Privacy Policy – 773pub

1. Introduction

773pub ("773pub", "we", "us", "our") is committed to protecting the privacy and personal data of all registered players and visitors to the 773pub website at https://773pub.club ("Platform"). This Privacy Policy describes in detail how 773pub collects, uses, stores, discloses, and protects personal information in connection with your use of the Platform and all related services.

This Privacy Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). By registering an account on 773pub or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy should be read together with the 773pub Terms & Conditions, which govern your use of the Platform generally.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, the data controller responsible for your personal data is:

• Platform Name: 773pub
• Website: https://773pub.club
• Contact: [email protected] (plain text — not a clickable link)
• Data Protection Officer: Reachable through the support email address above. Please use the subject line "Data Privacy Inquiry".

All personal data processing activities conducted by 773pub are carried out in accordance with applicable Philippine data protection law. Where 773pub engages third-party processors to handle personal data on its behalf, appropriate data processing agreements are in place to ensure equivalent standards of protection.

3. Information We Collect

773pub collects the following categories of personal data in connection with your use of the Platform:

773pub does not intentionally collect sensitive personal information as defined under Section 3(l) of RA 10173 (such as health data, religious beliefs, or political affiliation) except where strictly necessary for responsible gaming compliance or legal obligations.

4. How We Collect Your Data

773pub collects personal data through the following means:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting customer support, or participating in promotions.
• Automated Collection: Technical data collected automatically when you access the Platform, including server logs, cookie data, and session analytics.
• Payment Processors: Transaction confirmation data received from GCash, PayMaya, and partner banks when you make deposits or receive withdrawals.
• Third-Party Verification Services: Identity verification data obtained from authorised identity verification and anti-fraud service providers in connection with KYC compliance.
• Public Sources: Information available from public registries or databases consulted for anti-money laundering (AML) and know-your-customer (KYC) compliance purposes.

5. Purposes of Processing

773pub processes your personal data for the following purposes:

• Account Management: Creating, verifying, maintaining, and securing your 773pub player account.
• Payment Processing: Processing deposits and withdrawal requests via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels.
• Identity Verification (KYC): Verifying your identity and age in compliance with PAGCOR regulations and Philippine AML laws, including Republic Act No. 9160 (Anti-Money Laundering Act) as amended.
• Gaming Operations: Recording, tracking, and auditing game activity, bet placements, and outcomes for platform integrity, dispute resolution, and regulatory reporting.
• Responsible Gaming: Monitoring account activity for indicators of problem gambling and administering player-requested tools such as deposit limits and self-exclusion.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent transactions, unauthorised account access, money laundering, and platform abuse.
• Customer Support: Responding to enquiries, resolving complaints, and providing technical assistance.
• Legal and Regulatory Compliance: Fulfilling obligations under PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine law.
• Marketing: Sending promotional communications where you have opted in, and displaying relevant content based on your gaming activity (see Section 14 on Marketing).
• Platform Improvement: Analysing aggregated, anonymised usage data to improve platform performance, user experience, and game offerings.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, 773pub processes your personal data on the following legal grounds:

• Contractual Necessity: Processing required to perform the Terms & Conditions agreement between you and 773pub — including account creation, payment processing, and gaming services.
• Legal Obligation: Processing required to comply with Philippine law, including KYC/AML obligations, PAGCOR reporting requirements, and NPC compliance.
• Legitimate Interest: Processing for fraud prevention, platform security, responsible gaming monitoring, and analytics — where such interests are not overridden by your rights.
• Consent: Processing for marketing communications and optional platform features, where you have provided explicit, informed consent that may be withdrawn at any time.

7. Data Sharing and Disclosure

773pub does not sell, rent, or trade your personal data to third parties for 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 (Mynt), PayMaya (Voyager), BPI, BDO, Metrobank, and other payment service providers — to process deposits and withdrawals.
• Identity Verification Providers: Authorised KYC and AML compliance service providers engaged to verify player identities.
• Game Software Providers: Third-party game studios and live dealer providers whose software is integrated into the 773pub Platform — limited to data necessary for game operation and audit.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government bodies — when required by law or valid legal process.
• IT and Cloud Service Providers: Hosting, security, and infrastructure service providers who process data on 773pub's behalf under data processing agreements.
• Legal and Professional Advisers: Lawyers, auditors, and other professional advisers under strict confidentiality obligations, where necessary for legal proceedings or compliance.

All third-party processors engaged by 773pub are contractually required to maintain appropriate technical and organisational measures to protect your personal data and to process it only on 773pub's documented instructions.

8. Cookies and Tracking Technologies

773pub uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you access the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function, including session authentication, security tokens, and load balancing. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, last-visited game category, and display options.
• Analytics Cookies: Collect anonymised information about how the Platform is used — pages visited, session duration, device type — to help us improve the user experience.
• Security Cookies: Support fraud detection, suspicious login identification, and account protection measures.

