939 Privacy Policy – How We Protect Your Data

1. What Information We Collect

939 collects personal information at different points during your use of the platform. Below is a summary of the main categories of data we gather and why.

Registration Data

When you create a 939 account, we collect the information you provide during sign-up, including your full name, date of birth, mobile number, and any additional details required to complete identity verification. An OTP is sent to your registered mobile number to confirm it is yours.

Identity Verification (KYC)

As part of the KYC process, we may ask you to submit a government-issued ID and a selfie or proof of address. This is standard practice for online betting platforms and is required before certain account actions — such as withdrawals above a set threshold — can be completed. KYC documents are stored securely and used only for verification purposes.

Transaction Data

Every deposit and withdrawal you make through 939 is recorded. This includes the amount in Philippine Peso, the payment channel used (such as GCash, Maya, or bank transfer), timestamps, and transaction reference numbers. This data is essential for account management and financial record-keeping.

Activity and Betting Data

We record the bets you place, the games you play, your wagering history, and your session activity on the platform. This data helps us provide personalised features, resolve disputes, and maintain platform integrity.

Device and Technical Data

When you access 939 via browser or mobile, we automatically collect technical information such as your IP address, device type, operating system, browser version, and session duration. This data supports platform security and helps us identify suspicious or unauthorised access attempts.

2. How We Use Your Information

939 uses the personal data we collect for the following purposes:

• Account management — creating and maintaining your player account, processing logins, and enabling account security features like OTP verification.
• Processing transactions — handling deposits and withdrawals in PHP via your chosen payment channel, and maintaining accurate financial records.
• Identity and age verification — confirming you are 21 or older and that the details you provided during registration are accurate, as required by our Terms and Conditions.
• Platform security — detecting and preventing fraud, unauthorised account access, bonus abuse, and other violations of our rules.
• Responsible gaming — monitoring account activity to support the responsible gaming tools available on the platform, including deposit limits and self-exclusion.
• Customer support — responding to your queries and resolving disputes related to your account or transactions.
• Platform improvement — analysing aggregated, anonymised usage data to improve how 939 works, which games and sports markets are most used, and where the experience can be made better.
• Communications — sending you account-related notifications such as transaction confirmations, OTPs, and updates to these policies. Marketing communications are only sent where you have not opted out.

939 does not use your personal data for automated decision-making that produces legal or similarly significant effects on you without human review.

3. Who We Share Data With

939 does not sell, rent, or trade your personal information. We share data only in the following limited circumstances:

Payment Service Providers

To process your PHP deposits and withdrawals via GCash, Maya, or Philippine bank transfer, we share the transaction details and account identifiers required by those payment providers. These providers handle your financial data under their own privacy and security standards.

Identity Verification Partners

KYC document verification may be handled by a third-party identity verification service. These partners receive only the documents and data needed to complete the verification check and are contractually prohibited from using your information for any other purpose.

Platform Technology and Hosting

939 uses third-party infrastructure providers for hosting, security, and platform operations. These providers act as data processors under our instruction and do not have independent access to your data beyond what is needed to provide their technical services.

Legal and Regulatory Disclosure

We may disclose your personal information where required by law, a court order, or a regulatory authority. In such cases, 939 will disclose only what is legally required and will inform you where permitted to do so.

Business Transfers

If 939's business or assets are transferred to another entity, player data held at the time of transfer may form part of that transaction. Any successor entity would be bound to honour this Privacy Policy or provide you with advance notice of any material changes.

4. How We Protect Your Data

The security of your personal information is a priority at 939. We implement a combination of technical and organisational measures to protect data against unauthorised access, loss, or misuse.

• SSL/TLS encryption — all data transmitted between your device and 939 is encrypted in transit, whether you are logging in, making a deposit, or managing your account settings.
• OTP verification — sensitive account actions, including login from unrecognised devices and withdrawal requests, require OTP confirmation sent to your registered mobile number.
• Access controls — internal access to player data is restricted to staff who require it to perform their role. Access is logged and reviewed on a regular basis.
• Secure storage — KYC documents and sensitive account data are stored in encrypted systems with restricted access policies.
• Fraud monitoring — automated and manual monitoring identifies unusual account activity patterns, helping to protect players from unauthorised access and financial harm.

