789pub Privacy Policy

1.Introduction

This Privacy Policy ("Policy") explains how 789pub ("789pub," "we," "us," or "our") collects, uses, stores, and protects personal data relating to individuals ("you," "Player," or "User") who access or use the 789pub online casino and sports betting platform at https://789pub.club and any associated mobile-optimised interfaces (the "Platform").

789pub is committed to protecting the privacy and personal data of its players in accordance with the Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), and its implementing rules and regulations as issued by the National Privacy Commission ("NPC"). By registering an account or using the Platform, you consent to the collection and processing of your personal data as described in this Policy.

2.Data Controller

789pub is the data controller responsible for the personal data collected through the Platform. As data controller, 789pub determines the purposes and means of processing your personal data and is accountable for ensuring that processing is carried out lawfully, fairly, and transparently.

789pub has designated a Data Protection Officer ("DPO") responsible for overseeing compliance with this Policy and applicable data protection laws. Contact details for the DPO are provided in Section 14 of this Policy.

3.Personal Data We Collect

789pub collects personal data through several means: directly from you when you register, through your use of the Platform, and automatically through technical systems. The categories of data we collect include:

789pub does not collect sensitive personal data (as defined under the DPA) except where required for identity verification or responsible gaming compliance, in which case such collection is carried out with your explicit consent and under appropriate safeguards.

4.How We Use Your Personal Data

789pub uses your personal data for the following purposes:

• Account Management: To create, manage, and maintain your 789pub account, including verifying your identity and age (21+ requirement) during registration and at withdrawal.
• Platform Services: To enable you to deposit funds, place bets, play games, and withdraw winnings through the Platform.
• Payment Processing: To process GCash, PayMaya, BPI, BDO, and Metrobank transactions, including verifying that payment accounts belong to the registered account holder.
• Regulatory Compliance: To comply with PAGCOR regulatory requirements, anti-money laundering obligations under the Philippine Anti-Money Laundering Act ("AMLA"), and other applicable laws.
• Fraud Prevention and Security: To detect, investigate, and prevent fraud, money laundering, unauthorised account access, and other prohibited activities on the Platform.
• Customer Support: To respond to your queries, complaints, and requests via live chat and email.
• Responsible Gaming: To enforce self-exclusion requests, deposit limits, and other responsible gaming tools; to identify and respond to signs of problem gambling behaviour.
• Platform Improvement: To analyse usage patterns, identify technical issues, and improve the Platform's features, performance, and user experience.
• Marketing Communications: To send you promotional offers and information about new games or features at 789pub — only where you have provided your explicit opt-in consent. Marketing communications can be withdrawn at any time.

5.Legal Basis for Processing

Under the Data Privacy Act of 2012, 789pub processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 789pub (the Terms & Conditions), including account operations, payment processing, and game delivery.
• Legal Obligation: Processing is necessary to comply with legal obligations under Philippine law, including AMLA requirements, PAGCOR regulations, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for 789pub's legitimate interests, including fraud prevention, platform security, and improving services — provided those interests are not overridden by your rights and interests.
• Consent: For marketing communications and certain non-essential analytics, 789pub relies on your explicit consent, which can be withdrawn at any time without affecting the lawfulness of prior processing.

6.Data Sharing and Disclosure

789pub does not sell your personal data. We may share your personal data with the following categories of recipients in the circumstances described:

• Payment Processors: GCash (G-Xchange Inc.), PayMaya (PayMaya Philippines Inc.), BPI, BDO, and Metrobank — solely to process your deposits and withdrawals. Each processor operates under its own privacy policy and applicable Philippine financial regulations.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, Philippine National Police, and other authorities where disclosure is required by applicable law, court order, or regulatory directive.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to support our 21+ verification obligations. These providers are contractually bound to process data only for the specified purpose.
• Technology and Infrastructure Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on 789pub's behalf under strict data processing agreements.
• Game Content Providers: Certain aggregated, non-personally-identifiable game interaction data may be shared with licensed game studios for RTP auditing and technical support purposes.

All third parties with whom 789pub shares personal data are required to maintain appropriate technical and organisational security measures and to process data solely for the purposes specified by 789pub.