You may configure your browser to reject cookies; however, doing so may impair the functionality of certain Platform features, including login persistence and game loading. 773pub does not use third-party advertising or behavioural tracking cookies.

9. Data Retention

773pub retains personal data for as long as is necessary to fulfil the purposes described in this Policy, or as required by applicable Philippine law, whichever is longer:

• Active Accounts: Personal data is retained throughout the period your account remains active.
• Closed Accounts: Following account closure, identity and financial records are retained for a minimum of five (5) years as required by Philippine AML regulations (RA 9160 as amended).
• Transaction Records: Deposit, withdrawal, and betting transaction logs are retained for a minimum of five (5) years for regulatory compliance and dispute resolution.
• Support Communications: Customer support records are retained for three (3) years from the date of the last interaction.
• Marketing Data: Where consent has been withdrawn, marketing preferences and associated data are updated within 30 days and retained only as necessary to document the opt-out.

When retention periods expire, personal data is securely deleted or anonymised so that it can no longer be attributed to any individual.

10. Data Security

773pub implements technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 773pub servers.
• Encryption of sensitive data fields at rest, including financial account information and government ID numbers.
• Access controls and role-based permissions that limit staff access to personal data on a strict need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing.
• Two-factor authentication (2FA) for player accounts and internal staff systems.
• Incident response procedures, including breach notification protocols in compliance with NPC reporting requirements.

No method of data transmission or storage is completely secure. While 773pub takes all reasonable steps to protect your data, we cannot guarantee absolute security. In the event of a data breach affecting your personal data, 773pub will notify you and the NPC in accordance with the requirements of RA 10173 and NPC Circular 16-03.

11. Your Rights Under the Data Privacy Act

As a data subject under RA 10173, you have the following rights with respect to your personal data held by 773pub:

• Right to Be Informed: The right to be told how your personal data is being collected and used — fulfilled through this Privacy Policy.
• Right to Access: The right to request a copy of the personal data 773pub holds about you, including information on how it has been processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your 773pub account settings.
• Right to Erasure (Right to be Forgotten): The right to request deletion of your personal data, subject to legal retention obligations. Erasure requests will be considered on a case-by-case basis in light of applicable retention requirements under RA 9160 and PAGCOR regulations.
• Right to Object: The right to object to processing based on legitimate interest, including direct marketing communications. You may opt out of marketing emails at any time.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format, where technically feasible.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of your data subject rights, contact the 773pub Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request". We will respond within 15 business days of receiving a valid request.

12. International Data Transfers

Where personal data is transferred to service providers or technology partners located outside the Philippines, 773pub ensures that such transfers are conducted in compliance with Section 21 of RA 10173, which requires that the recipient country provides an adequate level of data protection or that appropriate contractual safeguards (such as standard contractual clauses) are in place. 773pub does not transfer personal data to jurisdictions that lack adequate data protection frameworks without implementing such safeguards.

13. Children's Privacy and Age Restriction

The 773pub Platform is strictly intended for individuals aged 21 years and above. 773pub does not knowingly collect personal data from individuals under the age of 21. Where 773pub discovers that personal data has been collected from an individual under 21, the associated account will be suspended immediately, all data will be deleted, and any deposits will be returned.

If you believe that a person under the age of 21 has registered an account on 773pub, please contact [email protected] immediately so that we can take appropriate action.

14. Marketing Communications

With your consent, 773pub may send you promotional emails, SMS notifications, and in-platform messages about bonuses, new games, special promotions, and platform updates. Marketing communications are sent only to players who have opted in during registration or through their account settings.

You may withdraw your consent to marketing communications at any time by:

• Clicking the unsubscribe link in any marketing email.
• Updating your communication preferences in your account settings.
• Contacting 773pub support and requesting removal from marketing lists.

Withdrawal of marketing consent does not affect the lawfulness of processing that occurred prior to withdrawal, and does not affect transactional communications such as deposit confirmations, withdrawal notifications, or security alerts — which are sent regardless of marketing preference as they are necessary for account operation.

15. Changes to This Privacy Policy

773pub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. The effective date at the top of this Policy will be updated accordingly. Where changes are material, 773pub will notify registered players via email to the address on file or through a notice displayed on the Platform. Continued use of the Platform following publication of an updated Privacy Policy constitutes acceptance of the revised terms.

16. Contact and Data Protection Officer

For any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 773pub, please contact:

• Data Protection Officer, 773pub
• Email: [email protected] — Subject Line: "Data Privacy Inquiry"
• Live Chat: Available 24/7 through the chat widget on all pages of the 773pub website.

If you are not satisfied with our response to a data privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines:

• National Privacy Commission (NPC) — 3/F, Core G, GSIS Headquarters, Financial Center, Roxas Boulevard, Pasay City, Metro Manila, Philippines