639 Privacy Policy – How We Protect Your Personal Data

1 Introduction

639 ("we", "Platform", "639.gd") takes the privacy and personal data protection of every member seriously. This Privacy Policy is drafted to clearly and transparently explain how we collect, process, store and protect your personal information when you use the 639 platform.

This document applies to all users of the 639 platform, including website visitors, registered members and any individual who interacts with our services. By continuing to use the 639 platform, you give your consent to the practices described in this Privacy Policy.

We fully comply with Malaysia's Personal Data Protection Act 2010 (PDPA) and all related legislation in force in Malaysia. If you have any questions about how we handle your data, please contact us using the details provided at the end of this document.

2 Types of Personal Data We Collect

We collect various types of information depending on how you interact with the 639 platform. In general, the data collected can be grouped into the following categories:

Data Categories	Example Information	Requirements
Identity Information	Full name, date of birth, identification card number	Required (KYC)
Contact Information	Email address, phone number, residential address	Required
Financial Information	Bank account number, e-wallet, transaction records	Required
Technical Data	IP address, device type, web browser, operating system	Automatic
Usage Data	Game records, betting history, account activity	Automatic
Communication Data	Support correspondence, feedback, complaints	Options

We do not collect sensitive information such as biometric data, medical records, or information related to religious beliefs unless there is a specific legal requirement to do so.

3 How We Collect Data

Your personal data is collected through several primary channels:

• Account Registration: When you register a new account at 639, you are required to provide basic information such as your name, email and phone number.
• KYC Verification: During the identity verification process, you will upload a copy of your identification document for compliance and security purposes.
• Platform Activity: Each time you use the platform, our system automatically logs activities such as games played, betting amounts, and session duration.
• Financial Transactions: Deposit and withdrawal information is recorded for accounting, fraud prevention, and regulatory compliance purposes.
• Cookies and Tracking Technologies: The 639 website uses cookies to improve the user experience and analyse usage patterns on an aggregate basis.
• Support Communications: When you contact our support team, the conversation is recorded for quality control and future reference purposes.

4 Purposes for Using Your Personal Data

639 uses collected personal data solely for legitimate and responsible purposes. The following are the primary purposes for which your data is used:

• Verify your identity during registration and the KYC process to ensure account security.
• Process deposits and withdrawals quickly and securely to the account registered in your name.
• Provide effective and personalised customer support.
• Send important notifications related to your account, transactions, and platform updates.
• Detect and prevent fraudulent activity, money laundering, and unauthorised access.
• Comply with legal and regulatory obligations related to the online gambling industry.
• Analyse usage patterns to improve the functionality and overall experience of the 639 platform.
• Send promotional information and exclusive offers — only to members who have given their consent.

5 Data Sharing with Third Parties

639 does not sell or rent your personal data to any third party. However, there are limited situations where we may share your information with trusted parties:

• Payment Service Providers: Required transaction information is shared with payment gateways and banking institutions to process your deposits and withdrawals.
• Technology Service Providers: Our technical partners who assist in operating the platform infrastructure are bound by strict confidentiality agreements.
• Regulatory Authority: We may be required to disclose certain information to the relevant authorities when mandated by law.
• Fraud Prevention: In cases of suspected fraud or illegal activity, relevant information may be shared with the appropriate authorities.

All third parties we work with are bound by strict data protection agreements and are not permitted to use your data for their own purposes.

6 Data Security Measures at 639

The security of your personal data is the absolute priority of the 639 team. We implement multiple layers of technical and organisational protection to keep your data safe at all times:

• 256-bit SSL Encryption: All data transmitted between your device and 639's servers is fully encrypted using the latest security protocols.
• Strict Access Control: Only authorised staff may access members' personal data, and all such access is logged and continuously monitored.
• Two-Factor Authentication: The 639 platform supports two-factor authentication (2FA) for an added layer of account security.
• 24/7 Monitoring: Our security systems operate around the clock to detect and respond to any threats or suspicious activity.
• Regular Security Testing: The 639 platform undergoes regular security audits and penetration testing by independent experts.
• Secure Data Backup: Data is regularly backed up to a secure location to ensure service continuity and data recovery when needed.

7 Cookies and Tracking Technologies

The 639 website uses cookies and similar tracking technologies to enhance your browsing experience and understand how our platform is used. Cookies are small text files stored on your device.

Types of cookies we use:

• Essential Cookies: Required for core platform functions such as login, gaming sessions and security. These cookies cannot be disabled.
• Performance Cookies: Help us understand how members use the platform so we can make continuous improvements.
• Functional Cookies: Remember your preferences such as language, display settings, and personal preferences.
• Analytics Cookies: Collect aggregated data on website traffic for internal analysis purposes only.

You can manage your cookie settings through your web browser settings. Please note that disabling certain cookies may affect the functionality of some sections of the 639 platform.

8 Data Retention Period

639 retains your personal data only for as long as necessary for the purposes stated in this Privacy Policy or as required by law. Our data retention guidelines are as follows:

• Active account data is retained for as long as your account remains active on the 639 platform.
• Financial transaction records are retained for a minimum of 7 years in accordance with Malaysian legal requirements.
• Customer support communication logs are retained for 3 years from the date of last interaction.
• Technical data and access logs are retained for 12 months for security and troubleshooting purposes.
• Once an account is closed, personal data will be deleted or anonymized within 90 days, unless we are legally required to retain it for longer.

9 Your Rights Regarding Personal Data

As a 639 member and data subject under Malaysia's PDPA, you have the following rights regarding your personal data:

To exercise any of the above rights, please contact our privacy team. We will process your request within 14 working days. In complex cases, this period may be extended up to 30 days with notice to you.

10 Children's Privacy

The 639 platform is strictly for individuals aged 18 and above. We do not knowingly collect, process, or store personal data from individuals under the age of 18.

If we discover that personal data of a child has been collected without our knowledge, we will take immediate steps to delete that information and close the account in question. If you have reason to believe that someone under the age of 18 has registered on our platform, please notify us immediately.

11 Amendments to This Privacy Policy

639 reserves the right to update this Privacy Policy from time to time to reflect changes in our practices, legal requirements or platform improvements. Any material changes will be communicated to you through:

• Email notification to the address registered in your account.
• Notices prominently displayed on the 639 platform homepage.
• A notification pop-up will appear at the next login after changes take effect.

The latest version of this Privacy Policy is always available on the 639 website. The last updated date is displayed at the top of this document. Continued use of the 639 platform after any changes take effect will be considered your acceptance of the updated policy.

12 Contact Us About Privacy

If you have any questions, concerns, or requests regarding this Privacy Policy or how 639 handles your personal data, the 639 privacy team is here to help:

• Privacy Email: [email protected]
• Live Chat: Available 24/7 via the chat icon on the 639 platform
• FAQ: Visit the page FAQ us for a quick response