39daph Privacy Policy

01 Introduction

39daph takes your privacy seriously. As an online casino and sports betting platform serving Filipino players, we understand that the personal data you share with us is sensitive and deserves the highest level of protection. This Privacy Policy has been prepared to give you a clear, honest, and complete picture of how 39daph handles your personal information — from the moment you register an account to the day you request its deletion.

This Policy is governed by the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules, as overseen by the National Privacy Commission (NPC). 39daph is also subject to data governance requirements set by the Philippine Amusement and Gaming Corporation (PAGCOR) as part of our operating licence obligations.

We encourage all 39daph players — whether you are based in Manila, Cebu, Davao, Quezon City, Makati, or anywhere else in the Philippines — to read this Policy in full. It is written in plain English so you can understand exactly what we do with your data and what choices you have.

02 Who We Are

For the purposes of this Privacy Policy, "39daph", "we", "us", and "our" refer to the operator of the 39daph online casino and sports betting platform at 39daph.org. 39daph is a PAGCOR-regulated gaming operator offering Filipino players access to slots, live dealer casino games, sports betting, bingo, sabong live streaming, and fishing games denominated in Philippine Peso (PHP).

39daph acts as the Personal Information Controller (PIC) under the Philippine Data Privacy Act — meaning we determine the purposes and means by which your personal data is processed. Certain third-party service providers who process data on our behalf are considered Personal Information Processors (PIP) and are bound by contractual data processing agreements with 39daph.

03 Data We Collect

39daph collects the following categories of personal data from players:

Category	Examples	Purpose
Identity Data	Full name, date of birth, nationality, government ID number (e.g., PhilSys, SSS, UMID, passport)	Account registration & KYC verification
Contact Data	Email address, mobile phone number, residential address	Account communication, support, fraud prevention
Financial Data	GCash number, PayMaya account, BPI/BDO/Metrobank account details, Visa card (masked), transaction history	Deposits, withdrawals, AML compliance
Gaming Data	Bet history, game sessions, win/loss records, bonus usage, session duration, wager amounts	Game delivery, responsible gaming monitoring, dispute resolution
Technical Data	IP address, device type, browser type, operating system, unique device identifiers	Platform security, fraud detection, service improvement
Usage Data	Pages visited, features used, clickstream data, session timestamps	Platform analytics, UX improvement
Communications Data	Live chat transcripts, support ticket records, email correspondence	Customer support, complaint resolution, audit trail

04 How We Collect Your Data

39daph collects your personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions;
• Automatically — when you use the 39daph platform, our systems automatically collect technical and usage data via cookies, log files, and analytics tools;
• From third parties — including identity verification service providers, payment processors (GCash, PayMaya, bank partners), fraud detection services, and PAGCOR where required for regulatory compliance;
• From game providers — our licensed game suppliers may provide aggregated gaming activity data to 39daph for the purpose of platform management and responsible gaming monitoring.

05 How We Use Your Data

39daph uses your personal data for the following purposes:

• To create and manage your 39daph account;
• To verify your identity and age (21+ as required by PAGCOR) during registration and KYC;
• To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and Visa;
• To deliver casino games, sports betting, bingo, sabong, and other platform features;
• To administer bonuses, promotions, and loyalty rewards;
• To monitor gameplay for responsible gaming purposes and apply player protection tools;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities;
• To comply with PAGCOR regulatory reporting obligations and applicable Philippine law;
• To communicate with you regarding account updates, security alerts, and support requests;
• To send promotional communications where you have opted in to receive them;
• To improve the 39daph platform through analytics and user experience research;
• To resolve disputes, enforce our Terms & Conditions, and maintain accurate audit records.

06 Legal Basis for Processing

Under the Philippine Data Privacy Act, 39daph processes your personal data on the following legal bases:

• Contractual necessity — processing required to fulfil our contractual obligations to you as a registered player, including account management, game delivery, and payment processing;
• Legal obligation — processing required to comply with PAGCOR regulations, AML laws, tax reporting obligations, and other applicable Philippine legal requirements;
• Legitimate interests — processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your data rights;
• Consent — processing for marketing communications and non-essential cookies, where you have given explicit opt-in consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

07 Sharing Your Data

39daph does not sell your personal data. We share your data only in the following limited circumstances:

7.1 Service Providers

We share data with carefully selected third-party service providers who assist us in operating the 39daph platform, including identity verification providers, payment processors, IT infrastructure providers, cloud hosting services, and customer support tools. All such providers are bound by data processing agreements that prohibit them from using your data for any purpose other than providing services to 39daph.

7.2 Game Suppliers

Licensed game providers whose titles are available on the 39daph platform may receive limited gaming session data necessary to deliver their games. These providers are subject to their own data protection obligations and are prohibited from using your data independently.

7.3 Regulatory Authorities

39daph is legally obligated to share player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and law enforcement agencies where required by Philippine law. Such disclosures are made only to the extent strictly necessary to meet our legal obligations.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of substantially all of 39daph's assets, your personal data may be transferred to the acquiring entity as part of that transaction, subject to equivalent data protection commitments.

08 Data Retention

39daph retains your personal data only for as long as necessary to fulfil the purposes outlined in this Privacy Policy, or as required by applicable law. The following general retention periods apply:

• Account data and KYC records: Retained for a minimum of 5 years following account closure, in accordance with PAGCOR and AMLC requirements;
• Financial transaction records: Retained for a minimum of 5 years following the date of each transaction, as required by AML and tax legislation;
• Gaming activity records: Retained for a minimum of 3 years following account closure for dispute resolution and audit purposes;
• Customer support communications: Retained for 2 years following the closure of a support interaction;
• Marketing consent records: Retained for the duration of your consent and 1 year thereafter as proof of consent.

When data is no longer required for any legitimate purpose, 39daph will securely delete or anonymise it in accordance with our internal data lifecycle management procedures.

09 Data Security

39daph implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption on all data transmitted between your browser and the 39daph platform;
• Encryption at rest for all stored personal data and financial records;
• Two-factor authentication (2FA) available for all player accounts;
• Role-based access controls ensuring that 39daph staff can only access player data to the extent required for their specific job function;
• Regular security audits and penetration testing conducted by independent cybersecurity professionals;
• Intrusion detection systems and real-time monitoring for suspicious platform activity;
• Staff training on data protection obligations and security awareness.

In the event of a data breach that poses a risk to your rights and freedoms, 39daph will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach and will inform affected players promptly in accordance with NPC notification guidelines.

10 Cookies & Tracking Technologies

39daph uses cookies and similar tracking technologies to operate the platform effectively, enhance your user experience, and gather anonymised analytics data. The following types of cookies are used:

• Strictly necessary cookies: Essential for the platform to function — including session management, login authentication, and security tokens. These cookies cannot be disabled without impairing platform functionality;
• Functional cookies: Remember your preferences, such as language settings and display options, to personalise your experience;
• Analytics cookies: Collect anonymised data about how players use the platform, which pages are visited most frequently, and where technical errors occur. This data is used solely to improve the 39daph platform;
• Marketing cookies: Used only where you have given explicit consent to receive personalised promotional communications. You may withdraw this consent at any time through your account settings.

You can manage your cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the 39daph platform.

11 Your Data Rights

Under the Philippine Data Privacy Act of 2012, all registered 39daph players have the following rights with respect to their personal data:

To exercise any of the above rights, please contact the 39daph Data Protection Officer (DPO) via in-platform live chat or at the email address provided in Section 15 of this Policy. We will respond to all data rights requests within 15 business days of receipt. In some cases, we may need to verify your identity before processing a request to protect against unauthorised access to your data.

12 Minors & Age Restriction

As part of our account registration process, 39daph requires all players to confirm that they are at least 21 years of age and to submit government-issued identity documents during KYC verification. Age verification is a mandatory step before any deposit or wagering activity is permitted on the platform.

Parents and guardians who believe that a minor may have registered on the 39daph platform should contact our support team immediately via in-platform live chat or at the email address in Section 15. We take such reports seriously and will act promptly.

13 Cross-Border Data Transfers

The 39daph platform primarily processes and stores player data within the Philippines. However, certain third-party service providers — including cloud infrastructure providers and game suppliers — may process data in other jurisdictions. Where such transfers occur, 39daph ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under Philippine law.

These safeguards may include standard contractual clauses, data processing agreements requiring compliance with applicable data protection standards, or transfers to jurisdictions recognised by the NPC as providing an adequate level of data protection.

By using the 39daph platform, you acknowledge that your personal data may be transferred to and processed in jurisdictions outside the Philippines as described above, subject always to the protections set out in this Privacy Policy.

14 Changes to This Privacy Policy

39daph reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players by posting a prominent notice on the 39daph platform and, where appropriate, by sending a notification to your registered email address.

The effective date at the top of this Policy will be updated whenever a revision is made. We encourage you to review this Policy periodically to stay informed about how 39daph protects your personal data. Continued use of the platform following the posting of a revised Privacy Policy constitutes your acceptance of the updated terms.

15 Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 39daph handles your personal data, please contact our Data Protection Officer (DPO):

• Live Chat: Available 24/7 directly within the 39daph platform — the fastest way to reach us
• Email: [email protected]
• Subject Line: Please include "Privacy Request" or "Data Rights" in your subject line for faster routing
• Support Hours: 24 hours a day, 7 days a week, Philippine Standard Time (PST)

If you are not satisfied with our response to a privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the national supervisory authority responsible for enforcing the Data Privacy Act of 2012.