pub772 Privacy Policy

1. Who We Are

pub772 ("pub772," "we," "us," or "our") operates the online gaming platform accessible at pub772.app, serving registered Members across the Philippines. As the operator of the pub772 platform, pub772 acts as the data controller responsible for the personal information collected from you in connection with your use of the Services. This Privacy Policy applies to all personal data processed by pub772 in connection with the pub772 website, its games, payment processing, customer support, and promotional activities.

For any privacy-related enquiries or to exercise your rights as a data subject, please contact our Data Protection team at [email protected]. We aim to respond to all data-related requests within thirty (30) calendar days.

2. Personal Data We Collect

pub772 collects personal data in several categories depending on how you interact with the platform. The categories of personal data we may hold about you include:

pub772 does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, unless specifically required for legal compliance purposes (for example, collecting information relevant to a self-exclusion request or an at-risk player referral).

3. How We Collect Your Data

pub772 collects personal data through the following means:

• Direct interactions: Data you provide when registering a pub772 account, completing identity verification, making a deposit or withdrawal, contacting customer support, or responding to promotions.
• Automated technologies: Technical data collected automatically when you access pub772, including through cookies, web beacons, log files, and similar tracking technologies. See Section 7 (Cookies & Tracking) for details.
• Third-party sources: Data received from payment processors (GCash, Maya, bank partners), identity verification service providers, fraud detection services, and analytics providers in connection with your use of pub772 services.
• Public sources: Where permitted by applicable law and necessary for compliance purposes, information from publicly available government or legal databases.

4. How We Use Your Personal Data

pub772 uses the personal data we collect for the following purposes:

• Account registration and management: To create and maintain your pub772 Member account, verify your identity and eligibility, and manage your account settings and preferences.
• Service delivery: To provide access to games, process bets, manage your pub772 wallet, and facilitate deposits and withdrawals via GCash, Maya, and other supported payment methods.
• Legal and regulatory compliance: To fulfil obligations under applicable Philippine law and gaming regulations, including anti-money laundering (AML) requirements, know-your-customer (KYC) verification, and age verification to enforce the 21+ requirement.
• Fraud prevention and security: To detect and prevent fraudulent activity, unauthorized account access, money laundering, and other prohibited activities on the pub772 platform.
• Responsible gaming: To monitor gaming behavior for indicators of problem gambling, enforce player-requested limits and exclusions, and provide appropriate interventions where required.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance in connection with your pub772 account.
• Marketing and promotions: To send you promotional communications about pub772 offers, bonuses, and events where you have provided consent or where pub772 has a legitimate interest in doing so. You may opt out of marketing communications at any time by contacting [email protected].
• Platform improvement: To analyze usage patterns and improve the pub772 platform, game selection, payment flows, and overall user experience.

5. Legal Basis for Processing

pub772 processes your personal data on the following legal grounds under the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and other applicable data protection legislation:

• Contractual necessity: Processing necessary to perform the contract between you and pub772 — including account management, payment processing, and game delivery.
• Legal obligation: Processing required by applicable law, including AML and KYC obligations.
• Legitimate interests: Processing necessary for pub772's legitimate business interests, such as fraud prevention, platform security, and service improvement, where those interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent, including for direct marketing communications. You have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

pub772 does not sell your personal data to third parties. We 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:

• Payment processors: GCash, Maya (PayMaya), GrabPay, BPI, BDO, Metrobank, and other payment partners, for the purpose of processing transactions on your pub772 account.
• Identity verification providers: Third-party KYC and AML service providers that assist pub772 in verifying member identities and screening for compliance purposes.
• Game providers: Certified third-party game suppliers whose products are integrated into the pub772 platform, to the extent necessary to deliver game services.
• Analytics and technical service providers: Service providers that assist pub772 with platform analytics, performance monitoring, and technical infrastructure, subject to contractual data processing agreements.
• Regulatory and law enforcement authorities: Where required by applicable Philippine law, court order, or a binding request from a competent regulatory or law enforcement authority.

Where pub772 transfers your personal data to any third-party service provider, we require that such provider maintains appropriate technical and organizational security measures and processes your data solely in accordance with pub772's instructions and applicable law.

