Your personal information matters to us. This Privacy Policy explains exactly what data 39ph collects, why we collect it, how we use and protect it, and what rights you have as a player and as a Filipino data subject under the Data Privacy Act of 2012.
Six key commitments 39ph makes to every player regarding their personal data — before you dive into the full policy below.
39ph collects personal data for specific, legitimate purposes — account management, KYC verification, payment processing, fraud prevention, and regulatory compliance. We do not collect data beyond what is reasonably required for these purposes.
All data transmitted between your device and the 39ph platform is encrypted via TLS. Sensitive stored data — including payment details and identification documents — is encrypted at rest using industry-standard protocols.
39ph does not sell, rent, or trade your personal information to third-party advertisers, data brokers, or unrelated commercial entities. Your data stays within the 39ph ecosystem and its directly engaged service providers.
Under the Philippine Data Privacy Act of 2012, you have rights to access, correct, object to processing, and request deletion of your personal data. 39ph provides clear mechanisms to exercise each of these rights through our support channels.
39ph's data practices are aligned with Republic Act No. 10173 — the Data Privacy Act of 2012 — and the implementing rules issued by the National Privacy Commission (NPC) of the Philippines.
Personal data is retained only for as long as required to fulfil the purpose for which it was collected, or as mandated by applicable law. After the retention period expires, data is securely deleted or anonymized.
This Privacy Policy ("Policy") describes how 39ph ("39ph," "we," "us," or "our") collects, uses, processes, stores, and discloses personal information about individuals ("you," "your," or "Player") who register for or use the 39ph online gaming platform accessible at 39ph.one. This Policy applies to all services, features, and interactions provided through the Platform. By creating an account or using the Platform, you acknowledge that you have read and understood this Policy. Please read it carefully alongside our Terms & Conditions.
39ph is the data controller responsible for your personal information collected through the Platform. As data controller, 39ph determines the purposes and means by which your personal data is processed. We are committed to processing your data in a manner that is consistent with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.
Our designated Data Protection Officer (DPO) oversees compliance with data privacy obligations and serves as the primary point of contact for data subject rights requests and privacy-related inquiries. Contact details for the DPO are provided in Section 14 of this Policy.
The categories of personal data 39ph may collect about you are described in the table below. Not all data listed will be collected from every player — the specific data collected depends on your level of account activity and the services you use.
| Category | Examples of Data Collected |
|---|---|
| Identity Data | Full legal name, date of birth, nationality, government-issued ID type and number (e.g., Philippine National ID, passport, UMID, driver's license, SSS, PhilSys) |
| Contact Data | Mobile number (Globe, Smart, DITO, or any Philippine carrier), email address |
| Account Data | Username, hashed password, account creation date, login timestamps, account status, communication preferences |
| Financial Data | GCash number, Maya account details, bank account information (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records |
| Gaming Activity Data | Game session logs, wager amounts, game outcomes, bonus usage, bet history, responsible gaming settings |
| Verification Data | Copies of government-issued identification documents submitted for KYC, selfie or liveness-check images where required |
| Technical Data | IP address, device identifiers, browser type and version, operating system, screen resolution, session duration, referring URL |
| Location Data | Approximate geographic location derived from IP address; precise GPS location is not collected |
| Communications Data | Support chat transcripts, email correspondence with 39ph, feedback and survey responses |
| Marketing Preferences | Records of marketing consents given or withdrawn, promotional opt-in and opt-out history |
We do not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data, except where biometric liveness checks are specifically required for KYC verification under applicable regulatory guidance.
39ph collects personal data through the following means:
39ph processes your personal data for the following purposes:
39ph processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012:
39ph does not sell your personal data. We may share your data with the following categories of recipients, only to the extent necessary for the stated purpose:
Where 39ph engages third-party processors, we require them to implement appropriate technical and organizational measures to protect your personal data and to process it only on our documented instructions.
39ph uses cookies and similar tracking technologies on the Platform to ensure the site functions correctly, to remember your preferences, and to analyze how the Platform is used. The types of cookies we use include:
You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent certain Platform features from working as intended.
39ph implements a range of technical and organizational measures designed to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include, but are not limited to:
In the event of a personal data breach that poses a risk to your rights and freedoms, 39ph will notify affected individuals and the National Privacy Commission within the timeframes required by the Data Privacy Act of 2012 and its implementing rules.
39ph retains your personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following general retention periods apply:
After applicable retention periods have expired, personal data is securely deleted using methods that render it unrecoverable, or irreversibly anonymized so that it can no longer be associated with you.
Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 39ph:
To exercise any of these rights, please contact our Data Protection Officer through the details provided in Section 14. 39ph will respond to valid data subject rights requests within 30 calendar days. Where the request is complex or numerous, we may extend this period by a further 30 days with prior notice to you.
39ph requires all registering users to confirm that they are at least 21 years of age and to submit to identity verification that includes age confirmation. Should 39ph discover or be notified that personal data has been collected from an individual who is under 21 years of age, the relevant account will be closed immediately and the associated personal data will be deleted from our systems, except to the extent that its retention is required for fraud prevention or legal compliance purposes.
If you are a parent or guardian and believe that your child or a person under 21 for whom you are responsible has registered on the 39ph Platform, please contact us immediately using the details in Section 14 so that we may take appropriate action.
In some cases, the third-party service providers engaged by 39ph — including game studios, identity verification services, and cloud infrastructure providers — may be located outside of the Philippines. Where personal data is transferred to recipients in other countries, 39ph takes steps to ensure that an appropriate level of protection is in place, which may include:
You may contact our DPO for further information about the safeguards applied to international data transfers involving your personal data.
39ph may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. Material changes — that is, changes that meaningfully affect your rights or the way we use your data — will be communicated to registered Players through in-platform notifications or email prior to the change taking effect.
The version of this Policy displayed on the Platform at any given time is the current operative version. The effective date shown at the top of this page indicates when the current version became operative. We encourage you to review this Policy periodically.
Your continued use of the Platform following notification of an updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with the updated Policy, you may request account closure as described in our Terms & Conditions.
For questions, concerns, or requests relating to this Privacy Policy or your personal data rights, please contact our Data Protection Officer through any of the following channels:
All formal data subject rights requests — including requests for access, rectification, erasure, and data portability — should be submitted by email with "Data Subject Rights Request" in the subject line, along with enough information to verify your identity as the account holder. 39ph may request additional verification before processing a data rights request.
If you believe that 39ph has not adequately addressed your privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines.
Republic Act No. 10173 gives Filipino data subjects meaningful control over their personal information. Here's a quick summary of each right and what it means in practice at 39ph.
Request a copy of all personal data 39ph holds about you — your profile, transaction history, game logs, and more.
Have incorrect or outdated personal data corrected. Update your contact details or name if they've changed.
Request deletion of your personal data, subject to legal retention requirements. Applicable once you close your account.
Opt out of marketing communications or object to specific data processing activities, particularly profiling.
Receive your personal data in a structured, machine-readable format to transfer to another service provider where technically feasible.
Know what data is collected, how it is used, and with whom it is shared — which is the purpose of this Privacy Policy.
File a complaint with the National Privacy Commission if you believe 39ph has not handled your data in accordance with the law.
Claim compensation for damages suffered as a result of a violation of your data privacy rights under RA 10173.
We built 39ph to be a platform Filipino players can trust — with their money, with their time, and with their data. One account, 1,000+ games, GCash deposits from ₱100, and support in Tagalog and English. 21+ only — play responsibly.
Must be 21 years of age or older. Gambling can be addictive — please play responsibly.