pub779 Privacy Policy

1 Definitions

The following terms carry specific meanings throughout this Privacy Policy. They are used consistently with the definitions in the Philippine Data Privacy Act of 2012 (DPA) and pub779's Terms & Conditions.

• "Personal Data" — any information that directly or indirectly identifies a natural person, including name, mobile number, email address, government ID details, IP address, and financial transaction data.
• "Sensitive Personal Information" — as defined under Section 3(l) of the DPA, including government ID numbers, financial account information, and any data expressly classified as sensitive under Philippine law.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, updating, retrieval, use, disclosure, erasure, or destruction.
• "Data Subject" — you, the individual whose Personal Data is being processed by pub779.
• "Controller" — pub779, as the entity that determines the purposes and means of processing Personal Data collected through the pub779 Platform.
• "Processor" — any third party that processes Personal Data on pub779's behalf under a documented data processing agreement.
• "NPC" — the National Privacy Commission of the Philippines, the regulatory authority overseeing compliance with the DPA.
• "PAGCOR" — the Philippine Amusement and Gaming Corporation, the regulatory body that licenses and supervises pub779's gaming operations.
• "Platform" — the pub779 website and all associated services accessible at pub779.net.

2 Scope and Data Controller

2.1 This Privacy Policy applies to all Personal Data collected, processed, and stored by pub779 in connection with your registration, use of the pub779 Platform, and any communications between you and pub779.

2.2 pub779 is the Data Controller in respect of all Personal Data described in this Policy. pub779 determines the purposes for which your Personal Data is collected and the means by which it is processed.

2.3 This Policy applies to all players who register an account on the pub779 Platform, individuals who contact pub779's support team, and visitors who browse pub779.net without registering an account (in which case limited browsing data applies — see Section 10).

3 Personal Data We Collect

3.1 pub779 collects the following categories of Personal Data from players. The specific data elements collected depend on the nature of your interaction with the Platform.

3.2 pub779 does not collect payment card data (credit or debit card numbers, CVV codes, or expiry dates) directly. All card-based transactions, if applicable, are processed by certified PCI-DSS compliant third-party payment processors, and pub779 receives only a tokenized reference, not raw card data.

4 How We Collect Your Data

4.1 Directly from you. Most Personal Data is provided directly by you during account registration, KYC submission, cashier transactions, support interactions, and promotional opt-ins.

4.2 Automatically through Platform use. Technical Data such as IP addresses, device identifiers, and session logs are collected automatically when you access the pub779 Platform, including on pages you visit without being logged in.

4.3 From third-party payment providers. When you make a deposit or withdrawal via GCash, Maya, or bank transfer, the relevant payment provider confirms transaction status and basic account verification data to pub779 as necessary for transaction processing and fraud prevention.

4.4 From identity verification services. pub779 uses third-party identity verification processors to assist with KYC and document authentication. These services confirm the validity of government-issued Philippine IDs against authoritative data sources.

4.5 From game providers. Third-party game studios and live dealer providers return game outcome data, RTP logs, and session records to pub779 as part of normal platform operation and regulatory audit requirements.

5 Purpose and Legal Basis for Processing

5.1 pub779 processes your Personal Data only for specified, explicit, and legitimate purposes. The following table describes the primary processing purposes and the corresponding legal basis under the DPA.

5.2 Where pub779 processes your data on the basis of legitimate interest, we conduct a balancing assessment to ensure that our legitimate interests do not override your fundamental privacy rights. You may request information about any specific legitimate interest assessment by contacting our Data Protection Officer.

6 Data Sharing and Disclosure

6.1 pub779 does not sell your Personal Data. pub779 does not sell, rent, or exchange your Personal Data with third-party marketers, advertising networks, or data brokers under any circumstances.

