39gl Privacy Policy
Your privacy matters to us. This policy explains exactly what personal data 39gl collects, why we collect it, how we protect it, and the rights you hold as a player under Philippine law.
How 39gl Protects Your Privacy
At 39gl, privacy is not an afterthought — it is built into how we operate. Here are the core principles that guide how we handle your personal information.
DPA 2012 Compliance
39gl operates in full compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines. We are registered with the National Privacy Commission (NPC) and follow all mandated data protection principles, including transparency, legitimate purpose, and proportionality.
256-Bit SSL Encryption
All data transmitted between your device and the 39gl Platform is protected by 256-bit SSL/TLS encryption — the same standard used by major banks in the Philippines, including BPI and BDO. Your personal and financial information is never transmitted in plain text at any point in the process.
No Selling of Personal Data
39gl does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We share data only where required by PAGCOR regulations, Philippine law, or with carefully selected service providers who are contractually bound to protect your information to our standards.
Your Data, Your Rights
As a data subject under Philippine law, you have the right to access, correct, object to, and request erasure of your personal data. 39gl provides straightforward mechanisms to exercise these rights — no bureaucratic runaround, just a simple request to our Data Protection Officer.
Defined Retention Periods
We only keep your personal data for as long as necessary to fulfil the purpose it was collected for, or as required by PAGCOR regulations and Philippine anti-money laundering laws. Once the retention period expires, your data is securely deleted or anonymised in accordance with our data lifecycle procedures.
Breach Notification
In the unlikely event of a personal data breach that poses a risk to your rights and freedoms, 39gl will notify the National Privacy Commission within 72 hours of discovery, and will communicate directly with affected players without undue delay, as required by the Data Privacy Act of 2012 and its implementing rules.
Introduction
This Privacy Policy ("Policy") sets out how 39gl ("39gl", "we", "us", "our") collects, uses, stores, shares, and protects the personal information of players and visitors who access the 39gl online casino and sports betting platform at https://39gl.bet (the "Platform"). This Policy applies to all personal data processed by 39gl in connection with the operation of the Platform, regardless of the device or channel through which you access our services.
39gl is committed to protecting your privacy and handling your personal data with transparency, integrity, and respect. We operate in full compliance with Republic Act No. 10173, known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as enforced by the National Privacy Commission ("NPC") of the Philippines. Our operations are also subject to the data handling requirements of the Philippine Amusement and Gaming Corporation ("PAGCOR").
Please Read Carefully: By registering an account on the 39gl Platform or by continuing to use our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree with any part of this Policy, please do not register an account or use the Platform.
This Policy should be read alongside our Terms and Conditions and Responsible Gaming Policy, all of which together govern your relationship with 39gl. Capitalised terms not defined in this Policy carry the meanings assigned to them in our Terms and Conditions.
Personal Data We Collect
39gl collects personal data about you in several ways: information you provide directly to us during registration and account management; information generated automatically when you use the Platform; and, in limited circumstances, information received from third-party sources. Below is a detailed breakdown of the categories of personal data we collect.
2.1 Account Registration Data
When you create a 39gl account, we collect the following information:
- Full legal name as it appears on a Philippine government-issued identification document
- Date of birth (used to verify that you meet the 21+ age requirement under PAGCOR regulations)
- Current residential address in the Philippines (city, province, postal code)
- Valid email address
- Valid Philippine mobile number
- Username and hashed password (we do not store passwords in plain text)
2.2 Identity Verification (KYC) Data
As required by PAGCOR's Know Your Customer ("KYC") obligations and Philippine anti-money laundering laws, we may collect the following additional documentation:
- Copies of government-issued photo identification (Philippine passport, UMID, driver's licence, SSS ID, PhilHealth ID, Voter's ID, or postal ID)
- Proof of residential address (utility bill, bank statement, or barangay certificate not older than three months)
- Source-of-funds documentation for large transactions, as required under the Anti-Money Laundering Act
- Selfie or liveness verification images used to match against submitted identification documents
2.3 Financial Transaction Data
To process your deposits and withdrawals, we collect:
- GCash account details, PayMaya account details, or bank account information (BPI, BDO, Metrobank) used for transactions
- Transaction history, including deposit amounts, withdrawal requests, and transaction timestamps
- Payment reference numbers and processor identifiers
All financial data is handled in Philippine Peso (₱) and processed through PAGCOR-compliant payment channels.
