pub779 Privacy Policy — How We Collect, Use, and Protect Your Personal Data

pub779 operates pub779.org, a PAGCOR-regulated online gaming platform serving Filipino players across the Philippines. As the operator of this platform, pub779 acts as the Personal Information Controller as defined under Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), with respect to the personal data of its registered Players and website visitors.

pub779 is committed to protecting the privacy and confidentiality of personal information in a manner consistent with the DPA, its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines, as well as the data protection requirements imposed by PAGCOR as a condition of pub779's operating license.

This Policy applies to all personal data processed by pub779 in connection with the pub779 platform, including data collected through the website, through customer support interactions, and through our payment processing activities. It does not apply to the privacy practices of third-party service providers who operate their own platforms, whose privacy notices govern their respective processing activities.

pub779 collects the following categories of personal data in the ordinary course of providing its services to Filipino players:

pub779 collects personal data through the following means:

• Directly from you: When you register a pub779 Account, complete KYC verification, make a deposit or withdrawal request, contact pub779 support, set responsible gaming limits, or otherwise interact with the platform in a way that requires you to provide information;
• Automatically through platform use: Technical data including your IP address, device characteristics, and usage patterns are collected automatically when you access the pub779 website, via server logs, cookies, and similar tracking technologies described in Section 7;
• From payment service providers: When you initiate a GCash, Maya, or bank transfer transaction, pub779 receives transaction confirmation data from the relevant payment service provider, including your registered name and the transaction reference;
• From identity verification services: Where pub779 uses third-party KYC verification tools to assist with document authentication, those providers may return verification outcome data to pub779;
• From PAGCOR and regulatory sources: pub779 may receive information from PAGCOR in connection with regulatory compliance activities, including information relevant to player protection and self-exclusion registers.

Under the Data Privacy Act of 2012, pub779 processes personal data on the following lawful bases:

• Contractual Necessity: Processing required to perform the contract between pub779 and the Player — including account management, game provision, deposit and withdrawal processing, and bonus crediting;
• Legal Obligation: Processing required to comply with pub779's legal and regulatory obligations, including PAGCOR licensing requirements, anti-money laundering (AML) obligations under Republic Act No. 9160 (Anti-Money Laundering Act), KYC requirements, and mandatory reporting to PAGCOR;
• Legitimate Interests: Processing necessary for pub779's legitimate interests, including platform security, fraud detection, responsible gaming monitoring, and the improvement of pub779's services, where those interests are not overridden by the Player's rights and interests;
• Consent: Where pub779 relies on your consent for specific processing activities — such as sending promotional communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

pub779 uses the personal data it collects for the following specific purposes:

• To create, manage, and maintain your pub779 Account, including authentication and account security;
• To process deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, and other supported Philippine payment methods, and to maintain accurate transaction records in Philippine Peso;
• To conduct KYC identity verification and ongoing Customer Due Diligence (CDD) as required by PAGCOR and Philippine AML legislation;
• To provide access to pub779's games and services, including live dealer games, slots, bingo, and sports betting;
• To detect, investigate, and prevent fraudulent activity, money laundering, account abuse, and other prohibited conduct;
• To operate and enforce pub779's responsible gaming program, including monitoring for indicators of problem gambling, implementing player-requested limits, and administering self-exclusion;
• To respond to your customer support enquiries and to resolve disputes;
• To comply with mandatory reporting obligations to PAGCOR and other Philippine regulatory authorities;
• To send you transactional communications related to your Account, including deposit confirmations, withdrawal notifications, and security alerts;
• To send promotional communications, including information about pub779 bonuses and new games, where you have consented to receive such communications or where pub779 has a legitimate interest in doing so under applicable law;
• To analyse aggregated and anonymised usage data for the purpose of improving the pub779 platform, optimising game performance, and enhancing the overall player experience.

pub779 does not sell your personal data. pub779 shares personal data only in the following limited circumstances and only to the extent necessary for the stated purpose:

• Payment Processors: GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), GrabPay, and local Philippine banks (BPI, BDO, Metrobank) receive transaction-relevant data to process your deposits and withdrawals. These providers process your data under their own privacy notices and applicable Philippine financial regulations;
• KYC and Identity Verification Providers: Third-party providers engaged by pub779 to assist with identity document verification may receive copies of your submitted identification documents. These providers are bound by confidentiality obligations and applicable data protection requirements;
• PAGCOR and Philippine Regulatory Authorities: pub779 is required by its PAGCOR license to provide player data and gaming records to PAGCOR upon request, and to file mandatory reports under Philippine AML legislation with relevant authorities including the Anti-Money Laundering Council (AMLC);
• Game Software Providers: Certified game providers (such as Pragmatic Play, Hacksaw Gaming, and Play'n GO) receive limited technical data necessary to deliver game content to your device. These providers do not receive financial or identity data;
• Legal and Law Enforcement Authorities: pub779 will disclose personal data where required to do so by a valid court order, subpoena, or other lawful demand from a competent Philippine authority;
• Professional Advisors: pub779's legal, audit, and compliance advisors may access personal data on a need-to-know basis, subject to professional confidentiality obligations.

