Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 689ph ("689ph," "we," "us," or "our"), the operator of the online gaming platform at https://689ph.club ("the Platform"), collects, uses, stores, shares, and protects the personal information of individuals ("Players," "Users," or "you") who access or use the Platform.

689ph is committed to protecting the privacy and personal data of all Filipino players and other users of the Platform. This Policy is drafted in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission ("NPC") of the Philippines.

By registering on, accessing, or using the 689ph Platform, you acknowledge that you have read, understood, and freely consent to the collection and processing of your personal data as described in this Policy. If you do not agree with any part of this Policy, you should discontinue your use of the Platform immediately.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, the data controller in respect of your personal information is 689ph, the operator of the gaming platform accessible at https://689ph.club.

All inquiries, requests, and complaints relating to your personal data and this Policy should be directed to the 689ph Data Protection Officer (DPO) via the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

689ph collects personal data from and about you in the following categories and through the following means:

689ph does not intentionally collect sensitive personal information beyond what is necessary for age verification, identity verification, and regulatory compliance. Where sensitive personal information (such as national identification numbers) is collected as part of the KYC process, it is handled with heightened security measures and accessed only by authorised personnel.

4. How 689ph Uses Your Personal Data

689ph processes your personal data for the following specific purposes:

• Account Management: To create, verify, maintain, and administer your 689ph player account, including authentication, password recovery, and account security processes.
• Payment Processing: To process deposits and withdrawals via GCash, Maya, bank transfer, and other supported payment methods; to verify payment method ownership; and to maintain accurate transaction records.
• Legal and Regulatory Compliance: To fulfil obligations under the Data Privacy Act of 2012, the Anti-Money Laundering Act (R.A. 9160 as amended), PAGCOR licensing conditions, and other applicable Philippine laws and regulations.
• Identity Verification and KYC: To verify your identity, age, and eligibility to participate in real-money gaming in accordance with PAGCOR requirements and 689ph's internal KYC policies.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, account compromise, bonus abuse, and other prohibited conduct on the Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide assistance through 689ph's 24/7 support channels.
• Responsible Gaming: To monitor gaming patterns for indicators of problem gambling; to administer deposit limits, self-exclusion requests, and cooling-off periods; and to provide appropriate player protection interventions.
• Platform Improvement: To analyse usage patterns, identify technical issues, and improve the functionality, performance, and content of the 689ph Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided consent to receive such communications. You may withdraw consent at any time through your account preferences.

689ph will not use your personal data for any purpose materially different from those listed above without providing prior notice and, where required by the DPA, obtaining your consent.

5. Legal Basis for Processing

689ph processes your personal data under the following legal bases as recognised by the Data Privacy Act of 2012:

• Consent (Section 12(a) DPA): Where you have freely, specifically, and informedly consented to processing — including marketing communications and optional account features.
• Contract Performance (Section 12(b) DPA): Where processing is necessary for the performance of the player account agreement between you and 689ph, including account administration, payment processing, and game operation.
• Legal Obligation (Section 12(c) DPA): Where processing is necessary for 689ph to comply with applicable Philippine law, including AML obligations, PAGCOR licensing requirements, and NPC regulations.
• Legitimate Interests (Section 12(f) DPA): Where processing is necessary for 689ph's legitimate interests in operating a secure, compliant, and commercially viable gaming platform, provided such interests are not overridden by your fundamental rights and freedoms.

6. Disclosure and Sharing of Personal Data

689ph does not sell your personal data. We disclose your personal data only in the following circumstances and to the following categories of recipients:

• Payment Processors: GCash (G-Xchange, Inc.), Maya (Voyager Innovations, Inc.), BPI, BDO, Metrobank, UnionBank, and other payment service providers as required to process your deposits and withdrawals. Each payment processor is bound by its own privacy policy and applicable Philippine financial data regulations.
• Game Providers: Third-party game studios and RNG certification bodies may receive limited technical data (such as player session tokens) as necessary to operate game services. Game providers do not receive personally identifiable information beyond what is technically required.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine regulatory bodies, where disclosure is required by law, court order, or regulatory direction.
• Identity Verification Services: Third-party KYC and identity verification providers used to fulfil 689ph's regulatory verification obligations. These providers are contractually bound to process data solely for the purpose of identity verification on 689ph's behalf.
• Professional Advisers: Legal counsel, auditors, and compliance consultants retained by 689ph, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all of 689ph's assets, your personal data may be transferred to the successor entity, subject to the same protections described in this Policy.

7. International Data Transfers

As an online gaming platform that may utilise cloud infrastructure and third-party service providers with operations outside the Philippines, your personal data may be transferred to, stored in, or processed in jurisdictions other than the Philippines. Where such transfers occur, 689ph ensures that:

• The recipient country provides an adequate level of data protection as determined by the National Privacy Commission, or
• Appropriate contractual safeguards are in place, such as data processing agreements incorporating the NPC's prescribed standard contractual clauses, or
• The transfer is necessary for the performance of a contract to which you are a party (such as processing a GCash withdrawal instruction), or
• You have explicitly consented to the transfer following being informed of the risks.

