pub774 Privacy Policy

1. Who We Are and How to Contact Us

This Privacy Policy is issued by pub774 ("pub774," "we," "us," or "our"), the operator of the online gaming platform accessible at pub774.co and all associated subdomains (the "Platform"). pub774 operates within the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR).

For all privacy-related inquiries, data subject requests, or concerns regarding this Policy, please contact our Data Privacy Officer:

• Email: support@pub774.co (plain text only — not a clickable link)
• Response time: Within 15 business days for data subject requests; within 72 hours for urgent security-related matters.

pub774 is a data controller for personal data collected from players and visitors to the Platform and processes such data in accordance with Republic Act No. 10173 (Philippine Data Privacy Act of 2012) and its Implementing Rules and Regulations, as well as applicable PAGCOR data handling requirements.

2. Scope and Application

This Privacy Policy applies to all personal data collected from individuals who: (a) register an account on the pub774 Platform; (b) visit the pub774 website without registering; (c) contact pub774 customer support; or (d) interact with pub774 through any other digital channel operated by pub774.

This Policy does not apply to third-party websites, payment processors, or service providers linked to or integrated within the pub774 Platform. Those third parties operate under their own independent privacy policies. pub774 is not responsible for the privacy practices of third parties, including payment services such as GCash and Maya, and encourages players to review the privacy notices of any third-party service they use in connection with their pub774 account.

3. Personal Data We Collect

pub774 collects personal data that is necessary, adequate, and relevant to the specific purposes described in this Policy. The categories of personal data we collect include:

pub774 does not intentionally collect sensitive personal information (as defined under the Philippine Data Privacy Act) beyond what is strictly required for identity verification and anti-money laundering compliance. We do not collect racial or ethnic origin, political opinions, religious beliefs, or biometric data beyond government ID photographs where required for KYC.

4. How We Use Your Personal Data

pub774 uses collected personal data for the following purposes:

• Account Management: To create, verify, maintain, and administer your pub774 account, including identity verification (KYC) in compliance with PAGCOR requirements and Philippine AML law (RA 9160).
• Service Delivery: To process deposits and withdrawals via GCash, Maya, and Philippine bank channels; to provide access to games; and to credit winnings to your account wallet.
• Security and Fraud Prevention: To detect, investigate, and prevent unauthorized access, fraudulent transactions, cheating, collusion, multi-accounting, and other prohibited conduct on the Platform.
• Regulatory Compliance: To comply with PAGCOR licensing requirements, AML obligations, tax reporting requirements under Philippine law, and any lawful instruction from competent Philippine authorities.
• Responsible Gaming: To administer player protection tools including deposit limits, self-exclusion, and cool-off periods; to identify and intervene with players displaying at-risk gambling behavior patterns in accordance with PAGCOR responsible gaming standards.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Marketing: To send you promotional offers, bonuses, and updates about pub774 where you have provided consent or where we have a legitimate interest. You may opt out of marketing communications at any time through your account settings.
• Platform Improvement: To analyze aggregated usage data (in anonymized or pseudonymized form where possible) to improve platform performance, game selection, and user experience.

5. Legal Bases for Processing

pub774 processes personal data on the following legal bases under the Philippine Data Privacy Act of 2012 (RA 10173):

• Contractual Necessity: Processing required to perform the contract between pub774 and the player, including account creation, game access, and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine law, including AML obligations (RA 9160), PAGCOR regulatory requirements, and tax reporting obligations.
• Legitimate Interest: Processing for fraud prevention, platform security, and improvement of pub774's services, where such interests are not overridden by the player's data protection rights.
• Consent: Processing for marketing communications, optional profiling for personalized offers, and any processing not covered by the above bases. Consent may be withdrawn at any time without affecting the lawfulness of processing prior to withdrawal.

6. Disclosure of Personal Data to Third Parties

pub774 does not sell, rent, or trade your personal data. We disclose personal data only in the following limited circumstances:

• Payment Processors: GCash, Maya, Philippine domestic banks, and other approved payment service providers receive the minimum personal data necessary to process deposits and withdrawals on your behalf.
• Game Providers: Third-party game studios and live dealer studio operators receive technical session identifiers necessary to facilitate gameplay. These providers do not receive your full identity data.
• KYC and AML Service Providers: Identity verification and anti-money laundering screening services receive identity data as necessary to perform regulated compliance checks.
• PAGCOR and Philippine Authorities: pub774 discloses personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), law enforcement agencies, and other competent Philippine authorities when required by law or upon a lawful order.
• IT and Infrastructure Providers: Cloud hosting, data storage, and security service providers who process data on pub774's behalf under binding data processing agreements consistent with RA 10173.