2.4 Usage and Technical Data
When you use the 39gl Platform, we automatically collect:
| Data Type | Examples | Purpose |
|---|---|---|
| Device Information | Device type, OS, browser version, screen resolution | Platform optimisation, fraud detection |
| Network Data | IP address, approximate geographic location | Geolocation compliance, security monitoring |
| Session Data | Login timestamps, session duration, pages visited | Account security, responsible gaming monitoring |
| Gameplay Data | Games played, bet amounts, wagering history | PAGCOR regulatory reporting, responsible gaming |
| Communication Data | Live chat logs, support ticket content, email records | Customer service, dispute resolution |
2.5 Marketing Preferences
Where you have opted in, we collect your communication preferences to send you relevant promotional offers, bonus notifications, and platform updates. You may update or withdraw your marketing consent at any time through your account settings or by contacting our support team.
Purpose of Processing
39gl processes your personal data only for specific, legitimate purposes. We do not use your personal information for any purpose incompatible with what is disclosed in this Policy. The primary purposes for which we process your personal data are:
- Account Creation and Management: To register your account, verify your identity, maintain your player profile, and enable you to access and use all features of the 39gl Platform.
- KYC and Age Verification: To comply with PAGCOR's mandatory Know Your Customer requirements and to verify that you meet the minimum age requirement of 21 years under Philippine gaming regulations.
- Payment Processing: To process your deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, and to maintain accurate financial records of all transactions on your account.
- Regulatory Compliance: To fulfil our obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable Philippine laws and regulations.
- Fraud Prevention and Security: To detect, prevent, and investigate fraudulent activity, money laundering, account takeover attempts, and other security threats to the Platform and its players.
- Customer Support: To respond to your queries, resolve disputes, and provide technical assistance through our 24/7 live chat and email support channels.
- Responsible Gaming: To monitor gameplay patterns, identify signs of problem gambling, apply self-exclusion or deposit limit requests, and ensure compliance with our responsible gaming obligations under PAGCOR guidelines.
- Platform Improvement: To analyse usage patterns and player feedback in order to enhance the functionality, performance, and user experience of the 39gl Platform.
- Marketing Communications: Where you have provided consent, to send you personalised bonus offers, promotional materials, and updates about new games or features on the Platform that may interest you.
Filipino Players Note: 39gl is specifically designed for players based in the Philippines. When assessing responsible gaming indicators, we may take into account regional data such as your city of residence (whether you are based in Metro Manila, Cebu, Davao, or elsewhere in the archipelago) to tailor support resources appropriately.
Legal Basis for Processing
Under the Data Privacy Act of 2012, 39gl must have a valid legal basis for processing your personal data. Depending on the nature of the processing activity, we rely on one or more of the following legal bases:
- Contractual Necessity: Processing your registration data, KYC information, and financial transaction data is necessary for 39gl to perform the contract we have with you — namely, providing you with access to the 39gl Platform and its services. Without this processing, we cannot open or maintain your account.
- Legal Obligation: Certain processing activities — including KYC verification, transaction monitoring, and PAGCOR reporting — are required by law. 39gl has no discretion to avoid this processing, as it is mandated by PAGCOR regulations and Philippine anti-money laundering legislation.
- Legitimate Interests: We process certain usage data and technical data on the basis of our legitimate interests in maintaining the security of the Platform, preventing fraud, and improving our services — provided these interests are not overridden by your privacy rights.
- Consent: Where we send you marketing communications or use non-essential cookies, we rely on your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting the lawfulness of processing that occurred before withdrawal.
Data Sharing & Disclosure
39gl does not sell your personal data to any third party. We share your information only in the specific circumstances described below, and only to the extent necessary for each stated purpose.
5.1 Regulatory and Government Authorities
As a PAGCOR-licensed operator, 39gl is required to share certain player data — including identity information and transaction records — with PAGCOR upon request, and to submit mandatory reports under the Anti-Money Laundering Act to the Anti-Money Laundering Council (AMLC). We may also disclose information to the National Privacy Commission, law enforcement agencies, and courts where required by law or court order.
5.2 Payment Processors
To facilitate deposits and withdrawals, we share the minimum necessary financial data with our approved payment processing partners, including GCash, PayMaya, and the partnered banks (BPI, BDO, Metrobank). These processors are bound by contractual data processing agreements and are prohibited from using your data for any purpose other than processing your transactions.
5.3 Technology and Service Providers
39gl engages carefully selected third-party technology providers for services such as cloud hosting, identity verification, fraud detection, and customer support software. Each provider is subject to a data processing agreement that requires them to implement appropriate technical and organisational security measures and to process your data only on 39gl's documented instructions.