7.Cookies and Tracking Technologies

789pub uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential Cookies: Required for the Platform to function, including maintaining your login session and remembering your preferences. These cannot be disabled without impairing Platform functionality.
• Analytics Cookies: Used to collect aggregated data about how players navigate and interact with the Platform, helping us identify usability issues and improve performance.
• Security Cookies: Used to detect unusual or suspicious activity, protect against fraud, and enforce access controls on restricted areas of the Platform.

You may manage cookie preferences through your browser settings. Disabling essential cookies will impair your ability to use the Platform, including the login function. Analytics cookies can be disabled without affecting core Platform functionality.

8.Data Retention

789pub retains personal data for the following periods, or longer where required by applicable law:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements applicable to covered transactions in the Philippines.
• Transaction and Betting Records: Retained for a minimum of five (5) years in compliance with AMLA and PAGCOR regulatory record-keeping requirements.
• Customer Support Records: Retained for three (3) years following resolution of the relevant query or complaint.
• Technical and Usage Data: Retained for twelve (12) months for security analysis and platform improvement purposes, after which it is anonymised or deleted.
• Marketing Consent Records: Retained for the duration of the marketing relationship and for two (2) years following withdrawal of consent, as evidence of prior lawful processing.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with 789pub's data destruction procedures.

9.Data Security

789pub implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and the Platform.
• Encryption of sensitive data at rest within 789pub's database infrastructure.
• Role-based access controls limiting internal access to personal data to authorised personnel on a need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability management programmes.
• Multi-factor authentication for all internal systems that process personal data.
• Incident response procedures aligned with the NPC's data breach notification requirements under the DPA.

In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 789pub will notify the National Privacy Commission within 72 hours of becoming aware of the breach and will communicate the breach to affected players without undue delay where required by law.

10.Your Data Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 789pub:

• Right to Be Informed: The right to be informed of the collection, use, and processing of your personal data — which this Policy satisfies.
• Right of Access: The right to obtain confirmation of whether 789pub holds your personal data and to receive a copy of that data.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations.
• Right to Object: The right to object to processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability: The right to receive personal data you have provided to 789pub in a structured, commonly used, machine-readable format.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, contact 789pub's Data Protection Officer using the contact details in Section 14. 789pub will respond to verified requests within thirty (30) days. Identity verification will be required before processing data access, rectification, or erasure requests.

11.Minors and Age Restrictions

The 789pub Platform is strictly prohibited to persons under 21 years of age in accordance with PAGCOR minimum age requirements. 789pub does not knowingly collect personal data from persons under 21.

If 789pub discovers that an account has been registered by a person under 21, the account will be immediately closed, all balances forfeited, and the personal data associated with the account deleted or anonymised in accordance with our data retention procedures, except where retention is required for regulatory compliance.

If you believe that 789pub has inadvertently collected personal data from a person under 21, please contact our Data Protection Officer immediately.

12.International Data Transfers

Where 789pub transfers personal data to service providers or partners located outside the Philippines, such transfers are made only where the recipient country or organisation provides an adequate level of protection for personal data as determined by the NPC, or where appropriate safeguards — such as standard contractual clauses or binding corporate rules — are in place to protect your data rights.

In all cases, 789pub ensures that international transfers of Philippine player data comply with the requirements of the Data Privacy Act of 2012 and the NPC's applicable implementing rules.

13.Updates to This Policy

789pub may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or Platform features. The date of the most recent update is displayed at the top of this Policy.

For material changes that significantly affect your rights or how your data is processed, 789pub will provide advance notice via email to your registered address or through a prominent notification on the Platform. Continued use of the Platform following the effective date of a revised Policy constitutes your acceptance of the revised terms.

14.Contact and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact 789pub through the following channels:

• Live Chat: Available 24/7 on the Platform — fastest response for general privacy queries
• Email (Data Requests): [email protected]
• Response Time: Within 2 minutes via live chat; within 4 hours via email; formal data rights requests acknowledged within 5 business days and resolved within 30 days

If you are not satisfied with 789pub's response to a privacy concern, you have the right to submit a complaint to the National Privacy Commission of the Philippines (NPC). Information about the NPC complaints process is available through the NPC's official government channels.