39daph Privacy Policy

1 Who We Are

This Privacy Policy is issued by 39daph ("the Company", "we", "us", "our"), the operator of the online gaming and sports betting platform accessible at 39daph.cam (the "Platform"). As the entity that determines the purposes and means of processing your personal data, 39daph acts as the Personal Information Controller as defined under the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines.

By accessing or using the 39daph Platform, registering an account, or providing us with your personal information in any form, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read alongside the 39daph Terms & Conditions and the Responsible Gaming Policy, all of which form part of the agreement between you and the Company.

2 Personal Data We Collect

39daph collects personal data from you in the following categories depending on how you interact with the Platform:

2.1 Registration & Identity Data

When you create a 39daph account, we collect: your full legal name, date of birth, gender, Philippine mobile number, email address, and a username and password of your choosing. This information is mandatory — without it, we cannot create your account or verify your eligibility to use the Platform.

2.2 Identity Verification (KYC) Data

To comply with anti-money laundering regulations and to verify that you meet the minimum age requirement of 21 years, we collect copies of government-issued Philippine identification documents. Acceptable documents include: Passport, Driver's License, SSS ID, PhilHealth ID, UMID, and Voter's ID. We may also collect a selfie photograph for biometric comparison purposes.

2.3 Financial Data

When you make deposits or withdrawals, we collect payment method details including your GCash-registered mobile number, Maya account reference, bank account name and number, or other payment identifiers. We do not store full card numbers or CVV codes on our servers; this data is handled directly by our payment processors.

2.4 Transactional Data

We maintain records of all financial transactions conducted through your 39daph account, including deposits, withdrawals, bonuses claimed, wagers placed, game results, and account balance history. This data is required for financial reconciliation, regulatory compliance, and dispute resolution.

2.5 Technical & Usage Data

When you access the Platform, we automatically collect: your IP address, device type and operating system, browser type and version, referring URL, pages visited, session duration, and interaction logs. This data is used for security monitoring, fraud prevention, and Platform performance optimization.

2.6 Communications Data

If you contact 39daph Support via live chat or email, we retain records of those communications including the content of your messages, the date and time of contact, and the resolution provided. This data is used for quality assurance, staff training, and regulatory record-keeping.

3 How We Use Your Personal Data

39daph uses the personal data we collect for the following purposes:

We will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your separate, specific consent.

4 Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173), 39daph relies on the following legal bases for processing your personal data:

• Contract Performance: Processing is necessary to perform the agreement between you and 39daph, including account creation, game play, and payment processing.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including KYC requirements under the Anti-Money Laundering Act (AMLA), PAGCOR licensing conditions, and tax reporting obligations.
• Legitimate Interest: Processing is necessary for 39daph's legitimate interests in fraud prevention, network security, and Platform performance — provided these interests are not overridden by your privacy rights.
• Consent: For processing activities not covered by the above bases, such as sending marketing communications, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time.

5 Sharing Your Personal Data

39daph does not sell or rent your personal information to third parties. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

5.1 Payment Processors

To process GCash, Maya, BPI, BDO, Metrobank, and other payment method transactions, we share the minimum required financial data with our licensed payment processing partners. These partners are bound by their own privacy policies and applicable Philippine financial regulations.

5.2 Game Content Providers

Game providers such as PG Soft, Pragmatic Play, Jili, and others may receive a unique player identifier and session token to enable game launches and record game outcomes. Full personal identity data is not transmitted to game providers.

5.3 KYC and Identity Verification Services

We use licensed third-party KYC verification service providers to authenticate government-issued identification documents. These providers process your identity data under strict contractual data processing agreements consistent with RA 10173.

5.4 Regulatory Authorities

39daph may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other Philippine government authorities when required by law, court order, or regulatory directive.

5.5 Professional Advisers

We may share data with lawyers, auditors, and accountants engaged by 39daph where they need access to data to provide their professional services, subject to confidentiality obligations.

6 Data Retention

39daph retains your personal data for as long as is necessary to fulfil the purposes for which it was collected and to comply with legal retention obligations. The following general retention periods apply:

• Account and KYC records: Retained for a minimum of five (5) years after account closure, in compliance with AMLA record-keeping requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications: Retained for three (3) years from the date of the last interaction.
• Technical logs: Retained for twelve (12) months from the date of generation, unless retained longer for an active security investigation.
• Marketing consent records: Retained for the duration of your account and for three (3) years after consent is withdrawn, as evidence of the consent given.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be associated with you as an individual.