5.4 Game Content Providers
Where you play games supplied by third-party software providers on the 39gl Platform, limited gameplay data (such as bet amounts and game outcomes) may be shared with those providers for the purpose of game integrity verification, RNG auditing, and regulatory compliance. Personal identification data is not shared with game software providers unless specifically required for regulatory purposes.
5.5 No Sale of Data
Firm Commitment: 39gl has never sold, and will never sell, your personal data to data brokers, advertising networks, or any third party for commercial gain. Your information is an asset we hold in trust for you — not a product we trade.
Cookies & Tracking Technologies
The 39gl Platform uses cookies and similar tracking technologies to provide you with a functional, secure, and personalised gaming experience. A cookie is a small text file placed on your device when you visit the Platform. Cookies do not contain your personal identification information in plain text.
6.1 Types of Cookies We Use
| Cookie Type | Purpose | Can Be Disabled? |
|---|---|---|
| Strictly Necessary | Session management, authentication, security token validation, CSRF protection | No — Platform will not function without these |
| Functional | Remembering your language preference, game lobby layout, and responsible gaming settings | Yes — but some features may be limited |
| Analytics | Understanding how players navigate the Platform to identify performance issues and usability improvements | Yes — via cookie consent settings |
| Responsible Gaming | Tracking session duration and displaying responsible gaming prompts at defined intervals | No — required by PAGCOR guidelines |
6.2 Managing Cookies
You can control non-essential cookies through the cookie preference centre accessible via the cookie banner displayed on your first visit to the Platform. You may also manage cookies through your browser settings; however, disabling all cookies may prevent certain parts of the Platform from functioning correctly. Note that strictly necessary cookies and responsible gaming cookies cannot be disabled as they are required for the lawful operation of the Platform under PAGCOR's regulatory framework.
Data Retention
39gl retains your personal data only for as long as is necessary to fulfil the purposes set out in this Policy, or as required by applicable Philippine law and PAGCOR regulations. The table below summarises our standard retention periods for the main categories of personal data we hold:
| Data Category | Retention Period | Basis |
|---|---|---|
| Account registration data | Duration of account + 5 years after closure | PAGCOR licensing requirements |
| KYC / identity verification documents | Duration of account + 5 years after closure | Anti-Money Laundering Act (AMLA) |
| Financial transaction records | Duration of account + 5 years after closure | AMLA and PAGCOR financial reporting |
| Gameplay and wagering history | Duration of account + 3 years after closure | PAGCOR regulatory reporting |
| Customer support communications | 3 years from date of last interaction | Dispute resolution and legal claims |
| Marketing consent records | Until consent is withdrawn + 1 year | DPA 2012 accountability requirement |
| Technical / server logs | 12 months rolling | Security monitoring and fraud detection |
Upon expiry of the applicable retention period, personal data is either securely and permanently deleted from our systems or irreversibly anonymised so that it can no longer be linked to you as an individual. Anonymised data may be retained for statistical and analytical purposes without time limitation.
Security Measures
39gl implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security programme includes, but is not limited to:
- Encryption in Transit: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher, enforcing 256-bit encryption for all session data.
- Encryption at Rest: Sensitive personal data stored on 39gl servers — including KYC documents, financial records, and authentication credentials — is encrypted at rest using AES-256 encryption.
- Password Security: Player passwords are never stored in plain text. We use industry-standard bcrypt hashing with salting to store password credentials securely.
- Two-Factor Authentication: 39gl supports two-factor authentication (2FA) via one-time password (OTP) sent to your registered Philippine mobile number for account login and withdrawal verification.
- Access Controls: Access to player personal data within 39gl is restricted on a strict need-to-know basis. Staff members are granted the minimum level of data access required to perform their specific job functions.
- Penetration Testing: The 39gl Platform undergoes regular independent security assessments and penetration testing to identify and remediate vulnerabilities before they can be exploited.
- Staff Training: All 39gl personnel with access to personal data undergo mandatory data privacy and security training upon onboarding and at least annually thereafter, in accordance with NPC guidelines.
Despite these measures, no internet transmission or electronic storage system can be guaranteed to be 100% secure. If you have reason to believe your 39gl account has been compromised, please contact our support team immediately so we can take protective action on your account.
Your Data Subject Rights
Under the Data Privacy Act of 2012 of the Philippines, you have the following rights with respect to your personal data held by 39gl. We are committed to honouring these rights promptly and without unnecessary barriers.
