778pub Privacy Policy

This Privacy Policy ("Policy") describes how 778pub ("778pub," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of users ("you," "your," or "Player") who access or use the 778pub website at 778pub.app and all associated services, games, and features (collectively, the "Platform").

778pub is committed to protecting the privacy and personal data of all players, particularly those accessing the Platform from the Philippines. This Policy is drafted in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC).

By registering an account on 778pub, accessing the Platform, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform immediately.

778pub collects personal data from you in several ways — directly when you provide it to us, automatically when you use the Platform, and occasionally from third-party sources. The categories of personal data we collect include:

2.1 Data You Provide Directly

• Registration Data: Full name, date of birth, email address, mobile number, and chosen username when you create a 778pub account.
• Identity Verification (KYC) Data: Government-issued ID (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license), proof of address, and selfie photographs submitted during the verification process.
• Financial Data: Payment method details including GCash account numbers, PayMaya account details, BPI, BDO, or Metrobank account information used for deposits and withdrawals. Note: 778pub does not store full card numbers or CVV codes.
• Communication Data: Messages, emails, and chat transcripts exchanged with the 778pub customer support team.
• Preference Data: Your communication preferences, responsible gaming settings, and account configuration choices.

2.2 Data Collected Automatically

• Device & Technical Data: IP address, browser type and version, operating system, device identifiers, screen resolution, and time zone settings.
• Usage Data: Pages visited, games played, session duration, click patterns, search queries within the Platform, and features accessed.
• Transaction Data: Records of all deposits, withdrawals, bets placed, game results, bonus activations, and account balance history.
• Cookie Data: Information collected through cookies and similar tracking technologies as described in Section 6 of this Policy.

2.3 Data from Third Parties

• Identity verification data from third-party KYC service providers used to confirm the authenticity of documents you submit.
• Fraud prevention and anti-money laundering screening data from compliance service providers.
• Payment confirmation data from payment processors including GCash, PayMaya, and banking partners.

778pub uses the personal data we collect for the following purposes:

778pub will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable Philippine law.

Under the Data Privacy Act of 2012 (RA 10173), 778pub processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 778pub — specifically, to operate your account, process transactions, and deliver gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering regulations (AMLA), PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for 778pub's legitimate business interests, including fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — we rely on your freely given, specific, and informed consent. You may withdraw this consent at any time.

778pub does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers to facilitate deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and AML compliance service providers who assist in verifying your identity and screening for financial crime risks.
• Game Software Providers: Game developers and platform providers (such as Playtech) whose games are hosted on the 778pub Platform, to the extent necessary to deliver game services.
• IT and Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who process data on our behalf under strict data processing agreements.
• Regulatory and Law Enforcement Authorities: Government agencies, regulators (including PAGCOR and the National Privacy Commission), and law enforcement bodies where disclosure is required by law or court order.
• Professional Advisors: Legal counsel, auditors, and accountants where necessary for the conduct of 778pub's business operations.

All third parties with whom 778pub shares personal data are required to handle that data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than those specified by 778pub.

778pub uses cookies and similar tracking technologies (such as web beacons and pixel tags) to enhance your experience on the Platform, remember your preferences, and gather analytics data that helps us improve our services.

Types of cookies we use:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, preferred payment method, and responsible gaming limits to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how players use the Platform — which pages are visited most, how long sessions last, and where users navigate from. This data helps 778pub improve the Platform.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your interests and gaming activity. These are only activated with your consent.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 778pub Platform. For detailed instructions on managing cookies in your specific browser, please refer to your browser's help documentation.

778pub retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

• Active Account Data: Retained for the duration of your account's active status on the Platform.
• Transaction Records: Retained for a minimum of five (5) years following the date of the transaction, in compliance with Philippine anti-money laundering regulations under RA 9160 (AMLA) as amended.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the last transaction, whichever is later.
• Customer Support Communications: Retained for three (3) years from the date of the last communication.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years thereafter as evidence of consent.
• Closed Account Data: Following account closure, personal data is retained for the minimum period required by law before being securely deleted or anonymized.

When personal data is no longer required, 778pub will securely delete or anonymize it in accordance with our internal data disposal procedures.

778pub implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• 256-Bit SSL/TLS Encryption: All data transmitted between your device and the 778pub Platform is encrypted using industry-standard SSL/TLS protocols.
• Data Encryption at Rest: Sensitive personal data stored in our databases is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized 778pub personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Two-Factor Authentication: Available for player accounts to provide an additional layer of security beyond username and password.
• Regular Security Audits: 778pub conducts regular penetration testing and security audits to identify and address potential vulnerabilities in our systems.
• Incident Response: In the event of a personal data breach, 778pub will notify affected players and the National Privacy Commission in accordance with the requirements of RA 10173 and NPC Circular 16-03.

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 778pub:

The 778pub Platform is strictly intended for adults who are 21 years of age or older, in accordance with Philippine gambling regulations. 778pub does not knowingly collect personal data from individuals under the age of 21.

If 778pub becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. All funds deposited by an underage user will be returned to the payment source used, less any winnings generated.

778pub primarily processes and stores personal data within the Philippines. However, some of our third-party service providers — including cloud infrastructure providers and game software suppliers — may process data in other countries.

Where personal data is transferred outside the Philippines, 778pub ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under Philippine law. These safeguards may include:

• Contractual clauses requiring the recipient to protect personal data to Philippine standards.
• Transfers to countries that have been assessed as providing an adequate level of data protection.
• Binding corporate rules where data is transferred within a corporate group.

By using the 778pub Platform, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where necessary for the provision of our services, subject to the safeguards described above.

The 778pub Platform may contain references to third-party services such as payment processors and game providers. These third parties operate their own privacy policies, which are independent of 778pub's Privacy Policy. 778pub is not responsible for the privacy practices of any third-party services.

We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of the 778pub Platform. 778pub does not endorse or make any representations about third-party privacy practices.

778pub reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. When we make material changes to this Policy, we will:

• Post the updated Privacy Policy on this page with a revised "Last Updated" date.
• Send a notification to your registered email address where the changes are significant.
• Display a prominent notice on the 778pub Platform for a reasonable period following the update.

Your continued use of the 778pub Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Policy, you must discontinue use of the Platform and may request account closure by contacting our support team.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 778pub handles your personal data, please contact our Data Protection Officer (DPO):

• Data Protection Officer: 778pub Privacy Team
• Email: [email protected]
• Support Email: [email protected]
• Mailing Address: 778pub, Metro Manila, Philippines

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated:

• National Privacy Commission (NPC)
• Address: 3rd Floor, Core G, GSIS Headquarters, Financial Center, Roxas Boulevard, Pasay City, Metro Manila, Philippines
• Website: privacy.gov.ph