6.2 pub779 may share your Personal Data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• PAGCOR and Philippine regulatory authorities: Disclosure required as a condition of pub779's operating license, including player data in regulatory reports and investigations.
• Anti-Money Laundering Council (AMLC): Suspicious transaction reports and covered transaction reports as mandated by RA 9160 as amended.
• Payment processors: GCash (G-Xchange Inc.), Maya (PayMaya Philippines Inc.), BPI, BDO, Metrobank, and other payment service providers, solely as necessary to process deposits and withdrawals.
• KYC and identity verification providers: Third-party services engaged to verify government-issued Philippine ID documents, subject to data processing agreements.
• Game technology providers: Licensed game studios and live dealer providers that supply games to the pub779 Platform, who receive session and outcome data for RNG auditing and technical support.
• IT and cloud infrastructure providers: Server hosting, database, and security service providers operating under strict contractual data protection obligations.
• Legal and professional advisers: Attorneys, auditors, and PAGCOR-accredited compliance consultants, where required for legal proceedings or regulatory matters.
• Law enforcement and courts: Where pub779 is legally compelled to disclose data pursuant to a valid court order, subpoena, or lawful request from Philippine law enforcement authorities.

7 International Data Transfers

7.1 The pub779 Platform is operated primarily from servers located in the Philippines. However, some third-party technology providers and game studios engaged by pub779 are headquartered or operate infrastructure outside the Philippines.

7.2 Where Personal Data is transferred to a country outside the Philippines, pub779 implements appropriate transfer safeguards as required by the DPA and NPC regulations, including:

• Data processing agreements incorporating standard contractual clauses consistent with NPC requirements
• Transfer only to countries whose data protection frameworks are recognized by the NPC as providing an adequate level of protection
• Binding corporate rules where applicable within corporate group structures

7.3 You may request details of the safeguards pub779 has in place for any specific international transfer by contacting the pub779 Data Protection Officer at the contact details provided in Section 15.

8 Data Retention

8.1 pub779 retains your Personal Data for the periods described below. These periods reflect the operational requirements of the Platform and the mandatory retention obligations imposed by PAGCOR, AMLA, and Philippine tax regulations.

• Account and identity records: For the duration of your active pub779 account and for a minimum of five years following account closure, as required by AMLA and PAGCOR for audit purposes.
• Financial transaction records: A minimum of five years from the date of the transaction, in compliance with AMLA covered and suspicious transaction record-keeping requirements.
• Gaming activity logs: Three years from the date of each session, for PAGCOR regulatory reporting and dispute resolution purposes.
• Customer support communications: Three years from the date of the interaction, for quality assurance and dispute resolution.
• Marketing consent records: For as long as you remain opted in to marketing communications, and for two years following opt-out to evidence compliance with consent requirements.
• Responsible gaming records (including self-exclusion): Permanently, or for such period as required by PAGCOR, to prevent circumvention of exclusion requests.
• Technical and log data: Up to 12 months from collection, subject to anonymization where continued identification is no longer required.

8.2 Upon expiry of the applicable retention period, pub779 will securely delete or irreversibly anonymize the relevant Personal Data, unless a longer retention period is required by law or ongoing legal proceedings.

9 Security Measures

9.1 pub779 implements a layered approach to information security, combining technical, organizational, and procedural controls to protect your Personal Data against unauthorized access, disclosure, alteration, or destruction.

Technical Safeguards

• 256-bit SSL/TLS encryption for all data in transit between your device and pub779's servers
• AES-256 encryption for Personal Data stored in pub779's databases
• Multi-factor authentication for all pub779 internal system access
• Continuous network monitoring, intrusion detection, and automated threat response systems
• Regular penetration testing and vulnerability assessments by independent security firms
• Segregated access controls ensuring pub779 employees can access only the data required for their specific role

Organizational Safeguards

• Mandatory data privacy and security training for all pub779 personnel
• Documented data handling procedures and an internal privacy management programme
• Privacy Impact Assessments conducted prior to implementing new data processing activities
• A designated Data Protection Officer (DPO) responsible for DPA compliance oversight

9.2 In the event of a Personal Data breach that is likely to prejudice your rights and freedoms, pub779 will notify the NPC within 72 hours of discovery and notify affected Data Subjects without undue delay, in accordance with NPC Circular 16-03 and the DPA's breach notification requirements.