Right to Access
You have the right to request a copy of the personal data 39gl holds about you, along with information about how it is being processed. We will respond to access requests within 15 business days.
Right to Correction
If any personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it. You can also update basic account details directly through your 39gl account settings.
Right to Erasure
You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 39gl's legal obligations under PAGCOR regulations and the Anti-Money Laundering Act.
Right to Object
You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on our legitimate interests, subject to an assessment of competing interests.
Right to Data Portability
Where technically feasible, you may request a copy of your personal data in a structured, commonly used, machine-readable format so that you can transfer it to another service provider.
Right to Complain
If you believe 39gl has not handled your personal data in accordance with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.
To exercise any of the above rights, please contact our Data Protection Officer using the contact details provided in Section 13 of this Policy. We may need to verify your identity before processing your request. We will respond to all valid data subject requests within fifteen (15) business days from receipt of a complete request, as required by the Data Privacy Act of 2012 and NPC guidelines.
Please note that certain rights are subject to limitations under Philippine law — for example, we cannot erase data that we are legally required to retain under PAGCOR regulations or the Anti-Money Laundering Act, even if you make a valid erasure request.
Minors & Age Restriction
The 39gl Platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. 39gl does not knowingly collect personal data from any individual under the age of 21. If you are under 21 years of age, you must not register an account or attempt to use the Platform.
Under-Age Access: If 39gl discovers or reasonably suspects that personal data has been collected from a person under the age of 21, we will immediately close the associated account, delete the collected personal data to the extent permitted by our legal obligations, and report the matter to PAGCOR as required. We encourage parents and guardians in the Philippines to use parental control tools to restrict access to online gaming platforms.
During the registration process, 39gl requires applicants to confirm their date of birth and agree to our Terms and Conditions, which explicitly state the 21+ age requirement. We supplement this with identity verification procedures as part of our KYC process to detect and prevent under-age registration.
International Data Transfers
39gl primarily processes and stores your personal data within the Philippines. However, in certain circumstances — such as when we use cloud infrastructure providers or game software suppliers whose servers are located outside the Philippines — your personal data may be transferred to, and processed in, countries other than the Philippines.
When such international transfers are necessary, 39gl ensures that adequate safeguards are in place to protect your personal data at a level equivalent to the protections afforded under the Data Privacy Act of 2012. These safeguards may include:
- Entering into data processing agreements that incorporate the standard contractual clauses recognised by the National Privacy Commission
- Transferring data only to countries or organisations that the NPC has determined provide an adequate level of data protection
- Obtaining your explicit consent to the transfer in cases where no other adequate safeguard applies
By using the 39gl Platform, you acknowledge that your personal data may be transferred internationally in the circumstances described above, subject always to the safeguards outlined in this section.
Changes to This Policy
39gl reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine laws and regulations, PAGCOR requirements, or the features and services offered on the Platform. All changes will be effective from the date they are published on this page.
When we make material changes to this Policy — that is, changes that significantly affect how we collect, use, or share your personal data — we will notify you by:
- Displaying a prominent notice on the 39gl Platform homepage and login page
- Sending a notification to your registered email address at least 14 days before the changes take effect
- Updating the "Effective Date" at the top of this Policy
Your continued use of the 39gl Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you should stop using the Platform and may request closure of your account in accordance with our Terms and Conditions.
We recommend that you review this Privacy Policy periodically to stay informed about how 39gl protects your personal data. The current version of this Policy is always accessible at https://39gl.bet/privacy-policy.
Contact Our Data Protection Officer
39gl has appointed a Data Protection Officer ("DPO") as required by the Data Privacy Act of 2012 and the National Privacy Commission's guidelines on DPO registration. Our DPO is responsible for overseeing compliance with this Policy and with applicable Philippine data privacy laws.
If you have any questions, concerns, or requests relating to this Privacy Policy or to the processing of your personal data by 39gl, please contact our DPO using the details below:
Data Protection Officer — 39gl
Email: [email protected]
Subject Line: Data Privacy Request / DPO Inquiry
Response Time: Within 15 business days of receipt
Operating Hours: Monday to Friday, 9:00 AM – 6:00 PM PHT
If you are not satisfied with the response you receive from our DPO, or if you believe that 39gl is processing your personal data in violation of the Data Privacy Act of 2012, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint is available on the NPC's official website.
For general customer support inquiries unrelated to data privacy — such as account issues, bonus queries, or gameplay assistance — please contact our 24/7 support team via the live chat function on the Platform or by emailing [email protected].
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