39 gl Privacy Policy

This Privacy Policy describes how 39 gl ("39 gl", "we", "us", or "our"), the operator of the online gaming platform at https://39gl.com, collects, uses, discloses, retains, and protects personal information relating to registered players and site visitors. 39 gl is committed to responsible data stewardship and to protecting the privacy rights of Filipino players in accordance with applicable Philippine law.

By registering an account on the 39 gl platform, or by continuing to use the platform after this Privacy Policy has been communicated to you, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

1. Data Controller

1.1 For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR), 39 gl is the Personal Information Controller (PIC) in respect of personal data collected through the 39 gl platform.

1.2 As Personal Information Controller, 39 gl determines the purposes for which your personal data is collected and the means by which it is processed. Where 39 gl engages third-party service providers to process data on its behalf (e.g., payment processors, identity verification providers), those parties act as Personal Information Processors (PIP) under written agreements that require them to maintain equivalent data protection standards.

2. Personal Data We Collect

2.1 Registration & Account Data

When you register an account with 39 gl, we collect:

• Full legal name (as it appears on your government-issued ID);
• Date of birth (for age verification — 21+ requirement);
• Philippine mobile number;
• Email address (if provided);
• Username and encrypted password hash;
• Residential address in the Philippines (city/municipality at minimum).

2.2 KYC & Identity Verification Data

Prior to processing withdrawals, 39 gl collects the following KYC data in compliance with PAGCOR's Anti-Money Laundering (AML) requirements:

• Government-issued photo ID (front and back scan or photograph): Philippine Passport, SSS/UMID Card, PhilSys National ID, LTO Driver's License, PhilHealth ID, or Voter's ID;
• Selfie photograph for facial verification against ID document;
• Proof of source of funds (for accounts exceeding PAGCOR-mandated transaction thresholds).

2.3 Financial Transaction Data

To process deposits and withdrawals, 39 gl collects:

• GCash account number or Maya account number;
• Bank account details (BPI, BDO, Metrobank, or other Philippine bank) where bank transfer is selected;
• Transaction reference numbers from your e-wallet or bank;
• Transaction history: deposit amounts, withdrawal amounts, timestamps, and associated game sessions.

2.4 Gaming Activity Data

As part of normal platform operations and PAGCOR compliance, 39 gl maintains records of:

• Game sessions: game title, start/end time, wager amounts, and game outcomes;
• Bonus credit allocations, wagering progress, and redemptions;
• Responsible gaming tool usage (deposit limits set, session reminders activated, self-exclusion requests).

2.5 Technical & Device Data

When you access the 39 gl platform, our systems automatically collect:

• IP address and approximate geolocation (city/region level);
• Device type, operating system, and browser type/version;
• Session identifiers and login timestamps;
• Referring URL (where applicable).

3. Legal Basis for Processing

39 gl processes your personal data on the following legal bases under RA 10173:

• Contractual necessity: Processing required to operate your 39 gl account, execute deposits and withdrawals, and provide gaming services pursuant to the Terms & Conditions you accepted at registration;
• Legal obligation: Processing required to comply with PAGCOR's regulatory requirements, Anti-Money Laundering Act obligations (RA 9160 as amended), and other applicable Philippine law;
• Legitimate interest: Processing for fraud prevention, platform security, and responsible gaming compliance, where our legitimate interests do not override your data protection rights;
• Consent: Where we send you promotional communications (bonus offers, event notifications), we rely on your express consent, which you may withdraw at any time.

4. How We Use Your Personal Data

39 gl uses personal data collected for the following purposes:

• To create and manage your 39 gl account and verify your identity;
• To process deposits from GCash, Maya, BPI, BDO, Metrobank, and USDT, and to process withdrawal requests;
• To fulfil KYC and AML obligations mandated by PAGCOR and the AMLC;
• To verify age eligibility (21+ requirement) before granting full account access;
• To provide customer support and resolve disputes;
• To detect and prevent fraud, cheating, collusion, and money laundering;
• To administer responsible gaming tools including deposit limits and self-exclusion;
• To send transactional notifications (deposit confirmations, withdrawal approvals, security alerts);
• To send promotional communications (where consent has been given);
• To improve platform performance, game library, and user experience based on aggregate usage analytics;
• To comply with court orders, regulatory requests, and law enforcement enquiries.

5. Sharing and Disclosure of Personal Data

5.1 39 gl does not sell personal data to unaffiliated third parties for commercial marketing purposes.