No system is completely immune to security risks. If you suspect your 939 account has been accessed without your authorisation, contact our support team immediately so we can act quickly to secure your account and investigate.

5. How Long We Keep Your Data

939 retains your personal information for as long as your account is active and for a defined period after account closure. Retention periods vary by data type:

• Account and registration data — retained for the duration of your account and for a period after closure as required by applicable regulations.
• Transaction records — financial transaction data is retained for the period required by Philippine financial record-keeping obligations.
• KYC documents — identity documents are retained for the period specified by applicable anti-money laundering regulations and then securely deleted.
• Betting and activity history — retained while your account is active and for a reasonable period after closure to support dispute resolution.
• Technical and device data — retained for a shorter rolling period primarily for security monitoring purposes.

When data reaches the end of its retention period, it is either permanently deleted or anonymised so it can no longer be linked to you as an individual.

6. Cookies and Tracking

939 uses cookies and similar technologies to keep the platform running smoothly and to understand how players interact with the site. Here is a plain-language summary of how we use them:

Essential Cookies

These are required for the platform to function. They maintain your login session, remember your language preferences, and ensure secure navigation between sections of 939. The platform cannot operate properly without them.

Analytics Cookies

We use anonymised analytics data to understand which parts of the platform are most visited, how players navigate between sports betting, casino, and slots sections, and where improvements are needed. This data does not identify you individually.

Security Cookies

Certain cookies support the fraud detection and account security features of 939. They help us identify login attempts from unfamiliar devices and flag unusual patterns that may indicate unauthorised access.

Managing Cookies

You can manage or disable cookies through your browser settings at any time. Note that disabling essential cookies will affect platform functionality and may prevent you from logging in or completing transactions. Disabling analytics or security cookies has less impact on core features but may reduce the platform's ability to protect your account.

7. Your Rights as a Player

As a registered 939 player based in the Philippines, you have rights regarding your personal data. You can exercise any of the following by contacting our support team:

• Right of access — you can request a copy of the personal data 939 holds about you.
• Right to correction — if any of your personal data is inaccurate or outdated, you can ask us to correct it. Some corrections may require re-verification of your identity.
• Right to deletion — you can request that we delete your personal data. This right is subject to legal retention obligations — for example, we are required to keep transaction records for a set period regardless of a deletion request.
• Right to object — you can object to the use of your data for direct marketing communications. You can opt out at any time through your account settings or by contacting support.
• Right to data portability — in certain circumstances, you can request your personal data in a structured, commonly used format.

We will respond to data rights requests within a reasonable timeframe. For complex requests, we may ask you to verify your identity before we proceed to protect you against unauthorised access to your own data.

8. Minors and Age Verification

939 is strictly for players aged 21 and above. We do not knowingly collect personal data from individuals under 21. Age verification is part of the registration process, and KYC checks provide a second layer of confirmation for account holders whose age cannot be confirmed at sign-up.

If you believe a minor has created a 939 account using your details or any false information, please contact our support team immediately. Accounts found to belong to players under 21 will be closed and any balance held pending review. We take underage access seriously and act on all credible reports promptly.

Parents and guardians are encouraged to use parental control tools available on their devices and networks to prevent minors from accessing online betting platforms.

9. Changes to This Policy

939 may update this Privacy Policy from time to time as the platform, applicable regulations, or our data practices change. When we do, the "Last updated" date at the top of this page will reflect the revision date.

For significant changes — such as a new way of using your data or a new category of third party we share data with — we may notify you directly through the platform or via your registered contact details. For minor clarifications or formatting updates, the revised policy will simply be published here.

Continuing to use 939 after an updated Privacy Policy is published means you accept the changes. If you disagree with a revision, you should stop using the platform and contact support to request account closure.

10. Contact Us

If you have questions about this Privacy Policy, want to exercise any of your data rights, or need to report a potential data security concern, please reach out to the 939 support team:

• Email: [email protected]
• FAQ: Visit the FAQ page for answers to common privacy and account questions.

For data deletion requests or KYC-related queries, please include your registered account name and mobile number in your message so the right team can locate your record and respond efficiently.

This Privacy Policy is governed by the laws applicable in the Philippines. Any disputes arising from data handling practices at 939 are subject to the jurisdiction of the appropriate Philippine courts.