Legal Document

Privacy Policy — 39 gl Online Casino Philippines

This Privacy Policy explains how 39 gl collects, uses, stores, and protects the personal information of Filipino players in compliance with the Republic of the Philippines Data Privacy Act of 2012 (Republic Act No. 10173). Please read it carefully before registering or providing any personal information to 39 gl.

Effective: 1 January 2026
Jurisdiction: Philippines
Applies to: All 39 gl Players

Privacy at 39 gl — Key Commitments

A plain-English summary of our core privacy practices — the full legal text is in the sections below

Data Privacy Act Compliance

39 gl processes personal data in full compliance with the Philippine Data Privacy Act of 2012 (RA 10173) and the National Privacy Commission's implementing rules and regulations.

Data Minimisation

39 gl collects only the personal data that is strictly necessary for account registration, identity verification, payment processing, and PAGCOR-mandated regulatory compliance.

No Data Selling

39 gl does not sell, rent, or trade your personal data to any third party for marketing purposes. Your information is used only for the operational purposes described in this Policy.

SSL Encryption

All data transmitted between your browser and the 39 gl platform is encrypted using industry-standard SSL/TLS technology. Stored personal data is protected by layered access controls and encryption at rest.

Your Rights Are Protected

As a Filipino data subject, you have the right to access, correct, erase, restrict, and object to the processing of your personal data. 39 gl provides clear channels to exercise each of these rights.

Breach Notification

In the event of a personal data breach that poses a real risk to affected players, 39 gl will notify the National Privacy Commission and affected data subjects within 72 hours of becoming aware of the breach.


SECTION 1

Who We Are

39 gl ("we", "us", "our") is an online gaming platform accessible at 39gl.net, operated for the Philippine market and serving Filipino players across Metro Manila, Cebu, Davao, Quezon City, Makati, and all other parts of the Philippines. 39 gl operates within a PAGCOR-compliant regulatory framework and is committed to the responsible handling of all personal data entrusted to us by our players.

For purposes of the Data Privacy Act of 2012 (Republic Act No. 10173), 39 gl acts as the Personal Information Controller with respect to the personal data of registered players and website visitors. Our Data Protection Officer ("DPO") can be contacted at [email protected] with the subject line "Data Privacy Request."

Regulatory Context: The Philippine Data Privacy Act of 2012 and the National Privacy Commission's Circular No. 2016-01 govern how 39 gl handles personal data. We treat compliance with these instruments as a baseline obligation, not a ceiling.
SECTION 2

Scope of This Privacy Policy

This Privacy Policy applies to all personal data processed by 39 gl in connection with your use of the 39 gl platform, including:

  • Account registration and ongoing account management.
  • Identity verification (KYC) and document submission.
  • Deposit and withdrawal transactions via GCash, PayMaya, BDO, BPI, and Metrobank.
  • Participation in casino games, sports betting, bingo, and promotional offers.
  • Customer support interactions via live chat or email.
  • Browsing of the 39 gl website without registration (limited data collection applies).

This Policy does not apply to any third-party websites, services, or platforms linked to or from the 39 gl site. 39 gl is not responsible for the privacy practices of those third parties and encourages you to review their respective privacy policies.

SECTION 3

Categories of Personal Data We Collect

39 gl collects the following categories of personal data, depending on how you interact with the platform:

Category Data Elements Purpose
Identity Data Full legal name, date of birth, nationality, gender Account registration, KYC age verification, PAGCOR compliance
Contact Data Mobile number (Globe, Smart, DITO), email address, residential address Account communication, 2FA codes, support correspondence
Identity Documents Philippine ID (SSS, PhilSys, driver's license, passport), selfie photos KYC identity verification, fraud prevention, PAGCOR regulatory reporting
Financial Data GCash number, PayMaya account, bank account details (last 4 digits), transaction records Payment processing, withdrawal verification, AML compliance
Gaming Data Game history, bet amounts, session durations, win/loss records, bonus usage Account management, responsible gaming monitoring, dispute resolution
Technical Data IP address, device type, browser type, operating system, login timestamps Security monitoring, fraud prevention, platform optimisation
Usage Data Pages visited, features used, click paths, time on site Platform improvement, user experience optimisation
Communications Data Live chat transcripts, email correspondence, support ticket content Dispute resolution, quality assurance, staff training
Special Categories: 39 gl does not intentionally collect sensitive personal information as defined under Section 3(l) of the Data Privacy Act — such as health data, political beliefs, or biometric data — beyond what is strictly required by law for identity verification purposes.
SECTION 4

How We Collect Your Data

39 gl collects personal data through the following means:

  • Direct submission: Information you provide when registering an account, completing KYC, submitting a support request, or participating in a promotion.
  • Automated collection: Technical and usage data collected automatically through cookies, log files, and analytics tools when you access the 39 gl platform.
  • Payment processors: Transaction data shared by GCash, PayMaya, and banking partners as part of deposit and withdrawal processing.
  • Identity verification providers: Data returned by KYC verification services used to authenticate government-issued Philippine identification documents.
  • Game providers: Gaming session data provided by game technology suppliers (Pragmatic Play, PG Soft, JILI, Evolution, etc.) to support account records.
  • Fraud and security services: Risk indicators and device fingerprint data from fraud-prevention tools used to protect player accounts.
SECTION 5