5.2 39 gl may share your personal data with the following categories of recipients, under data processing agreements or legal obligations:

• Payment processors: GCash (G-Xchange Inc.), Maya (PayMaya Philippines), and Philippine banks — solely to execute your requested transactions;
• Identity verification providers: Third-party KYC service providers engaged to verify government-issued ID documents and perform facial recognition matching;
• Game providers: JILI, PG Soft, Evolution Gaming, and other licensed game studios — limited to session identifiers and wager data necessary to operate games and resolve disputes;
• PAGCOR: As the supervising regulatory authority, PAGCOR may require access to player account data, transaction records, and gaming history for regulatory inspection purposes;
• AMLC: The Anti-Money Laundering Council may require disclosure of financial transaction data in connection with suspicious transaction reports (STRs) or covered transaction reports (CTRs) under RA 9160;
• Law enforcement and courts: Where required by valid legal process, court order, or statutory obligation under Philippine law.

5.3 All third-party processors engaged by 39 gl are contractually bound to process personal data only in accordance with 39 gl's instructions and to maintain data security standards equivalent to those described in this Policy.

6. Cookies and Tracking Technologies

6.1 The 39 gl platform uses cookies and similar technologies to maintain login sessions, detect fraud, and analyse aggregate platform usage. Cookies used by 39 gl fall into the following categories:

• Strictly necessary cookies: Required for account authentication and session management. Cannot be disabled without affecting platform functionality;
• Security cookies: Used to detect suspicious activity, prevent CSRF attacks, and manage trusted device sessions;
• Analytics cookies: Used to collect aggregate, anonymised usage data to improve platform performance. No individual player is identified in analytics reports.

6.2 39 gl does not use third-party advertising or cross-site tracking cookies. Your browsing activity on the 39 gl platform is not shared with advertising networks.

7. Data Retention

7.1 39 gl retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and KYC records: Retained for a minimum of 5 years from the date of account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act;
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction in compliance with AMLC requirements;
• Gaming activity logs: Retained for a minimum of 2 years for dispute resolution purposes, and longer where required by PAGCOR;
• Support communications: Retained for 2 years from the date of the last communication, unless a longer retention period is required for active disputes.

7.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data.

8. Security Measures

39 gl implements technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, and destruction:

• Encryption in transit: All data transmitted between players and the 39 gl platform is encrypted using TLS 1.2 or higher with 256-bit encryption;
• Encryption at rest: Sensitive data fields (including KYC documents and financial identifiers) are encrypted at rest using AES-256;
• Access controls: Access to personal data is restricted to authorised 39 gl personnel on a need-to-know basis and is subject to role-based access controls and audit logging;
• Password security: Player passwords are stored as irreversible cryptographic hashes. 39 gl never stores plaintext passwords;
• Penetration testing: The 39 gl platform undergoes regular security assessments by independent security professionals;
• Incident response: 39 gl maintains a documented data breach response procedure aligned with NPC Circular No. 16-03.

9. Your Data Privacy Rights

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

To exercise any of these rights, contact 39 gl at: [email protected] (plain text — not a clickable link). 39 gl will respond to data rights requests within 15 business days of receipt.

10. Children's and Minors' Privacy

10.1 The 39 gl platform is strictly prohibited for individuals under the age of 21, in accordance with PAGCOR's age restrictions for online gaming in the Philippines. 39 gl does not knowingly collect or process personal data from individuals under 21 years of age.

10.2 If 39 gl becomes aware that personal data has been collected from an individual under 21 years of age, the relevant account will be immediately suspended, all personal data will be deleted to the extent not required for legal retention purposes, and any deposited funds will be returned. Where mandatory reporting obligations apply, the matter will be referred to the relevant authorities.

11. Cross-Border Data Transfers

11.1 Some of 39 gl's service providers — including game studios and infrastructure providers — may be located outside the Philippines. Where personal data is transferred outside the Philippines, 39 gl ensures that such transfers are subject to appropriate safeguards, including contractual obligations on the recipient to maintain data protection standards equivalent to those required by RA 10173.

11.2 39 gl does not transfer personal data to jurisdictions that the National Privacy Commission has determined to provide inadequate data protection without implementing additional safeguards.

12. Changes to This Privacy Policy

12.1 39 gl reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or platform services. Material changes will be communicated to registered players via in-platform notification or to the registered contact details on file.

12.2 The effective date at the top of this Policy indicates when it was last reviewed and updated. Continued use of the 39 gl platform following notification of a material change constitutes acceptance of the revised Policy.

13. Data Protection Officer & Contact

39 gl has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. For all privacy-related enquiries, data rights requests, or to report a suspected data breach, please contact:

• Email: [email protected]
• Subject line: "Data Privacy Request — [your registered username]"
• In-platform support: Available 24/7 via live chat on the 39 gl platform

This Privacy Policy was last reviewed on 1 June 2026 and is effective from 1 January 2026. Previous versions are available upon written request.