of the Data Privacy Act of 2012. The NPC can be contacted at privacy.gov.ph (please note: 39 gl is not permitted to provide a clickable external link to this resource in this document, but the NPC website is publicly accessible via any search engine).

This Privacy Policy was last updated on January 1, 2026 and supersedes all prior versions. Players who registered before this date and continue using the Platform are deemed to have accepted the updated Policy.