Privacy Policy – 778 pub

1. About This Privacy Policy

778 pub operates the online gaming platform accessible at 778pub.asia (the "Platform"). 778 pub is the personal information controller responsible for your data processed through the Platform. This Privacy Policy applies to all players, visitors, and any individual whose personal data is processed in connection with 778 pub's services.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). As a PAGCOR-authorized operator, 778 pub is also subject to PAGCOR's data governance requirements, which are reflected in this Policy.

By registering an Account or continuing to use the 778 pub Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree to the terms of this Policy, you should not use the Platform.

2. Personal Data We Collect

2.1 Registration and Identity Data

When you create a 778 pub Account, we collect: full legal name, date of birth, gender, nationality, email address, Philippine mobile number, and the password you set (stored in salted hash form — never in plain text).

2.2 KYC Verification Data

To comply with PAGCOR requirements and the Anti-Money Laundering Act (AMLA), we collect government-issued Philippine ID documents (e.g., PhilSys, passport, UMID, driver's license), selfie photographs for facial verification, and where required for higher account tiers: proof of address and source of funds documentation.

2.3 Financial Data

We collect records of deposits, withdrawals, and transaction history. We receive payment confirmation data from GCash, Maya, and bank InstaPay networks. We do not store full GCash or bank account credentials — payment processing is handled by the relevant regulated payment service providers.

2.4 Gaming Activity Data

We record game session data including games played, wagers placed, game outcomes, session durations, and bonus usage. This data is required for PAGCOR compliance, dispute resolution, and responsible gaming monitoring.

2.5 Technical and Device Data

We automatically collect IP address, browser type and version, operating system, device identifiers, and session timestamps when you access the Platform. This data is used for security, fraud prevention, and platform optimization.

2.6 Communications Data

If you contact 778 pub support through live chat or email, we retain records of those communications including chat transcripts and email correspondence.

3. How We Collect Your Data

• Directly from you — through the registration form, KYC submission process, deposit and withdrawal requests, and support communications.
• Automatically — through server logs, cookies, and session tracking technologies when you browse or use the Platform.
• From payment providers — GCash, Maya, and bank partners share transaction confirmation data necessary to credit your Wallet and process withdrawals.
• From identity verification services — third-party KYC providers may verify your submitted ID documents against authoritative Philippine government databases.
• From PAGCOR and other regulators — we may receive information about players from PAGCOR in the course of regulatory compliance, including exclusion lists.

4. Legal Basis for Processing

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

• Contractual necessity — processing your registration data, KYC information, and transaction data is necessary to provide the 778 pub gaming services you have contracted for.
• Legal obligation — PAGCOR authorization conditions, the Anti-Money Laundering Act, the Data Privacy Act itself, and other applicable Philippine law require 778 pub to collect and retain certain personal data.
• Legitimate interests — fraud prevention, platform security, and responsible gaming monitoring are legitimate interests that require processing of technical and gaming activity data.
• Consent — where we process data for marketing communications, we rely on your explicit consent. You may withdraw consent for marketing at any time through your Account settings.

5. How We Use Your Personal Data

778 pub uses your personal data for the following purposes:

• Creating and maintaining your Account and verifying your identity and age eligibility (21+ requirement).
• Processing deposits, withdrawals, and Wallet transactions in PHP.
• Providing access to Games, live dealer tables, bingo rooms, and all Platform features.
• Detecting and preventing fraud, money laundering, and unauthorized Account access.
• Complying with PAGCOR reporting obligations, AMLC covered transaction reporting, and NPC requirements.
• Monitoring gaming patterns for responsible gaming purposes, including identifying potential problem gambling behavior.
• Resolving disputes, responding to support queries, and maintaining records required for regulatory purposes.
• Sending transactional notifications (deposit confirmations, withdrawal updates, security alerts) via SMS and email.
• Sending promotional communications about 778 pub bonuses and offers — only where you have provided explicit consent.
• Improving the Platform through analytics of aggregated, anonymized usage data.

6. Data Sharing and Disclosure

778 pub does not sell your personal data to third parties. We share data only in the following circumstances and only to the extent necessary:

6.1 Regulatory Authorities

We disclose personal and transaction data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine competent authorities as required by law or regulatory instruction.

