pub709 Privacy Policy

pub709 ("the Operator," "we," "us," or "our") is committed to protecting the privacy of every player who uses the pub709 Platform. This Privacy Policy has been written to comply with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations as enforced by the National Privacy Commission (NPC) of the Philippines.

This policy sets out in clear, plain English what personal data pub709 collects from Philippine players and site visitors, the specific purposes for which that data is processed, the legal basis for each processing activity, the third parties with whom data may be shared, and the rights available to you as a data subject under Philippine law.

This Privacy Policy should be read together with the pub709 Terms & Conditions and the pub709 Responsible Gaming Policy, all of which form part of the contractual and legal framework governing your relationship with pub709. In the event of any conflict between this Privacy Policy and the Terms & Conditions on a privacy-specific matter, this Privacy Policy shall prevail.

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, pub709 is the personal information controller responsible for the personal data processed through the pub709 Platform.

pub709 has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and with applicable Philippine data privacy legislation. If you have any questions, concerns, or requests regarding your personal data, you may contact the pub709 DPO through the customer support channels listed in Section 15 of this policy.

All data processing activities conducted by pub709 are recorded in an internal data processing register maintained by the DPO and subject to periodic review to ensure continued accuracy and compliance.

pub709 collects personal data from you at various points during your use of the pub709 Platform. The categories of personal data collected are set out in the table below:

pub709 does not collect sensitive personal information as defined under Section 3(l) of the Data Privacy Act — such as health data, political affiliation, or religious beliefs — except where a player voluntarily discloses such information in the context of a responsible gaming self-exclusion or dispute communication, in which case it is treated with the highest level of confidentiality.

pub709 uses personal data collected from Philippine players for the following specific and documented purposes:

• Account Registration and Authentication: To create and maintain your pub709 account and to verify your identity during each pub709 Login session;
• KYC and Age Verification: To verify that you meet the 21+ age requirement under applicable Philippine gaming regulations and to confirm your identity before processing any withdrawal request;
• Payment Processing: To process deposits via GCash, PayMaya, BPI, BDO, Metrobank, and USDT, and to fulfil withdrawal requests to your nominated payment method;
• Regulatory Compliance: To meet pub709's obligations under Philippine gaming regulations, the Anti-Money Laundering Act (RA 9160 as amended), and the Data Privacy Act of 2012;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorised access, multi-accounting, and other security threats to the pub709 Platform;
• Responsible Gaming: To monitor gaming patterns for indicators of problem gambling, to administer self-exclusion requests and deposit limit activations, and to deliver responsible gaming communications where warranted;
• Customer Support: To respond to your queries, resolve disputes, and maintain records of support interactions for quality and compliance purposes;
• Platform Improvement: To analyse aggregated, anonymised usage data to improve the pub709 Platform's performance, game offering, and user experience;
• Promotional Communications: To send you information about pub709 bonuses and promotions where you have opted in to receive such communications — you may opt out at any time via your account settings.

pub709 does not use personal data for automated decision-making that produces legal or similarly significant effects, except where required by AML compliance screening processes, which are subject to human oversight.

Under the Data Privacy Act of 2012, pub709 processes personal data on the following legal bases:

• Contractual Necessity: Processing necessary to perform the pub709 player agreement, including account management, payment processing, and the provision of gaming services;
• Legal Obligation: Processing required to comply with Philippine law, including AMLA reporting obligations, KYC requirements under gaming regulations, and data preservation obligations;
• Legitimate Interests: Processing necessary for pub709's legitimate interests in fraud prevention, platform security, and responsible gaming monitoring, where those interests are not overridden by your fundamental rights and freedoms;
• Consent: Where required by the Data Privacy Act — specifically for direct marketing communications — pub709 relies on your freely given, specific, informed, and unambiguous consent. Consent may be withdrawn at any time without detriment to your continued use of the pub709 Platform.

pub709 may share personal data with the following categories of third parties, strictly for the purposes described:

• Payment Service Providers: GCash (G-Xchange Inc.), PayMaya (Maya Bank), BPI, BDO, Metrobank, and cryptocurrency processing partners receive the minimum financial data necessary to process deposit and withdrawal transactions;
• KYC and Identity Verification Partners: Third-party KYC technology providers engaged by pub709 to assist with automated identity document verification and liveness checking. All such providers operate under strict data processing agreements and may not retain your data beyond the period required to complete the verification;
• Gaming Software Providers: Slot, live dealer, bingo, and sportsbook software providers may receive session-level data necessary to operate the relevant game or betting platform. Individual provider privacy practices are governed by separate agreements with pub709;
• Philippine Government Authorities: pub709 is legally required to share certain transaction data and suspicious activity reports with the Anti-Money Laundering Council (AMLC) and, where applicable, with PAGCOR and other authorised Philippine regulatory bodies. Such disclosures are made only to the extent required by law;
• Professional Advisers: pub709's legal counsel, accountants, and auditors may access personal data on a strictly need-to-know basis and are bound by professional confidentiality obligations.