You may contact the 689ph Data Protection Officer to obtain information about the specific safeguards applicable to any international transfer of your personal data.

8. Data Retention

689ph retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention requirements:

• Active Account Data: Retained for the duration of your active 689ph account and for a minimum of five (5) years following account closure, in compliance with the Anti-Money Laundering Act's record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, or longer where required by applicable law or ongoing regulatory investigation.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the completion of the business relationship, in accordance with AMLC requirements.
• Support Communications: Retained for up to three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution purposes.
• Marketing Preferences: Retained until you withdraw consent or the purpose for processing ceases, whichever is earlier.

Upon the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 689ph's data disposal procedures.

9. Cookies and Tracking Technologies

689ph uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in to your 689ph account during an active session. These cannot be disabled without impairing the Platform's core functionality.
• Functional Cookies: Used to remember your preferences, such as language settings and display preferences, to personalise your 689ph experience.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players use the Platform — which pages are visited most, how long sessions last, where users navigate from — to inform Platform improvements. Analytics data does not identify individual players.
• Security Cookies: Used to detect and prevent fraudulent logins, bot activity, and other security threats to the Platform and to player accounts.

You may control non-essential cookie usage through your browser settings. Disabling all cookies may impair certain Platform functionality, including persistent login sessions. 689ph does not currently use cross-site tracking cookies for third-party advertising purposes.

10. Your Data Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights in relation to the personal data 689ph holds about you:

• Right to Be Informed: The right to be informed whether personal data pertaining to you is being, or has been, collected and processed by 689ph.
• Right of Access: The right to request access to your personal data held by 689ph and to receive a copy of such data in a commonly used electronic format.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data 689ph holds about you.
• Right to Erasure / Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 689ph's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data on grounds of legitimate interests, including direct marketing, where you have reasonable grounds to object.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another data controller, where technically feasible.
• Right to Damages: The right to claim compensation where you have suffered damage as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data by 689ph.
• Right to Complain: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, please contact the 689ph Data Protection Officer as detailed in Section 15. 689ph will respond to data subject requests within fifteen (15) business days of receipt, subject to identity verification requirements.

11. Children's Privacy and Age Restriction

The 689ph Platform is strictly intended for persons aged twenty-one (21) years or older. 689ph does not knowingly collect personal data from individuals under the age of 21. Age verification procedures are implemented during the registration and KYC process to prevent access by minors.

If 689ph becomes aware that personal data has been collected from a person under the age of 21, such data will be deleted immediately and the relevant account will be terminated. If you have reason to believe that a minor has registered on the 689ph Platform, please contact our support team immediately.

12. Security of Personal Data

689ph implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 689ph Platform.
• Encrypted storage of passwords and sensitive authentication credentials using industry-standard hashing algorithms.
• Access controls ensuring that personal data is accessible only to 689ph personnel and contractors with a legitimate need to process it.
• Regular security assessments and penetration testing of Platform infrastructure.
• Two-factor authentication options for player accounts to reduce the risk of unauthorised access.
• Incident response procedures to detect, contain, and report personal data breaches in accordance with NPC notification requirements.

Notwithstanding the above measures, no data transmission or storage system is completely secure. 689ph cannot guarantee the absolute security of personal data. Players are encouraged to use strong, unique passwords and to enable two-factor authentication on their 689ph accounts as an additional layer of personal data protection.

13. Third-Party Services and Links

The 689ph Platform may reference or interact with third-party services including payment processors, game studios, and identity verification providers. Each third-party service operates under its own privacy policy and is an independent data controller in respect of the personal data it collects and processes through its own systems.

689ph is not responsible for the privacy practices of third-party services. Players are encouraged to review the privacy policies of any third-party service they interact with in connection with their 689ph account, particularly GCash and Maya as primary payment methods used by Filipino players on the Platform.

14. Changes to This Privacy Policy

689ph reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, 689ph's data processing practices, or Platform functionality. Material changes to this Policy will be communicated to registered Players via the email address or mobile number on file at least seven (7) days prior to the amended Policy taking effect.

The current version of this Privacy Policy is always available at https://689ph.club/privacy-policy. The date at the top of this Policy indicates when it was last updated. Continued use of the Platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy.

15. Contact and Data Subject Requests

For all privacy-related inquiries, data subject access requests, complaints, or to contact the 689ph Data Protection Officer, please reach us through:

• Live Chat: Available 24/7 through the 689ph Platform support widget.
• Email: [email protected] (mark the subject line "Privacy / DPO Request")

689ph is committed to handling all privacy inquiries with professionalism, confidentiality, and in accordance with the timelines prescribed by the Data Privacy Act of 2012 and National Privacy Commission regulations. If you are not satisfied with 689ph's response to a privacy complaint, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.