Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") applies to all personal information collected by 772pub through our website (https://772pub.cam), mobile application, customer service channels, and any related services (collectively, the "Platform"). By accessing or using the Platform, registering an account, or engaging with our services, you acknowledge that you have read, understood, and consent to the data practices described in this Policy.

772pub operates under license from the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to Philippine data protection laws, gaming regulations, and international standards for responsible data handling. We act as the data controller for all personal information collected through the Platform.

This Policy should be read in conjunction with our Terms and Conditions, Responsible Gaming Policy, and Cookie Policy. If you have questions about how we handle your personal data or wish to exercise your data protection rights, please contact our Data Protection Officer using the contact information provided at the end of this Policy.

2. Information We Collect

772pub collects various categories of personal information necessary to provide gaming services, ensure platform security, comply with legal obligations, and improve user experience. The information we collect includes:

2.1 Information You Provide Directly

When you register for a 772pub account or interact with our services, we collect information that you voluntarily provide, including:

• Registration Information: Full legal name, date of birth, gender, residential address, email address, mobile phone number, username, and password.
• Identity Verification Documents: Government-issued identification (Philippine passport, driver's license, UMID, postal ID, voter's ID), proof of address (utility bills, bank statements), and facial photographs for biometric verification.
• Financial Information: Payment method details (GCash account, PayMaya account, bank account numbers), transaction history, deposit and withdrawal records, and proof of payment method ownership.
• Communication Records: Messages sent through customer support channels (live chat, email, phone), feedback forms, survey responses, and correspondence with 772pub staff.
• Responsible Gaming Information: Self-imposed limits (deposit limits, loss limits, session time limits), self-exclusion preferences, and responsible gaming tool settings.

2.2 Information Collected Automatically

When you access the 772pub Platform, we automatically collect certain technical and usage information through cookies, log files, and similar technologies:

• Device Information: Device type, operating system, browser type and version, device identifiers (IMEI, MAC address), screen resolution, and mobile network information.
• Connection Information: IP address, internet service provider, geographic location (country, city, region), time zone, and connection type.
• Usage Data: Pages visited, games played, session duration, click-through data, referring URLs, search queries, bets placed, winnings and losses, bonus usage, and feature interactions.
• Performance Data: Load times, error messages, system performance metrics, and platform stability information.

2.3 Information from Third Parties

We may receive information about you from third-party sources, including:

• Payment Processors: Transaction verification, fraud detection data, and payment method validation from GCash, PayMaya, banks, and other payment service providers.
• Identity Verification Services: Age verification, identity authentication, and fraud prevention data from third-party verification providers.
• Regulatory Authorities: Information received from PAGCOR, anti-money laundering agencies, or other regulatory bodies as required by law.
• Publicly Available Sources: Information from public records, social media profiles, or other publicly accessible sources when necessary for verification or fraud prevention purposes.

3. How We Use Your Information

772pub processes your personal information for specific, legitimate purposes that are necessary for operating our gaming platform, complying with legal obligations, and providing you with a secure and enjoyable gaming experience. The purposes for which we use your information include:

3.1 Service Provision and Account Management

• Creating and maintaining your 772pub account
• Processing registrations and verifying your identity
• Enabling access to games, features, and platform functionality
• Managing your account settings, preferences, and profile information
• Processing deposits, withdrawals, and other financial transactions
• Tracking gaming activity, bet history, and account balance
• Administering bonuses, promotions, and loyalty rewards
• Providing customer support and responding to inquiries

3.2 Legal and Regulatory Compliance

• Verifying that you meet minimum age requirements (21 years or older)
• Complying with PAGCOR licensing conditions and reporting obligations
• Conducting Know Your Customer (KYC) and Customer Due Diligence (CDD) checks
• Detecting, preventing, and investigating money laundering and terrorist financing
• Meeting anti-fraud, anti-corruption, and sanctions screening requirements
• Responding to legal requests, court orders, and regulatory inquiries
• Maintaining records required by Philippine gaming and financial regulations
• Reporting suspicious transactions to authorities as legally required

3.3 Security and Fraud Prevention

• Protecting the Platform from unauthorized access, hacking, and cyberattacks
• Detecting and preventing fraudulent transactions, bonus abuse, and account manipulation
• Identifying multiple accounts, collusion, or other prohibited activities
• Monitoring for patterns of problem gambling behavior
• Enforcing Terms and Conditions and investigating violations
• Protecting 772pub's intellectual property and business interests
• Maintaining Platform integrity and fairness for all users