pub779 uses cookies — small text files stored on your browser — and similar technologies (such as local storage objects and session tokens) to operate the platform effectively. The types of cookies used by pub779 are as follows:

• Strictly Necessary Cookies: These are essential for the pub779 platform to function. They maintain your login session, remember your authentication state, and enable core features such as deposit and game access. These cookies cannot be disabled without disrupting your use of pub779;
• Performance and Analytics Cookies: pub779 uses anonymised analytics data to understand how players navigate the platform, which pages are most visited, and where technical issues occur. This data is used in aggregate and does not identify individual players;
• Functionality Cookies: These cookies remember your preferences, such as your language setting and any customised display options, so you do not need to re-enter them on each visit;
• Responsible Gaming Cookies: Certain cookies are used to support pub779's responsible gaming features, including session duration tracking for time reminder alerts.

pub779 does not use third-party advertising or behavioural tracking cookies. You may manage or delete cookies through your browser settings; however, disabling strictly necessary cookies will prevent you from using the pub779 platform.

pub779 retains personal data for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable law and regulatory obligation. The following general retention guidelines apply:

• Active Account Data: Personal data associated with an active pub779 Account is retained for the duration of the Account and for a period following Account closure as required by law;
• KYC and AML Records: Identity verification documents and transaction records are retained for a minimum of five (5) years following the end of the business relationship, as required under Philippine AML legislation;
• Gaming and Transaction Records: Detailed gaming activity and financial transaction records are retained for a minimum of five (5) years in compliance with PAGCOR record-keeping requirements;
• Customer Support Records: Support interaction records, including chat transcripts and email correspondence, are retained for up to three (3) years following the closure of the relevant support case;
• Responsible Gaming Records: Self-exclusion records are retained for the duration of the exclusion period and for a minimum period thereafter, to prevent the inadvertent re-activation of a self-excluded Account.

Upon the expiry of the applicable retention period, pub779 will securely delete or anonymise personal data so that it can no longer be associated with an identifiable individual.

pub779 implements appropriate technical and organisational measures to protect personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and pub779's servers;
• Encryption of sensitive personal data (including identity document copies and payment method details) stored in pub779's databases;
• Role-based access controls limiting access to personal data to those pub779 personnel with a legitimate operational need;
• Multi-factor authentication for administrative access to pub779's internal systems;
• Regular security assessments and penetration testing of pub779's platform infrastructure;
• Formal data breach response procedures, including notification to the National Privacy Commission (NPC) and to affected Players where required under the DPA.

pub779's primary operations are based in the Philippines and personal data is processed predominantly within the Philippines. In the limited circumstances where personal data is transferred to a third-party service provider operating outside of the Philippines — for example, in connection with certified game software providers or certain cloud infrastructure services — pub779 ensures that:

• The transfer is made only to a country that has been assessed as providing an adequate level of data protection, or;
• Appropriate safeguards are in place, such as contractual data protection clauses consistent with NPC guidelines, to protect the transferred data to a standard equivalent to Philippine law requirements.

pub779 does not transfer Player financial transaction data or KYC identity documents outside the Philippines except where strictly required by a payment processing chain or regulatory authority.

Under the Philippine Data Privacy Act of 2012, as a data subject you have the following rights in respect of your personal data held by pub779:

To exercise any of the above rights, please contact pub779's Data Protection Officer at the contact details provided in Section 14. pub779 will respond to all data subject requests within a reasonable period and in any event within the timeframe required by the DPA. Please note that certain rights are subject to limitations where processing is required for pub779's compliance with legal obligations.

If pub779 becomes aware that it has collected personal data from a person under the age of 21, it will take immediate steps to close the Account, void all transactions, and securely delete the personal data of the underage individual in accordance with its data retention obligations. Parents or guardians who become aware that a minor has created a pub779 Account should contact pub779 support immediately.

pub779 may update this Privacy Policy from time to time to reflect changes in its data processing practices, applicable law, or PAGCOR requirements. When material changes are made to this Policy, pub779 will provide reasonable prior notice to registered Players via email to their registered address and/or via a prominent notice on the pub779 platform.

The date on which the current version of this Privacy Policy became effective is stated at the top of the document. We encourage you to review this Policy periodically. Continued use of the pub779 platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with a material change, you may close your Account by contacting pub779 support.

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or wish to raise a concern about pub779's data handling practices, please contact the pub779 Data Protection Officer:

pub779 will acknowledge receipt of all data subject rights requests and privacy complaints within a reasonable period and will endeavour to resolve them in good faith within the timeframes required by the Data Privacy Act.

If you are not satisfied with pub779's response to a privacy complaint, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the government body responsible for enforcing the Data Privacy Act of 2012. Information on how to file a complaint with the NPC is available on the NPC's official government website. You may also escalate concerns about pub779's gaming-related data practices to PAGCOR through its official complaint channels.