7 Cookies & Tracking Technologies

39daph uses cookies, web beacons, pixel tags, and similar tracking technologies on the Platform. These technologies help us provide you with a functional and personalized experience.

7.1 Types of Cookies We Use

• Essential Cookies: Required for core Platform functions such as maintaining your login session, processing transactions, and applying security controls. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, game lobby filters, and notification preferences.
• Analytics Cookies: Help us understand how players use the Platform, which pages are most visited, and where errors occur, so we can improve the 39daph experience.
• Security Cookies: Used to detect and prevent fraudulent activity, including device fingerprinting for duplicate account detection.

7.2 Managing Cookies

You can control non-essential cookies through your browser settings. Most modern browsers allow you to block, delete, or receive alerts about cookies. Please note that disabling certain cookies may affect the functionality of the 39daph Platform, including the ability to maintain a gaming session.

8 Your Data Subject Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 39daph:

• Right to be Informed: The right to know whether 39daph holds personal data about you and to receive a general description of how that data is processed.
• Right of Access: The right to request a copy of the personal data 39daph holds about you, including a description of its source, how it has been processed, and who it has been shared with.
• Right to Correction: The right to request correction of inaccurate, incomplete, outdated, false, or misleading personal data held about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to our legal retention obligations.
• Right to Object: The right to object to the processing of your personal data, particularly for direct marketing purposes.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please submit your request in writing to [email protected] with the subject line "Data Privacy Request — [Your Name]". We will respond to all verified data subject requests within thirty (30) days of receipt.

9 Data Security

39daph implements technical, organizational, and physical security measures designed to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our security practices include:

• TLS 1.3 encryption for all data transmitted between your device and the 39daph Platform;
• AES-256 encryption for personal data stored in our databases;
• Role-based access controls ensuring only authorized 39daph personnel can access player data;
• Regular third-party penetration testing and security audits;
• Multi-factor authentication for administrative access to player data systems;
• 24/7 automated intrusion detection and anomaly monitoring systems;
• Segregation of player funds from operational accounts in line with PAGCOR requirements.

Despite our best efforts, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 39daph will notify the National Privacy Commission and affected players within 72 hours of becoming aware of the breach, as required by NPC Circular No. 16-03.

10 Children's Privacy

The 39daph Platform is strictly intended for adults aged 21 years and older in accordance with PAGCOR regulations governing online gaming in the Philippines. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that we have inadvertently collected personal data from a person under 21, we will immediately suspend the relevant account, delete the associated personal data, and — where the account was funded — arrange for the return of any real-money balance through appropriate channels.

11 Cross-Border Data Transfers

Some of the third-party service providers 39daph works with — including game content providers, KYC service providers, and cloud infrastructure partners — may be located outside the Philippines and may process your personal data in jurisdictions other than the Philippines.

Where personal data is transferred outside the Philippines, 39daph ensures that appropriate safeguards are in place to protect your data in a manner consistent with the requirements of the Data Privacy Act of 2012. These safeguards may include contractual data processing agreements that impose equivalent data protection obligations on the recipient, or the recipient being located in a country determined by the NPC to provide an adequate level of data protection.

By using the 39daph Platform, you consent to the transfer of your personal data to third-party providers located outside the Philippines, subject to the safeguards described in this section.

12 Changes to This Privacy Policy

39daph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or Platform features. The most current version of this Policy will always be accessible at 39daph.cam/privacy-policy, with the effective date clearly stated at the top of the document.

Where changes are material — meaning they significantly affect how we collect, use, or share your personal data — we will notify registered players via their registered email address or SMS at least seven (7) days before the changes take effect. Your continued use of the Platform after the effective date constitutes your acceptance of the revised Privacy Policy.

If you do not agree with any changes to this Policy, you should stop using the 39daph Platform and contact us to request account closure and deletion of your personal data, subject to our legal retention obligations.

13 Contact & Data Protection Officer

39daph has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Policy, you may contact our DPO through the following channel:

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) if you believe that 39daph has not handled your personal data in accordance with the Data Privacy Act of 2012. The NPC can be reached at their official government website or through their public complaints procedure.