6.2 Payment Service Providers

Transaction data is shared with GCash, Maya, and participating banks (BPI, BDO, Metrobank) solely to process your deposits and withdrawals. These providers are independently regulated and operate under their own privacy frameworks.

6.3 KYC and Identity Verification Partners

Identity document data submitted during KYC is processed by contracted third-party verification service providers under data processing agreements that require compliance with the DPA and equivalent data protection standards.

6.4 Live Game Studio Operators

Where you participate in live dealer games provided by third-party studio operators, your Player ID and session data are shared with that operator to facilitate the game session. Game studios are contractually required to process this data solely for game provision purposes.

6.5 Legal and Safety Disclosures

We may disclose personal data to law enforcement, courts, or other authorities where required by valid legal process, court order, or where necessary to protect the rights, safety, or property of 778 pub, its staff, or other players.

7. Data Retention

778 pub retains personal data for the following periods, in line with DPA requirements and PAGCOR obligations:

• Account and KYC data: Retained for a minimum of five (5) years after Account closure, as required by AMLC and PAGCOR record-keeping obligations.
• Transaction records: Retained for five (5) years from the date of each transaction.
• Gaming session data: Retained for three (3) years for dispute resolution and responsible gaming compliance purposes.
• Support communications: Retained for two (2) years from the date of the last communication in a support thread.
• Marketing consent records: Retained for the duration of your consent and one (1) year thereafter for compliance evidence purposes.

After applicable retention periods, data is securely deleted or anonymized in accordance with NPC guidelines.

8. Data Security

778 pub implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• 256-bit TLS encryption for all data transmitted between your device and the 778 pub Platform.
• Passwords stored exclusively as salted cryptographic hashes — never in recoverable plain-text form.
• Multi-factor authentication options for Account access, including OTP verification for new devices.
• Access controls restricting personal data access to 778 pub staff and contractors with a demonstrated need to process it.
• Regular security assessments and penetration testing of Platform infrastructure.
• Incident response procedures compliant with the NPC's 72-hour personal data breach notification requirement.

Despite these measures, no data transmission over the internet is entirely without risk. You are responsible for securing your own device and Account credentials.

9. Cookies and Tracking Technologies

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

• Essential cookies: Required for Platform functionality including session management, login state, and Wallet balance display. These cannot be disabled without impairing Platform use.
• Security cookies: Used to detect and prevent fraudulent logins and suspicious session activity.
• Analytics cookies: Aggregate, anonymized data on page performance and navigation patterns used to improve the Platform.
• Preference cookies: Storing your language, display, and notification preferences between sessions.

You may manage non-essential cookies through your browser settings. Disabling essential cookies may affect your ability to use core Platform features including the 778 pub Login.

10. Your Data Subject Rights

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

778 pub will respond to all data subject rights requests within thirty (30) calendar days, or notify you within that period if additional time is required. Requests may be subject to identity verification before processing.

11. Children's Privacy and Age Restriction

The 778 pub Platform is strictly restricted to persons aged twenty-one (21) years and above as mandated by PAGCOR. We do not knowingly collect personal data from individuals under 21. If we become aware that an Account has been registered by or for a person under 21, we will close that Account immediately and delete associated personal data to the extent consistent with our legal retention obligations.

If you have reason to believe that a person under the age of 21 has registered an Account or provided personal data through the Platform, please notify us immediately at [email protected].

12. Changes to This Privacy Policy

778 pub may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or PAGCOR requirements. Material changes will be communicated to registered players by email to the address on record at least fourteen (14) days before the effective date, except where earlier implementation is required by regulatory instruction.

The current version of this Privacy Policy is always accessible at 778pub.asia/privacy-policy. The effective date at the top of this document indicates when this version was last updated. Continued use of the Platform after an updated Policy's effective date constitutes acceptance of the revised terms.

13. Contact and Data Protection Officer

778 pub has appointed a Data Protection Officer (DPO) in compliance with Section 21 of the Data Privacy Act of 2012. For all data privacy queries, rights requests, complaints, or concerns regarding 778 pub's processing of your personal data, contact the DPO at: