69club Privacy Policy

1 Introduction

69club is committed to protecting the privacy and personal data of every player who uses our Platform. We recognize that your personal information belongs to you, and we take our obligations as a personal information controller under Philippine law seriously. This Policy applies to all personal data collected through the Platform, including data submitted during registration, identity verification, financial transactions, gameplay, customer support interactions, and any other engagement with 69club services.

This Policy should be read together with our Terms and Conditions and our Responsible Gaming Policy, both of which are accessible on the Platform. Capitalized terms not defined in this Policy have the meanings given to them in our Terms and Conditions.

If you are a resident of Manila, Cebu, Davao, Quezon City, Makati, or anywhere across the Philippines, the protections described in this Policy apply to you in full under Republic Act No. 10173 and its implementing regulations.

2 Information We Collect

69club collects personal information through several channels. The categories of personal data we collect and the circumstances in which each category is collected are described below:

2.1 Registration & Account Information

• Full legal name as it appears on a government-issued identification document
• Date of birth (for age verification — players must be 21 or older under Philippine law)
• Registered email address and mobile number
• Username and encrypted password
• Residential address, city, and province within the Philippines
• Preferred currency (Philippine Peso — PHP)

2.2 Identity Verification (KYC) Information

• Copies of government-issued photo identification (e.g., Philippine National ID, passport, driver's license, SSS/GSIS ID, Voter's ID)
• Proof of residential address (e.g., utility bill, bank statement issued within the past three months)
• Selfie or live photograph for biometric identity confirmation where required
• Source of funds documentation where required by PAGCOR AML obligations

2.3 Financial & Transaction Information

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method identifiers
• Payment method details including GCash mobile number, Maya account reference, BPI/BDO/Metrobank account information, Coins.ph wallet reference, or USDT TRC20 wallet address (we store only the minimum identifiers necessary — full account credentials are never stored by 69club)
• Wagering history, game activity records, and session logs
• Bonus and promotion redemption history

2.4 Technical & Usage Data

• IP address and approximate geolocation (country and region level)
• Device type, operating system, and browser or app version
• Session duration, pages visited, and navigation patterns within the Platform
• Cookie identifiers and similar tracking data (see Section 6)
• Telecommunications network identifier (e.g., Smart, Globe, DITO) where determinable

2.5 Communications Data

• Records of live chat, email, and support ticket interactions with the 69club support team
• Feedback, survey responses, and promotional opt-in preferences

Summary of Data Categories

3 How We Use Your Information

69club uses the personal information we collect for the following purposes:

• Account Management: Creating, maintaining, and administering your 69club account, including processing your 69club Login credentials and managing your player profile.
• Identity Verification & Age Verification: Confirming your identity and verifying that you meet the 21+ age requirement mandated under PAGCOR regulations and Philippine gambling law.
• Transaction Processing: Processing deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, 7-Eleven, Coins.ph, and USDT TRC20 in Philippine Peso (PHP).
• Regulatory Compliance: Meeting our obligations under PAGCOR licensing conditions, Philippine Anti-Money Laundering Act (AMLA) requirements, and other applicable laws and regulations.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, unauthorized access, multi-accounting, bonus abuse, and other prohibited conduct on the Platform.
• Customer Support: Responding to your enquiries, resolving disputes, and providing assistance via live chat and email.
• Responsible Gaming: Monitoring gaming behavior to identify potential problem gambling indicators and to administer responsible gaming tools including deposit limits, self-exclusion, and cooling-off periods.
• Platform Improvement: Analyzing aggregated usage data to improve Platform performance, game selection, and user experience for Filipino players nationwide.
• Marketing Communications: Sending promotional offers, bonus notifications, and game updates to players who have opted in to receive such communications. You may opt out at any time by contacting [email protected].
• Legal Proceedings: Establishing, exercising, or defending legal claims in connection with disputes arising out of the use of the Platform.

We do not use your personal information for automated decision-making processes that produce legal or similarly significant effects without appropriate human oversight and, where required, your prior consent.

4 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 69club processes your personal information on the following legal bases:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and 69club (i.e., our Terms and Conditions), including account creation, transaction processing, and the delivery of Platform services.
• Legal Obligation: Processing is required for compliance with applicable laws, including PAGCOR licensing conditions, AMLA obligations, and NPC data protection requirements.
• Legitimate Interest: Processing is carried out for 69club's legitimate interests in fraud prevention, Platform security, and business operations, provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: For processing activities not covered by the above bases — including marketing communications and certain cookie-based analytics — we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5 Sharing Your Information

69club does not sell, rent, or trade your personal data to third parties for commercial or marketing purposes. We may share your personal information only in the following circumstances and only to the extent strictly necessary:

• Licensed Game Providers: We share limited player data (such as account identifiers and session tokens) with our licensed third-party game providers solely to enable gameplay on the Platform. Game providers are bound by data processing agreements that prohibit any further use of your data.
• Payment Processors: Transaction data is shared with payment service providers (including GCash, Maya, BPI, BDO, Metrobank, 7-Eleven, Coins.ph, and USDT TRC20 network operators) to process your deposits and withdrawals.
• PAGCOR & Regulatory Authorities: We are required by law to report certain player data, transaction records, and activity logs to PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine regulatory and law enforcement bodies upon lawful request or as mandated by applicable regulation.
• Identity Verification Providers: KYC and identity verification services may be conducted by licensed third-party verification providers operating under data processing agreements consistent with this Policy.
• Legal Proceedings: We may disclose personal information to courts, arbitrators, law enforcement agencies, or legal advisers where necessary to establish, exercise, or defend legal claims.
• Business Transfers: In the event of a merger, acquisition, or transfer of substantially all of 69club's assets, player data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

6 Cookies & Tracking Technologies

69club uses cookies and similar technologies (such as local storage and session tokens) on the Platform. These technologies serve the following purposes:

• Essential Cookies: Required for core Platform functionality, including maintaining your 69club Login session, remembering your language and currency preferences, and ensuring Platform security. These cannot be disabled without impairing your ability to use the Platform.
• Analytics Cookies: Used to collect aggregated and anonymized information about how players navigate the Platform. This helps us identify areas for improvement and optimize the player experience. Analytics data is not linked to your personal identity.
• Functional Cookies: Used to remember your Platform preferences across sessions, such as your preferred game category, display settings, and notification preferences.

69club does not use third-party advertising cookies, cross-site behavioral tracking cookies, or social media pixel trackers on the Platform. You may manage cookie preferences through your browser settings; however, disabling essential cookies may affect Platform functionality.

7 Data Retention

69club retains personal information for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention obligations:

• Account & KYC Records: Retained for a minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and Philippine AML regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with the Anti-Money Laundering Act of 2001 (as amended) and AMLC regulations.
• Support & Communications Records: Retained for two (2) years from the date of the interaction, or longer where relevant to ongoing or potential legal proceedings.
• Technical & Usage Logs: Retained for twelve (12) months from the date of collection, after which they are anonymized or deleted.
• Marketing Consent Records: Retained for as long as your marketing consent remains active and for one (1) year following any withdrawal of consent, for record-keeping purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with recognized data destruction standards. Retention periods may be extended where necessary to comply with a specific legal obligation or to defend a pending legal claim.

8 Data Security

69club implements a comprehensive set of technical and organizational security measures to protect your personal information against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security measures include:

• AES-256 encryption for personal and financial data stored at rest on 69club servers
• TLS 1.2 / 1.3 encryption for all data transmitted between your device and the Platform
• Strict role-based access controls ensuring that only authorized 69club personnel with a legitimate need can access player personal data
• Regular third-party security audits and penetration testing of Platform infrastructure
• Multi-factor authentication requirements for all internal administrative access to player data systems
• Comprehensive data breach detection, response, and notification procedures consistent with NPC reporting requirements

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 69club will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach and will notify affected players without undue delay, as required by Philippine law.

9 Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal information held by 69club:

• Right to Be Informed: The right to be informed about how your personal data is collected, used, and disclosed — which this Privacy Policy fulfills.
• Right of Access: The right to request a copy of the personal information 69club holds about you, including the purposes for which it is processed and the recipients to whom it has been disclosed.
• Right to Rectification: The right to request correction of inaccurate, outdated, or incomplete personal information in your 69club account.
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations under PAGCOR and AML regulations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller where technically feasible.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. We will honor all such objections without requiring justification.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that your data protection rights have been violated. Visit the NPC website at privacy.gov.ph for more information.

To exercise any of the above rights, please submit a written request to the 69club Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will acknowledge your request within three (3) business days and resolve it within the period prescribed by the NPC's rules and regulations. We may need to verify your identity before processing your request.

10 International Data Transfers

Some of 69club's third-party service providers — including certain game providers and technical infrastructure partners — may be located outside the Philippines. Where personal data is transferred to jurisdictions outside the Philippines, 69club ensures that appropriate safeguards are in place to protect the security and integrity of your data, including:

• Data processing agreements requiring the recipient to apply data protection standards equivalent to those required under Philippine law
• Contractual clauses approved by the National Privacy Commission or otherwise consistent with NPC guidance on cross-border data flows
• Transfers to jurisdictions recognized by the NPC as providing adequate levels of data protection

By using the 69club Platform, you acknowledge and consent to the transfer of your personal data to our service providers in accordance with the safeguards described above. We will always take reasonable steps to ensure that your data receives an adequate level of protection wherever it is processed.

11 Children's Privacy & Age Restrictions

The 69club Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations and PAGCOR licensing requirements. We do not knowingly collect personal information from individuals under the age of 21.

If we become aware that a player has provided personal information while being under 21 years of age, we will immediately suspend the account, void all associated transactions, and delete the personal information of the underage individual as soon as practicable. Any funds deposited by an underage player will be returned to the original payment method after an appropriate review period.

If you believe that a person under the age of 21 has registered on the Platform or provided their personal information to 69club, please notify us immediately at [email protected] so that we can take prompt corrective action.

12 Changes to This Privacy Policy

69club reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When we make material changes to this Policy, we will:

• Update the "Last Updated" date at the top of this page
• Send a notification to your registered email address where the changes are material and likely to affect your rights
• Display a prominent notice on the Platform for a reasonable period following publication of the revised Policy

Your continued use of the Platform following publication of an updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree to any amendment, you must cease using the Platform and may request account closure by contacting [email protected].

We encourage you to review this Privacy Policy periodically to stay informed about how 69club is protecting your personal information.

13 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 69club, please contact our Data Protection Officer using the following details:

• Email: [email protected] (Subject line: "Data Privacy Request")
• Live Chat: Available 24/7 via the Platform after completing your 69club Login
• Response Time: Data privacy enquiries are acknowledged within three (3) Philippine business days and resolved within the period prescribed by NPC regulations
• Coverage: Serving players across Manila, Cebu, Davao, Quezon City, Makati, and nationwide across the Philippines

For complaints that have not been satisfactorily resolved by 69club, you have the right to escalate your concern to the National Privacy Commission (NPC) of the Philippines. The NPC handles complaints relating to violations of the Data Privacy Act of 2012 and may be contacted through the official NPC website.

This Privacy Policy was last reviewed and updated on January 1, 2026. 69club reserves all rights not expressly granted herein.