7. Cookies & Tracking Technologies

pub772 uses cookies and similar tracking technologies on its platform. Cookies are small text files stored on your device that allow pub772 to recognize your browser and remember certain information between sessions. pub772 uses the following types of cookies:

• Strictly necessary cookies: Essential for the pub772 platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Performance and analytics cookies: Used to collect aggregate information about how Members use the pub772 platform, enabling us to improve functionality and identify technical issues.
• Functionality cookies: Used to remember your preferences, such as language settings and game lobby filters, to provide a more personalized experience.

You can control non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the pub772 platform. By continuing to use pub772 after being notified of our use of cookies, you consent to the use of cookies as described in this section.

8. Data Retention

pub772 retains your personal data for as long as necessary to fulfil the purposes for which it was collected, or for as long as required by applicable law. Specific retention periods include:

• Account data: Retained for the duration of your active pub772 membership, plus a minimum of five (5) years following account closure, to comply with AML and regulatory record-keeping requirements.
• Financial transaction data: Retained for a minimum of five (5) years following the date of the transaction, in accordance with Philippine anti-money laundering regulations.
• Customer support communications: Retained for three (3) years following the resolution of the support interaction.
• Responsible gaming data: Self-exclusion and limit records are retained indefinitely to prevent re-registration in breach of an exclusion period.
• Technical and usage data: Retained for up to twelve (12) months following collection, unless required for longer periods for fraud investigation or legal proceedings.

When your personal data is no longer required for any of the above purposes, pub772 will securely delete or anonymize it in accordance with its data retention and destruction procedures.

9. Data Security

pub772 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, disclosure, alteration, or destruction. These measures include, but are not limited to:

• TLS/SSL encryption for all data in transit between your device and the pub772 platform.
• Encryption of sensitive stored data, including financial and identity information.
• Access controls limiting internal access to personal data on a strict need-to-know basis.
• Regular security assessments and penetration testing of the pub772 platform infrastructure.
• Staff training on data protection obligations and incident response procedures.

While pub772 takes all reasonable precautions to protect your data, no online platform can guarantee absolute security. In the event of a personal data breach that poses a risk to your rights and freedoms, pub772 will notify affected Members and relevant regulatory authorities as required by applicable Philippine data protection law.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules, you have the following rights with respect to the personal data pub772 holds about you:

• Right to be informed: The right to be told what personal data pub772 collects about you and how it is used — which this Privacy Policy fulfils.
• Right of access: The right to request a copy of the personal data pub772 holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data in your pub772 account.
• Right to erasure ("right to be forgotten"): The right to request deletion of your personal data, subject to pub772's legal obligation to retain certain records for regulatory compliance purposes.
• Right to object: The right to object to pub772's processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe pub772 has violated your data privacy rights.

To exercise any of these rights, please contact pub772 at [email protected] with a clear description of your request. pub772 will respond within thirty (30) calendar days. Identity verification may be required before processing your request.

11. Children's Privacy

The pub772 platform is strictly intended for adults aged 21 years and above in accordance with applicable Philippine gaming regulations. pub772 does not knowingly collect personal data from individuals under the age of 21. If pub772 becomes aware that personal data has been collected from a person under the minimum age, that account will be immediately closed and all associated personal data will be deleted, except where retention is required by law.

If you are a parent or guardian and believe that your child has registered a pub772 account or provided personal data to pub772 in breach of the age requirement, please contact us immediately at [email protected] so that we can take appropriate action.

12. Updates to This Privacy Policy

pub772 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or the pub772 platform. When material changes are made, pub772 will notify registered Members via their registered mobile number or by displaying a prominent notice on the pub772 platform at least seven (7) days before the changes take effect.

The effective date at the top of this Privacy Policy indicates when the current version was last updated. We encourage you to review this Privacy Policy periodically to stay informed about how pub772 protects your personal data. Your continued use of the pub772 Services after any updated Privacy Policy takes effect constitutes your acceptance of the revised terms.

13. Contact & Data Protection Enquiries

For any questions about this Privacy Policy, to exercise your data subject rights, or to raise a privacy concern, please contact pub772's Data Protection team:

• Email: [email protected]
• Platform: pub772.app
• Response time: Within 30 calendar days for data requests; within 72 hours for urgent security matters

pub772 is committed to resolving all privacy-related concerns promptly and transparently. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.