Privacy Policy – pub 774

01 Who We Are

pub 774 is an online gaming and casino platform operating under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). For the purposes of the Data Privacy Act of 2012, pub 774 acts as the Personal Information Controller (PIC) in respect of the personal data of its registered players and website visitors.

As a Personal Information Controller, pub 774 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently in accordance with applicable Philippine data protection law.

Our designated Data Protection Officer (DPO) can be contacted at the details provided in Section 14 of this Policy. The DPO is responsible for overseeing pub 774's data protection compliance programme and serves as the primary point of contact for data subjects exercising their rights under the Data Privacy Act.

02 Personal Data We Collect

pub 774 collects the following categories of personal data, depending on your interaction with the Platform:

2.1 Identity and Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth (for age verification — you must be 21 or older)
• Nationality and country of residence
• Email address and mobile phone number
• Residential address

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, driver's licence, SSS ID, PhilHealth ID, UMID)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or liveness verification images where required
• Proof of payment method ownership

2.3 Financial Data

• GCash or PayMaya account reference numbers
• Bank account details (account name and number, bank name) for withdrawal processing
• Debit card details (card number is tokenised and never stored in full)
• Transaction history, including deposits, withdrawals, and bonus credits

2.4 Gaming Activity Data

• Game session logs, including games played, wagers placed, and outcomes
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, self-exclusion status)
• Customer support interaction records

2.5 Technical and Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Pages visited, time spent on the Platform, and clickstream data
• Login timestamps and session duration
• Cookie identifiers and similar tracking technologies (see Section 7)

03 How We Collect Your Data

pub 774 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the Platform, through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance service providers; payment verification data from payment processors.
• Regulatory sources: Information received from PAGCOR or other regulatory authorities in connection with licensing, compliance, or enforcement matters.

04 Why We Use Your Personal Data

pub 774 uses your personal data for the following purposes:

05 Legal Basis for Processing

Under the Data Privacy Act of 2012, pub 774 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you as a registered player, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws, including PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act itself.
• Legitimate interests: Processing for fraud prevention, platform security, and analytics, where our legitimate interests are not overridden by your data protection rights.
• Consent: Processing for direct marketing communications, where we have obtained your explicit consent. You may withdraw this consent at any time by contacting customer support or using the unsubscribe mechanism in our communications.

06 Data Sharing and Disclosure

pub 774 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:

6.1 Service Providers (Personal Information Processors)

pub 774 engages third-party service providers who process personal data on our behalf, including KYC and identity verification providers, payment processors, fraud detection services, cloud hosting providers, and customer support platform providers. All such providers are bound by data processing agreements that require them to process your data only on pub 774's instructions and in compliance with applicable data protection law.

6.2 Regulatory and Law Enforcement Authorities

pub 774 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine government authorities where required by law, court order, or regulatory direction. Such disclosures are made only to the extent required and in accordance with applicable legal procedures.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of pub 774's assets, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the privacy practices of the acquiring entity prior to the transfer taking effect.

07 Cookies and Tracking Technologies

pub 774 uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function, including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and responsible gaming tool configurations, to personalise your experience.
• Analytics cookies: Collect anonymised data about how players use the Platform to help us identify areas for improvement. This data does not identify you personally.
• Marketing cookies: Used only with your consent to deliver relevant promotional content. You may opt out of marketing cookies at any time through your account settings or by contacting support.

You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies may affect the functionality of the Platform. For a full list of cookies used by pub 774, please contact our Data Protection Officer.

08 Data Retention

pub 774 retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and KYC data: Retained for a minimum of five (5) years after account closure, as required by PAGCOR licensing conditions and the Anti-Money Laundering Act.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA requirements.
• Customer support records: Retained for three (3) years from the date of the interaction.
• Marketing consent records: Retained for the duration of your consent and for three (3) years thereafter as evidence of consent.
• Technical and usage data: Retained for up to two (2) years, after which it is anonymised or deleted.