All third-party data processors engaged by pub709 are contractually required to process personal data only on pub709's documented instructions, to implement appropriate technical and organisational security measures, and to comply with applicable Philippine data privacy law.

The pub709 Platform uses cookies and similar tracking technologies to provide you with a functional, personalised, and secure gaming experience. A cookie is a small text file placed on your device when you visit a website. pub709 uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the pub709 Platform to function. These cookies maintain your pub709 Login session, remember your preferences within the active session, and enable security features such as CSRF protection. These cookies cannot be disabled;
• Functional Cookies: Allow pub709 to remember your language preferences, preferred game lobby view, and responsible gaming settings between sessions. Disabling these cookies will not prevent Platform access but may affect your user experience;
• Analytical Cookies: pub709 uses anonymised, aggregated analytics data to understand how players navigate the Platform — such as which game categories are most visited and which pages have the highest exit rates. This data is used solely to improve the Platform and is never used to identify individual players;
• Security and Fraud Detection Cookies: Used to detect and prevent suspicious activity, bot access, and multi-accounting attempts on the pub709 Platform. These cookies are strictly necessary for platform integrity.

pub709 does not use third-party advertising or retargeting cookies. You will not be tracked across other websites for advertising purposes based on your pub709 Platform activity.

You may manage cookie preferences through your browser settings. Deleting or blocking cookies that are strictly necessary for pub709 Login and session management may prevent you from accessing the pub709 Platform.

pub709 retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to any longer retention periods required by applicable Philippine law. The following retention periods apply:

• Active Account Data: Retained for the duration of your active pub709 account relationship plus a period of five (5) years following account closure, to meet AML record-keeping requirements under RA 9160;
• KYC Documentation: Retained for five (5) years from the date of verification or from the date of account closure, whichever is later, in accordance with AMLC requirements;
• Transaction Records: Retained for five (5) years from the date of each transaction, as required by Philippine AML regulations;
• Customer Support Records: Retained for three (3) years from the date of the final communication in a support thread, unless the matter relates to an ongoing regulatory or legal matter in which case retention is extended for the duration of that matter;
• Technical and Server Log Data: Retained for twelve (12) months for security and fraud investigation purposes, after which it is securely deleted or anonymised;
• Marketing Consent Records: Retained for the duration of the active consent plus three (3) years following withdrawal of consent, for compliance audit purposes.

Following the expiry of the applicable retention period, pub709 will securely delete or irreversibly anonymise your personal data in accordance with industry-standard data destruction procedures.

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pub709:

• Right to Be Informed: The right to be notified that your personal data is being processed, as fulfilled by this Privacy Policy;
• Right of Access: The right to request a copy of the personal data pub709 holds about you, together with information about how it is being used;
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data pub709 holds about you. Many data fields can be updated directly from your pub709 account dashboard;
• 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 pub709's overriding legal obligations (particularly AML record-keeping requirements) which may require retention regardless of your erasure request;
• Right to Object: The right to object to processing of your personal data based on pub709's legitimate interests, including processing for direct marketing purposes. An objection to direct marketing will be honoured immediately and without condition;
• Right to Data Portability: The right to receive a structured, commonly used, machine-readable copy of the personal data you have provided to pub709, where technically feasible;
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe pub709 has processed your personal data in violation of the Data Privacy Act of 2012. The NPC can be contacted at [email protected] (plain text only — not a clickable link).

To exercise any of the above rights, please contact the pub709 Data Protection Officer via live chat or by emailing [email protected] (plain text — not a clickable link). pub709 will respond to all verified data subject requests within fifteen (15) business days. pub709 reserves the right to require identity verification before processing any data subject request to protect against unauthorised access to personal data.

