Privacy Policy — pub 504

01 Introduction

pub 504 ("we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses our platform. This Privacy Policy applies to all services offered through the pub 504 website and any associated mobile or web applications (collectively, the "Platform").

This Policy is drafted in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC). By registering an account or using any part of the pub 504 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

02 Personal Data We Collect

pub 504 collects only the personal data that is necessary to provide our services, comply with legal obligations, and maintain the security and integrity of the Platform. The categories of personal data we may collect include:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification number (e.g., Philippine National ID, passport, driver's license, SSS/GSIS number).
• Contact Data: Email address, mobile number, and residential address (including city, province, and postal code).
• Account Data: Username, encrypted password, account preferences, and communication settings.
• Financial Data: GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank), and transaction history including deposits, withdrawals, and wager records.
• Technical Data: IP address, device type, browser type and version, operating system, time zone, and session data.
• Usage Data: Pages visited, games played, bet amounts, session duration, and clickstream data within the Platform.
• KYC Documentation: Copies of government-issued IDs, selfies for identity verification, and proof of address documents submitted during the verification process.
• Communications Data: Records of your interactions with our customer support team, including live chat transcripts and email correspondence.

We do not collect sensitive personal information (as defined under RA 10173) unless it is strictly necessary for compliance purposes, and only with your explicit consent where required.

03 How We Collect Your Data

pub 504 collects personal data through the following means:

• Direct Submission: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated Technologies: Data collected automatically when you access the Platform, including cookies, web beacons, pixel tags, and server logs that record technical and usage data.
• Third-Party Sources: Data received from payment processors (e.g., GCash, PayMaya, BPI), identity verification service providers, fraud prevention agencies, and game software suppliers, where permitted by law.

04 How We Use Your Personal Data

pub 504 uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your pub 504 player account, including authentication and account security.
• Service Delivery: To process deposits and withdrawals, facilitate gameplay, and deliver the full range of pub 504 services to you.
• KYC & Compliance: To verify your identity and age (21+), comply with anti-money laundering (AML) obligations, and meet all applicable Philippine regulatory requirements.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the Platform.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Responsible Gaming: To monitor gaming behavior, enforce deposit limits and self-exclusion requests, and identify players who may need support.
• Marketing & Promotions: To send you relevant bonus offers, promotional updates, and platform news — but only where you have provided consent or where we have a legitimate interest to do so. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the pub 504 Platform.
• Legal Obligations: To comply with court orders, regulatory requests, and other legal obligations imposed on pub 504 under Philippine law.

05 Legal Basis for Processing

Under the Data Privacy Act of 2012, pub 504 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you agreed to upon registration — including account management, payment processing, and service delivery.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, PAGCOR licensing requirements, and NPC directives.
• Legitimate Interests: Processing is necessary for pub 504's legitimate business interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights.
• Consent: For marketing communications and certain non-essential data processing activities, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

06 Data Sharing & Disclosure

pub 504 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data only in the following circumstances:

• Service Providers: Trusted third-party vendors who assist us in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), KYC verification providers, cloud hosting services, and customer support tools. These parties are contractually bound to process your data only on our instructions and in accordance with applicable law.
• Game Software Suppliers: Licensed game providers whose software powers games on the pub 504 Platform may receive limited technical data necessary to deliver gameplay.
• Regulatory & Law Enforcement Authorities: We may disclose your data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent Philippine authorities when required by law or in response to a valid legal process.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of pub 504's business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

07 Cookies & Tracking Technologies

pub 504 uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The types of cookies we use include:

• Essential Cookies: Required for the Platform to function correctly, including session management, authentication, and security features. These cannot be disabled without affecting Platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform, helping us identify areas for improvement.
• Preference Cookies: Store your settings and preferences (such as language and display options) to personalize your experience.
• Marketing Cookies: Used to deliver relevant promotional content based on your activity on the Platform. These are only set with your consent.

You may manage or disable non-essential cookies through your browser settings at any time. Note that disabling certain cookies may affect the functionality of the pub 504 Platform.

08 Data Retention

pub 504 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account Data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine AML regulations.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory authority.
• Support Communications: Retained for up to three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Technical & Usage Data: Retained for up to twelve (12) months, after which it is anonymized or deleted.

When personal data is no longer required, pub 504 will securely delete or anonymize it in accordance with our internal data disposal procedures.

09 Data Security

pub 504 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your device and the pub 504 Platform is encrypted using industry-standard SSL/TLS protocols.
• Password Hashing: Account passwords are never stored in plain text. We use strong cryptographic hashing algorithms to protect your credentials.
• Access Controls: Access to personal data is restricted to authorized pub 504 personnel on a strict need-to-know basis. All staff with access to personal data are bound by confidentiality obligations.
• Intrusion Detection: Our systems are monitored continuously for suspicious activity, unauthorized access attempts, and potential security breaches.
• Regular Security Audits: pub 504 conducts periodic security assessments and penetration testing to identify and remediate vulnerabilities.

10 Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pub 504:

• Right to Be Informed: You have the right to know what personal data pub 504 collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of Access: You may request a copy of the personal data pub 504 holds about you, along with information about how it is processed.
• Right to Rectification: You may request the correction of any inaccurate or incomplete personal data in your pub 504 account.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: If you believe pub 504 has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within thirty (30) days, as required by law.

11 Children's Privacy

The pub 504 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gambling regulations. We do not knowingly collect personal data from anyone under the age of 21.

If pub 504 discovers or is notified that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and report the matter to the appropriate authorities where required.

Parents and guardians who believe their child may have registered on the pub 504 Platform are encouraged to contact us immediately at [email protected] so that we can take prompt action.

12 Changes to This Privacy Policy

pub 504 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, we will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this page will always reflect the most recent revision. We encourage you to review this Privacy Policy periodically to stay informed about how pub 504 protects your personal data. Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the changes.

13 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way pub 504 handles your personal data, please reach out to our Data Protection Officer. We are committed to addressing all privacy-related inquiries promptly and transparently.