Legal Basis for Processing Personal Data

Under the Data Privacy Act of 2012, 39 gl processes personal data on the following lawful bases:

  • Consent: Where you have given clear, specific consent to the processing of your personal data — for example, opting into marketing communications or promotional notifications.
  • Contractual necessity: Processing required to perform the contract between 39 gl and you as a registered player — including account management, game access, and payment processing.
  • Legal obligation: Processing required to comply with PAGCOR regulatory requirements, Anti-Money Laundering Act (AMLA) obligations, and other applicable Philippine laws.
  • Legitimate interests: Processing for fraud prevention, security monitoring, platform improvement, and responsible gaming monitoring, where those interests are not overridden by your rights.
Withdrawing Consent: Where 39 gl relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time by contacting [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
SECTION 6

How We Use Your Personal Data

39 gl uses the personal data collected for the following specific and clearly defined purposes:

  • Creating and managing your 39 gl account and verifying your identity at registration and on an ongoing basis.
  • Processing deposits and withdrawal requests via GCash, PayMaya, BDO, BPI, and Metrobank in Philippine Peso.
  • Providing access to the 39 gl game library including slots, live dealer tables, sports betting, and bingo.
  • Sending account-related communications — transaction confirmations, security alerts, and KYC status updates.
  • Administering bonuses, promotions, and the 39 gl VIP program, including tracking bonus wagering progress.
  • Monitoring gaming behaviour for responsible gaming purposes, including detecting signs of problem gambling and applying deposit or loss limits where requested.
  • Preventing, detecting, and investigating fraud, money laundering, and other financial crimes in compliance with AMLA requirements.
  • Responding to customer support requests and resolving disputes.
  • Complying with regulatory reporting obligations to PAGCOR and other competent Philippine authorities.
  • Improving the 39 gl platform through analytics and user experience research (using aggregated, anonymised data where possible).
  • Sending marketing communications about 39 gl offers and promotions, where you have opted in to receive them.
SECTION 7

Sharing and Disclosure of Personal Data

39 gl does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We share personal data only in the following limited circumstances, each subject to appropriate confidentiality and data processing agreements:

  • Payment processors: GCash, PayMaya, BDO, BPI, and Metrobank receive the minimum data necessary to process your transactions.
  • Game technology providers: Pragmatic Play, PG Soft, JILI, Evolution, and other providers receive session data required to operate game functionality within your account.
  • KYC and identity verification services: Identity document data is shared with certified verification providers to complete age and identity checks.
  • Fraud and security providers: Technical and device data is processed by fraud prevention tools to protect your account and the platform.
  • Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government bodies, where required by law.
  • Legal and professional advisors: Where necessary for legal proceedings, regulatory investigations, or professional advice, subject to strict confidentiality obligations.

All third parties with whom 39 gl shares personal data are bound by contractual data processing agreements requiring them to handle your data in accordance with the Data Privacy Act of 2012 and this Privacy Policy.

SECTION 8

Cookies and Tracking Technologies

The 39 gl platform uses cookies and similar tracking technologies to enhance your user experience, maintain your session, and collect analytical data. The following categories of cookies are used:

  • Essential cookies: Strictly necessary for the platform to function — session management, login state, security tokens. These cannot be disabled without preventing platform access.
  • Performance cookies: Collect aggregated, anonymised data about how players use the 39 gl platform to identify performance issues and improvement areas.
  • Functional cookies: Remember your preferences such as language settings, game display options, and responsible gaming limit configurations.
  • Analytics cookies: Used to understand usage patterns and improve the 39 gl experience. Data collected is aggregated and not used to identify individual players.

You may control cookie preferences through your browser settings. Blocking essential cookies will affect your ability to use the 39 gl login and gaming features. A cookie consent banner is displayed on your first visit to 39gl.net, giving you the option to accept or configure non-essential cookies.

SECTION 9

Data Retention

39 gl retains personal data only for as long as it is necessary for the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

Data Category Retention Period Basis
Account & KYC data Duration of account + 5 years after closure PAGCOR regulatory requirement, AMLA compliance
Financial transaction records 10 years from date of transaction Anti-Money Laundering Act (AMLA) obligation
Gaming history Duration of account + 3 years after closure Dispute resolution, regulatory reporting
Support communications 3 years from last interaction Dispute resolution, quality assurance
Technical & usage data 13 months from collection Security monitoring, platform analytics
Marketing consent records Until withdrawal of consent + 2 years Evidence of lawful marketing basis
Post-Retention Disposal: Upon expiry of the applicable retention period, 39 gl will securely delete or anonymise personal data in accordance with the National Privacy Commission's guidelines on data disposal. Anonymised data may be retained indefinitely for statistical purposes.
SECTION 10

Data Security Measures

39 gl implements technical, organisational, and physical security measures appropriate to the sensitivity and volume of personal data we process. These include:

  • SSL/TLS encryption for all data transmitted between player devices and the 39 gl platform.
  • Encryption at rest for all stored personal data, including KYC documents and financial records.
  • Multi-factor authentication requirements for access to systems holding personal data by 39 gl staff.
  • Role-based access controls ensuring that 39 gl employees can only access personal data necessary for their specific functions.
  • Regular security audits and penetration testing by independent cybersecurity firms.
  • Intrusion detection systems and 24/7 security monitoring of the 39 gl infrastructure.
  • Staff data protection training and confidentiality obligations for all employees with access to personal data.