The technical and organisational security measures implemented by pub709 include:

• Encryption in Transit: All data transmitted between your browser or mobile device and the pub709 Platform is encrypted using TLS 1.2 or higher (256-bit SSL);
• Encryption at Rest: Sensitive personal data stored in pub709's database infrastructure, including password hashes and financial data, is encrypted at rest using AES-256 encryption;
• Access Controls: Access to personal data within pub709's systems is restricted on a strict need-to-know basis. Internal access is controlled by role-based access management and reviewed quarterly;
• Password Security: Player passwords are stored as salted cryptographic hashes and are never stored or transmitted in plaintext. pub709 staff cannot view your password;
• Two-Factor Authentication: pub709 supports two-factor authentication (2FA) for the pub709 Login to provide an additional layer of account security;
• Penetration Testing: pub709's Platform infrastructure undergoes regular penetration testing and security assessments by qualified third-party security professionals;
• Incident Response: pub709 maintains a documented personal data breach response procedure. In the event of a data breach that poses a risk to player rights and freedoms, pub709 will notify the NPC within seventy-two (72) hours and affected players without undue delay, in accordance with NPC Circular 16-03.

pub709 employs age verification checks at the point of registration and during KYC processing to enforce the 21+ requirement. Any account found to have been registered by or on behalf of a person under the age of 21 will be immediately closed and all associated funds forfeited in accordance with the pub709 Terms & Conditions.

If pub709 becomes aware that personal data has been collected from a person under the age of 21 without appropriate parental or guardian consent, pub709 will take immediate steps to delete that data from its systems and to close the associated account. If you believe that a minor may have registered a pub709 account using false age information, please contact pub709 support immediately at [email protected] (plain text — not a clickable link).

pub709 may transfer personal data to third-party service providers whose servers or operations are located outside the Republic of the Philippines. Where such transfers occur — for example, in connection with cloud infrastructure hosting, KYC technology platforms, or gaming software providers — pub709 ensures that appropriate safeguards are in place to maintain the same level of data protection afforded by the Data Privacy Act of 2012.

Safeguards for cross-border transfers implemented by pub709 include:

• Binding contractual clauses incorporating the data protection requirements of the Data Privacy Act of 2012 into all data processing agreements with overseas third parties;
• Transfers only to jurisdictions determined by the NPC to provide an adequate level of data protection, or to recipients who have agreed to NPC-approved contractual safeguards;
• Regular review of overseas processing arrangements to confirm continued compliance with applicable standards.

You may request further information about specific cross-border transfer safeguards applicable to your personal data by contacting the pub709 DPO.

pub709 is subject to the Anti-Money Laundering Act of 2001 (Republic Act No. 9160) and its subsequent amendments, including the amendments introduced by RA 10365 and RA 11521. As a covered person under Philippine AML law, pub709 is legally required to:

• Conduct customer due diligence (CDD) on all registered players, including identity verification and source of funds assessment for high-value transactions;
• Monitor transactions for suspicious patterns and file Suspicious Transaction Reports (STRs) and Covered Transaction Reports (CTRs) with the Anti-Money Laundering Council (AMLC) where applicable thresholds are met;
• Maintain records of all reportable transactions and associated customer data for the minimum periods specified by AMLC;
• Respond to AMLC inquiries and freeze orders without advance notice to the affected player where required by AMLC directive.

These AML reporting obligations are mandatory and override pub709's general confidentiality obligations to players. pub709 is legally prohibited from "tipping off" a player that their transactions have been the subject of an STR or that an AML investigation is underway. Compliance with these obligations does not constitute a breach of this Privacy Policy.

pub709 reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable Philippine law, or changes in the pub709 Platform's features and services. The effective date at the top of this policy will be updated whenever a material change is made.

Where amendments are material — meaning they affect your rights as a data subject or significantly change how pub709 uses your personal data — pub709 will notify you via the email address associated with your pub709 account and via an in-platform notification visible on your next pub709 Login. For non-material amendments (such as clarifications of existing language or corrections of typographical errors), the policy will be updated without individual notification.

Your continued use of the pub709 Platform following the effective date of any amended Privacy Policy constitutes your acknowledgement of the amendments. If you disagree with any amendment, you may request account closure by contacting pub709 support at [email protected] (plain text — not a clickable link).

For all privacy-related queries, data subject access requests, complaints, or concerns regarding this Privacy Policy or pub709's data processing practices, please contact the pub709 Data Protection Officer through the following channels:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24 hours a day, 7 days a week via the live chat widget on the pub709 Platform

pub709 aims to acknowledge all privacy-related enquiries within two (2) business days and to provide a substantive response within fifteen (15) business days. Complex data subject requests — such as full data access requests requiring extensive data retrieval — may take up to thirty (30) business days, in which case pub709 will notify you of the extended timeline promptly.

If you are not satisfied with pub709's response to your privacy concern, you have the right to escalate your complaint directly to the National Privacy Commission of the Philippines at [email protected] (plain text — not a clickable link) or via the NPC's official website.

For matters relating to responsible gaming, self-exclusion, or account restrictions, please visit the pub709 Responsible Gaming page for dedicated guidance and self-service tools.