3.4 Service Improvement and Personalization

• Analyzing usage patterns to improve Platform functionality and user experience
• Developing new features, games, and services based on user preferences
• Personalizing content, game recommendations, and promotional offers
• Conducting market research and user satisfaction surveys
• Optimizing website performance, load times, and mobile responsiveness
• Testing new features and performing A/B testing for platform enhancements

3.5 Marketing and Communications

• Sending account-related notifications (transaction confirmations, password resets)
• Providing promotional offers, bonuses, and exclusive deals (with your consent)
• Distributing newsletters, updates, and gaming-related content
• Notifying you of new games, features, or platform changes
• Conducting promotional campaigns and competitions

You may opt out of marketing communications at any time by adjusting your account preferences or clicking unsubscribe links in promotional emails. Please note that you cannot opt out of essential service-related communications.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act and international data protection standards, 772pub processes your personal information based on the following legal grounds:

• Consent: You have provided explicit, informed consent for specific processing activities, such as receiving marketing communications or using optional features.
• Contractual Necessity: Processing is necessary to fulfill our contractual obligations under the Terms and Conditions, including providing gaming services, processing transactions, and managing your account.
• Legal Obligation: Processing is required to comply with Philippine laws, PAGCOR regulations, anti-money laundering requirements, tax obligations, or other legal mandates.
• Legitimate Interests: Processing is necessary for 772pub's legitimate business interests, such as fraud prevention, platform security, service improvement, and protection of user rights, provided these interests do not override your fundamental rights and freedoms.

5. How We Share Your Information

772pub does not sell, rent, or trade your personal information to third parties for marketing purposes. However, we may share your information with carefully selected third parties in the following circumstances:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers to perform functions on our behalf, including:

• Payment Processors: GCash, PayMaya, banks, and payment gateways to process deposits, withdrawals, and financial transactions.
• Identity Verification Services: Third-party providers that verify age, identity, and address information to meet KYC requirements.
• Game Providers: Software developers and gaming studios that supply games, live dealer services, and related content to the Platform.
• Cloud Hosting Providers: Secure data centers and cloud infrastructure providers that host Platform data and ensure availability.
• Customer Support Tools: Live chat platforms, email services, and ticketing systems used to provide customer assistance.
• Analytics and Marketing Tools: Providers that help us analyze user behavior, measure campaign performance, and improve marketing effectiveness.
• Security and Fraud Prevention Services: Cybersecurity firms, fraud detection systems, and anti-money laundering screening providers.

All service providers are contractually obligated to protect your data, use it only for specified purposes, and maintain confidentiality in accordance with data protection laws.

5.2 Regulatory and Legal Authorities

We may disclose your information to regulatory bodies, law enforcement agencies, courts, or government authorities when:

• Required by law, court order, subpoena, or legal process
• Necessary to comply with PAGCOR licensing conditions and reporting obligations
• Mandated by anti-money laundering or counter-terrorism financing regulations
• Responding to requests from the National Privacy Commission or data protection authorities
• Protecting 772pub's legal rights or defending against legal claims
• Investigating suspected fraud, illegal activity, or Terms violations

5.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring entity or successor organization. We will notify you of any such transfer and provide information about how the new entity will handle your data.

5.4 Affiliated Companies

We may share information with affiliated companies within our corporate group for internal administration, consolidated reporting, and shared services, provided that all affiliates adhere to this Privacy Policy and applicable data protection laws.

6. Data Retention

772pub retains your personal information only for as long as necessary to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce agreements. Specific retention periods include:

Data Category	Retention Period
Account registration data	Duration of account + 5 years after closure
Transaction records	7 years from transaction date (AML compliance)
Identity verification documents	5 years after last verification or account closure
Game play history	5 years (PAGCOR requirement)
Communication records	3 years after last contact
Marketing consent records	Duration of consent + 2 years
Self-exclusion records	Permanent retention (regulatory requirement)

After retention periods expire, we securely delete or anonymize your personal information in accordance with data protection best practices. However, we may retain certain information longer if required by law, for legal defense purposes, or to protect against fraud.