10 Cookies and Tracking Technologies

10.1 pub779 uses cookies and similar tracking technologies to operate the Platform, remember your session preferences, prevent fraud, and analyze Platform usage patterns. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session management cookies that keep you logged in and security cookies that prevent cross-site request forgery. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Remember your language preferences, account settings, and responsible gaming tool selections to improve your experience across sessions.
• Analytics Cookies: Used by pub779's internal analytics systems to understand how players navigate the Platform, identify technical issues, and measure the effectiveness of Platform improvements. Data is aggregated and anonymized where possible.
• Fraud Prevention Cookies: Used to detect and prevent fraudulent account activity, including multi-account detection and unusual login pattern analysis required by PAGCOR.

10.2 pub779 does not use third-party advertising or retargeting cookies. pub779 does not place tracking cookies from external advertising networks on the Platform.

10.3 Most web browsers allow you to manage cookie settings, including blocking or deleting cookies. Please note that blocking strictly necessary cookies will impair your ability to use the pub779 Platform, including the ability to log in.

11 Your Privacy Rights Under the DPA

11.1 As a Data Subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to the Personal Data pub779 holds about you. You may exercise any of these rights by submitting a written request to pub779's Data Protection Officer using the contact details in Section 15.

11.2 pub779 will respond to valid rights requests within 15 business days of receipt. Where a request is complex or voluminous, pub779 may extend this period by a further 15 business days, with written notice to you of the extension and the reason.

11.3 Rights requests will not be fulfilled where doing so would conflict with pub779's mandatory PAGCOR or AMLA compliance obligations, active legal proceedings, or a lawful order from a Philippine court or authority.

12 Minors and Age Restriction

12.1 The pub779 Platform is strictly restricted to individuals aged 21 years and above. pub779 does not knowingly collect Personal Data from persons under the age of 21.

12.2 Age is verified as part of the KYC process, and accounts found to belong to persons under 21 will be immediately closed in accordance with pub779's Terms & Conditions and PAGCOR requirements.

12.3 If pub779 becomes aware that Personal Data of a person under 21 has been inadvertently collected, that data will be deleted promptly and the matter reported to PAGCOR and, where appropriate, relevant Philippine authorities.

13 Third-Party Links

13.1 The pub779 Platform does not contain links to external third-party websites. All navigation within pub779.net remains on the pub779 domain.

13.2 Game content is delivered via embedded technology from licensed game providers. These providers operate their game engines under their own privacy and security frameworks. pub779 ensures all embedded game providers are contractually bound by data protection obligations consistent with the DPA, though pub779 is not responsible for the independent privacy practices of game provider companies in their own external contexts.

14 Updates to This Privacy Policy

14.1 pub779 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, NPC guidance, or PAGCOR requirements.

14.2 Material updates — those that meaningfully affect your rights or pub779's data processing obligations — will be communicated to registered players via email or prominent in-Platform notification at least seven days before the updated Policy takes effect.

14.3 The current version of this Privacy Policy is always accessible at pub779.net/privacy-policy. The "Last Updated" date at the top of this document reflects when the most recent revision was made.

14.4 Your continued use of the pub779 Platform after the effective date of an updated Privacy Policy constitutes your acknowledgment of the revised terms. If you do not accept an updated Policy, you should close your Account before the effective date of the revision.

15 Contact and Data Protection Officer

15.1 pub779 has appointed a Data Protection Officer (DPO) as required under the Philippine Data Privacy Act and NPC regulations. The DPO is responsible for overseeing pub779's compliance with the DPA and this Privacy Policy.

15.2 You may exercise your data subject rights, raise a privacy concern, or contact pub779's DPO through the following channels:

• Email: [email protected] — please include "Privacy Request" or "DPO Enquiry" in the subject line
• Live Chat: Available 24/7 via pub779.net — request to speak with the compliance team for privacy matters
• Operating Hours: 24 hours a day, 7 days a week for general support; privacy-specific requests are handled on business days within the 15-day response window

15.3 If you are not satisfied with pub779's response to a privacy concern or rights request, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines (NPC). Information on NPC complaint procedures is available through official Philippine government channels.