All third-party processors engaged by pub774 are contractually required to handle personal data only for the specific purpose for which it is shared and in compliance with applicable privacy law.

7. Data Retention

pub774 retains personal data for as long as your account is active and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and Philippine AML record-keeping obligations under RA 9160. Financial transaction records are retained for a minimum of ten (10) years as required by AML regulations.

Where personal data is no longer required for its original purpose and no legal retention obligation applies, pub774 will securely delete or anonymize the data. Marketing preferences and consent records are retained for as long as a marketing relationship exists and for a reasonable period thereafter to evidence compliance.

8. Data Security

pub774 implements technical and organizational security measures appropriate to the nature of the personal data processed, including:

• TLS encryption for all data transmitted between your device and the pub774 Platform.
• Password hashing using industry-standard cryptographic algorithms — pub774 does not store plaintext passwords.
• Two-factor authentication (OTP via registered Philippine mobile number) for account access from unrecognized devices.
• Role-based access controls limiting pub774 staff access to personal data on a need-to-know basis.
• Regular security assessments and penetration testing of Platform infrastructure.
• Automated fraud and anomaly detection systems monitoring for unusual account activity.

In the event of a personal data breach that is likely to result in serious harm to affected individuals, pub774 will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with RA 10173 and NPC Circular 16-03.

9. Cookies and Tracking Technologies

pub774 uses cookies and similar technologies to operate the Platform, maintain session state, detect fraud, and analyze aggregate usage patterns. The types of cookies used include:

• Strictly Necessary Cookies: Required for the Platform to function (e.g., session management, login state, security tokens). These cannot be disabled.
• Analytical Cookies: Collect anonymized data on how players use the Platform to support performance optimization. These are subject to your consent preferences.
• Preference Cookies: Store your language, display, and notification settings between sessions.

pub774 does not use third-party advertising or tracking cookies. You may manage non-essential cookies through your browser settings; however, disabling strictly necessary cookies may impair your ability to use the Platform.

10. Your Rights as a Data Subject

As a data subject under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data processed by pub774:

• Right to be Informed: To receive clear information about how pub774 processes your personal data (as provided in this Policy).
• Right of Access: To request a copy of the personal data pub774 holds about you.
• Right to Rectification: To request correction of inaccurate or incomplete personal data.
• Right to Erasure or Blocking: To request deletion or blocking of personal data that is unlawfully processed, no longer necessary for its original purpose, or where consent has been withdrawn — subject to pub774's legal retention obligations under AML and PAGCOR regulations.
• Right to Data Portability: To receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Object: To object to processing based on legitimate interest, including direct marketing.
• Right to Damages: To be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorizedly used personal data.

To exercise any of the above rights, please contact our Data Privacy Officer at support@pub774.co. pub774 will respond within 15 business days. If you are unsatisfied with our response, you may lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Children and Minors

pub774 strictly prohibits access to the Platform by individuals under the age of 21 years, in accordance with PAGCOR regulations governing online casino gambling in the Philippines. 21+

pub774 does not knowingly collect personal data from individuals under the age of 21. If pub774 becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended, the data will be deleted to the extent permitted by law, and any deposits or winnings attributable to the underage account will be handled in accordance with PAGCOR's guidelines on underage player incidents.

If you believe that a minor has registered on the pub774 Platform, please notify us immediately at support@pub774.co.

12. Cross-Border Data Transfers

Some of pub774's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to countries that may not provide the same level of data protection as the Philippines, pub774 ensures that appropriate safeguards are in place, such as contractual clauses consistent with NPC-recognized standards, prior to any such transfer. pub774 does not transfer personal data internationally for purposes beyond those described in this Policy.

13. Changes to This Policy

pub774 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. Material changes will be notified to registered players via the email address or mobile number on file at least seven (7) days before the changes take effect. The current version of this Policy, together with its effective date, is always accessible at pub774.co/privacy-policy. Continued use of the Platform after the effective date of any update constitutes your acknowledgment of the revised Policy.