While 39 gl takes all reasonable steps to protect your data, no digital platform can guarantee absolute security. You are encouraged to use a strong, unique password for your 39 gl account and enable two-factor authentication to further protect your account from unauthorised access.

SECTION 11

Your Rights as a Data Subject

Under the Data Privacy Act of 2012, registered 39 gl players have the following rights with respect to their personal data. You may exercise any of these rights by contacting our Data Protection Officer at [email protected] with the subject line "Data Privacy Request." 39 gl will respond within 15 working days.

Right to Access

Request a copy of the personal data 39 gl holds about you and information about how it is processed.

Right to Rectification

Request correction of inaccurate or incomplete personal data in your 39 gl account.

Right to Erasure

Request deletion of personal data where retention is no longer necessary or lawful, subject to regulatory obligations.

Right to Restrict

Request restriction of processing in certain circumstances, such as while a data accuracy dispute is being resolved.

Right to Object

Object to processing based on legitimate interests, particularly with respect to direct marketing communications.

Right to Portability

Request a machine-readable copy of data you provided to 39 gl where technically feasible.

Right to Complain

Lodge a complaint with the National Privacy Commission (NPC) if you believe 39 gl has mishandled your personal data.

Right to Withdraw Consent

Withdraw consent to processing at any time where consent was the legal basis, without affecting prior lawful processing.

NPC Contact: The National Privacy Commission of the Philippines can be reached at its official website and serves as the independent authority responsible for overseeing compliance with the Data Privacy Act of 2012. You may lodge a complaint with the NPC if you are not satisfied with 39 gl's response to a data subject request.
SECTION 12

Children and Minors

The 39 gl platform is strictly restricted to individuals who are at least 21 years of age, in accordance with PAGCOR regulations governing online gaming in the Philippines. 39 gl does not knowingly collect, process, or retain personal data from minors.

Age verification is a mandatory step in the 39 gl registration and KYC process. Any account where the registered user is found to be below the age of 21 will be immediately suspended, any balances held will be returned to the deposit source, and all personal data will be deleted in accordance with this Policy.

21+ Requirement: If you have reason to believe that a minor has registered or is accessing the 39 gl platform, please notify us immediately at [email protected]. We will take immediate action to investigate and, where confirmed, close the account and delete associated personal data.
SECTION 13

Third-Party Links and Services

The 39 gl platform may contain links to or integrations with third-party services — including payment providers (GCash, PayMaya), game technology providers, and customer support tools. These third-party services operate under their own privacy policies, which are independent of this document.

39 gl is not responsible for the privacy practices, data handling standards, or security measures of any third-party service. When you interact with a third-party service accessed through or in connection with the 39 gl platform — such as completing a GCash payment — you are subject to that provider's privacy policy in addition to this one.

39 gl recommends that you review the privacy policies of all third-party services you interact with. The inclusion of a third-party service in the 39 gl platform does not constitute an endorsement of that service's privacy practices.

SECTION 14

Changes to This Privacy Policy

39 gl reserves the right to amend or update this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulatory requirements, or National Privacy Commission guidelines. The effective date at the top of this document will be updated to reflect the date of the most recent revision.

Where amendments are material — meaning they affect your rights as a data subject or change how 39 gl processes your personal data in a significant way — we will provide advance notice via email to your registered address and/or a prominent notification on the 39 gl platform prior to the changes taking effect.

Your continued use of the 39 gl platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with the updated Policy, you may request account closure by contacting our support team.

SECTION 15

Contact Us & Data Protection Officer

If you have questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by 39 gl, please contact our Data Protection Officer through the following channels:

  • Email (DPO / Privacy Requests): [email protected] — use subject line "Data Privacy Request" for priority handling
  • Live Chat: Available 24/7 through the 39 gl platform for general privacy questions
  • Response Commitment: All data subject requests acknowledged within 48 hours; substantive response within 15 working days
  • NPC Complaints: You may also raise concerns directly with the Philippine National Privacy Commission if you feel your rights have not been adequately addressed
Responsible Gaming Contact: For responsible gaming concerns — including self-exclusion requests, deposit limit settings, or gambling harm support — please visit our Responsible Gaming page or contact support marked "Responsible Gaming." All responsible gaming requests are handled with priority and full confidentiality.

Your Data Is Safe with 39 gl

We keep your information secure, process it transparently, and give you control over it. Ready to explore the full 39 gl casino experience?