Upon expiry of the applicable retention period, pub 774 will securely delete or anonymise your personal data in accordance with our data disposal procedures. Where data is anonymised rather than deleted, the anonymised data may be retained indefinitely for statistical and analytical purposes, as it no longer constitutes personal data under the Data Privacy Act.

09 Data Security

pub 774 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• Encryption: All data transmitted between your device and the pub 774 Platform is encrypted using industry-standard TLS (Transport Layer Security) protocols. Sensitive data at rest, including financial information and KYC documents, is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to authorised pub 774 personnel and service providers on a strict need-to-know basis. All staff with access to personal data undergo data protection training and are bound by confidentiality obligations.
• Two-factor authentication: pub 774 supports and encourages the use of two-factor authentication (2FA) for all player accounts to reduce the risk of unauthorised access.
• Penetration testing: The Platform undergoes regular security assessments and penetration testing by independent security professionals to identify and remediate vulnerabilities.
• Incident response: pub 774 maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects without undue delay, as required by the Data Privacy Act.

10 Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by pub 774:

10.1 Right to Be Informed

You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfils that obligation. If you have questions not addressed here, you may contact our Data Protection Officer.

10.2 Right of Access

You have the right to request a copy of the personal data pub 774 holds about you, along with information about how it is being processed. Access requests will be fulfilled within fifteen (15) business days of receipt, subject to identity verification.

10.3 Right to Rectification

If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update certain account details directly through your account settings, or contact customer support for assistance with other data corrections.

10.4 Right to Erasure

You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, or where you withdraw consent and there is no other legal basis for processing. Note that this right is subject to pub 774's legal obligations to retain certain data under PAGCOR regulations and the Anti-Money Laundering Act, which may override erasure requests in specific circumstances.

10.5 Right to Object

You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, though pub 774 may continue processing if it can demonstrate compelling legitimate grounds that override your interests.

10.6 Right to Data Portability

Where technically feasible, you have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another personal information controller.

10.7 Right to Lodge a Complaint

If you believe pub 774 has not handled your personal data in accordance with the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through their official government channels.

11 Children's Privacy and Age Restriction

The pub 774 Platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with Philippine law governing casino-style gambling. pub 774 does not knowingly collect personal data from individuals under the age of 21.

If pub 774 discovers or is notified that personal data has been collected from an individual under 21 years of age, we will immediately suspend the relevant account, delete the personal data collected, and return any deposits to the payment source. If you believe that a minor has registered on the pub 774 Platform, please notify us immediately at the contact details in Section 14.

pub 774 employs age verification procedures during the registration and KYC process specifically to prevent underage access to the Platform. These procedures are a core component of our PAGCOR compliance obligations and our commitment to responsible gaming.

12 Cross-Border Data Transfers

Some of pub 774's service providers, including cloud hosting and KYC verification providers, may process personal data outside of the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to that afforded by the Data Privacy Act, pub 774 will implement appropriate safeguards to ensure your data remains protected, including:

• Contractual clauses that require the recipient to process your data in accordance with standards equivalent to those required by Philippine law.
• Verification that the recipient country or organisation has been assessed as providing adequate data protection by the National Privacy Commission.
• Binding corporate rules where the recipient is part of the same corporate group as pub 774.

By using the pub 774 Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described above.

13 Updates to This Privacy Policy

pub 774 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The effective date at the top of this Policy indicates when it was last revised.

For material changes that significantly affect your rights or the way we process your personal data, pub 774 will provide advance notice via email to your registered address or through a prominent notice on the Platform, at least fourteen (14) days before the changes take effect. For minor or administrative changes, the updated Policy will be posted on this page without separate notification.

We encourage you to review this Privacy Policy periodically to stay informed about how pub 774 protects your personal data. Your continued use of the Platform after the effective date of any update constitutes your acknowledgement of the revised Policy.

14 Contact Us and Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or pub 774's handling of your personal data, please contact our Data Protection Officer through the following channels:

For complaints that cannot be resolved through pub 774's internal process, you may contact the National Privacy Commission (NPC) of the Philippines through their official government website and complaint channels.