7. Data Security

772pub implements industry-standard technical and organizational security measures to protect your personal information against unauthorized access, disclosure, alteration, or destruction. Our security measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS/SSL protocols. Sensitive data at rest is encrypted using AES-256 encryption.
• Access Controls: Strict access permissions ensure that only authorized personnel can access personal information on a need-to-know basis.
• Authentication: Multi-factor authentication (MFA) for administrative accounts and optional 2FA for player accounts.
• Network Security: Firewalls, intrusion detection systems, and DDoS protection to safeguard Platform infrastructure.
• Secure Data Centers: Personal information is stored in ISO 27001-certified data centers with physical security, redundancy, and disaster recovery capabilities.
• Regular Security Audits: Penetration testing, vulnerability assessments, and third-party security audits to identify and address potential risks.
• Employee Training: Regular data protection and security awareness training for all staff handling personal information.
• Incident Response: Established procedures for detecting, responding to, and reporting data breaches in accordance with legal requirements.

While we employ robust security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security, but we continuously monitor and improve our security practices to protect your data.

8. Your Privacy Rights

Under the Philippine Data Privacy Act, you have the following rights regarding your personal information:

• Right to Information: You have the right to be informed about how your data is collected, used, and shared.
• Right of Access: You may request a copy of the personal information we hold about you.
• Right to Rectification: You can request correction of inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal information, subject to legal retention obligations.
• Right to Object: You can object to processing of your data for direct marketing or other purposes based on legitimate interests.
• Right to Data Portability: You may request transfer of your data to another service provider in a structured, machine-readable format where technically feasible.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw consent at any time without affecting prior lawful processing.
• Right to Lodge a Complaint: You may file a complaint with the National Privacy Commission if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the contact information provided in Section 12. We will respond to your request within thirty (30) days as required by law. Certain requests may require identity verification to prevent unauthorized access to your information.

9. Cookies and Tracking Technologies

772pub uses cookies, web beacons, and similar tracking technologies to enhance user experience, analyze Platform performance, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize you and remember your preferences.

Types of cookies we use include:

• Essential Cookies: Required for Platform functionality, account access, and security features. These cannot be disabled.
• Performance Cookies: Collect anonymous usage data to improve Platform performance and identify technical issues.
• Functional Cookies: Remember your preferences, settings, and customization choices.
• Analytics Cookies: Help us understand how users interact with the Platform through tools like Google Analytics.
• Marketing Cookies: Track your activity to deliver relevant advertisements and measure campaign effectiveness.

You can manage cookie preferences through your browser settings. However, disabling certain cookies may limit Platform functionality. For detailed information, please refer to our Cookie Policy.

10. International Data Transfers

Your personal information may be transferred to and processed in countries outside the Philippines where our service providers, cloud hosting infrastructure, or business partners are located. These countries may have different data protection laws than the Philippines.

When we transfer data internationally, we ensure adequate protection through:

• Standard contractual clauses approved by data protection authorities
• Transfer to jurisdictions with adequate data protection frameworks
• Contractual obligations requiring recipients to maintain Philippine-equivalent data protection standards
• Additional security measures such as encryption and access controls

11. Children's Privacy

772pub strictly prohibits individuals under twenty-one (21) years of age from accessing gaming services. We do not knowingly collect personal information from minors. If we discover that we have inadvertently collected information from an individual under 21, we will immediately delete such information and close the associated account.

If you believe that a minor has accessed 772pub services, please contact us immediately at the address provided in Section 12.

12. Contact Information and Data Protection Officer

If you have questions, concerns, or complaints regarding this Privacy Policy or our data practices, or if you wish to exercise your privacy rights, please contact our Data Protection Officer:

• Data Protection Officer: 772pub Privacy Team
• Email: [email protected]
• Postal Address: [Insert Physical Address], Philippines
• Customer Support: Available 24/7 through live chat on the Platform

For complaints or concerns about how we handle your personal information, you may also contact the National Privacy Commission of the Philippines:

• Website: https://www.privacy.gov.ph
• Email: [email protected]
• Telephone: (02) 8234-2228

13. Changes to This Privacy Policy

772pub reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated through:

• Prominent notice on the Platform homepage
• Email notification to registered users
• In-app notifications
• Updated "Effective Date" at the top of this Policy

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of 772pub services after Policy changes constitutes acceptance of the revised Policy.