pubph Privacy Policy

1. Introduction

1.1 pubph is committed to protecting the privacy and security of all personal information entrusted to us by Filipino players. This Privacy Policy sets out the types of personal data we collect, the purposes for which we use it, the circumstances in which we may share it, and the measures we take to keep it secure.

1.2 This Privacy Policy should be read alongside the pubph Terms & Conditions, which govern your use of the Platform. In the event of any inconsistency between this Privacy Policy and the Terms & Conditions, the Terms & Conditions shall prevail on matters of account conduct and the Privacy Policy shall prevail on matters of data protection.

1.3 pubph operates as a PAGCOR-regulated online gaming platform and is subject to applicable Philippine laws relating to data protection, anti-money laundering, and responsible gaming. We collect and process personal data only to the extent necessary to meet these obligations and to provide you with a secure, fair, and functional gaming experience.

2. Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, the data controller for personal information collected through the pubph Platform is pubph, operating under PAGCOR licensing in the Republic of the Philippines.

2.2 pubph is responsible for determining the purposes and means of processing your personal data. Any questions, concerns, or requests relating to the processing of your personal data should be directed to our Data Protection Officer using the contact details provided in Section 13 of this policy.

3. Personal Data We Collect

3.1 pubph collects several categories of personal information depending on how you interact with the Platform. The data we collect includes:

3.1.1 Account Registration Data

When you register an account on pubph, we collect the following information:

• Full legal name as it appears on your government-issued identification;
• Date of birth (to verify that you are at least 21 years old);
• Philippine mobile number (for account verification and two-factor authentication);
• Email address (for account communications and password recovery);
• Residential address;
• Username and password (the password is stored in hashed form and is never visible to pubph staff);
• IP address and device information at the time of registration.

3.1.2 KYC Verification Data

As required by PAGCOR regulations and anti-money laundering laws, pubph collects identity verification documents including:

• Clear photograph or scan of a valid Philippine government-issued photo ID (UMID, PhilSys National ID, Driver's License, SSS ID, Passport, or other acceptable ID);
• Proof of residential address (utility bill, bank statement, or government correspondence issued within the preceding three months);
• Proof of payment method ownership (screenshot or photo of e-wallet account, bank statement, or card front showing only the last four digits);
• Selfie photograph holding identification for enhanced verification where required.

3.1.3 Financial Transaction Data

pubph records all financial transactions on your account, including:

• Deposit amounts, dates, times, and payment methods used;
• Withdrawal requests, amounts, dates, and destination payment methods;
• Transaction identifiers and reference numbers provided by third-party payment processors;
• Account balance and transaction history.

pubph does not store complete credit or debit card numbers, CVV codes, or full bank account details. Payment processing is handled by certified third-party processors that comply with PCI-DSS standards.

3.1.4 Gameplay and Betting Data

pubph automatically records gameplay activity for regulatory compliance, security monitoring, and service improvement purposes, including:

• Games played, bet amounts, win amounts, timestamps, and session duration;
• Bonus claims, wagering progress, and bonus outcome (completed, forfeited, or expired);
• Responsible gaming settings including deposit limits, loss limits, session time alerts, and self-exclusion periods;
• Customer support interactions, chat logs, and complaint records.

3.1.5 Technical and Device Data

When you access the pubph Platform, we automatically collect technical data including:

• IP address and approximate geographic location;
• Device type, operating system, browser type and version;
• Screen resolution, language settings, and time zone;
• Referral source (how you arrived at the pubph website);
• Pages visited, features used, session duration, and interaction patterns;
• Cookie identifiers and local storage data.

4. How We Use Your Personal Data

4.1 pubph uses the personal data we collect for the following purposes:

Purpose	Data Used	Legal Basis
Account creation and management	Registration data, device data	Contract performance
Identity verification (KYC)	KYC documents, registration data	Legal obligation (PAGCOR)
Processing deposits and withdrawals	Financial transaction data	Contract performance
Providing games and betting services	Gameplay data, account data	Contract performance
Anti-money laundering monitoring	Financial data, KYC data	Legal obligation
Responsible gaming monitoring	Gameplay data, account data	Legal obligation (PAGCOR)
Fraud prevention and security	Technical data, financial data	Legitimate interests
Customer support	All data categories as needed	Contract performance
Platform analytics and improvement	Technical data, gameplay data	Legitimate interests
Promotional communications	Contact data, gameplay data	Consent
Regulatory reporting to PAGCOR	Financial data, gameplay data	Legal obligation

4.2 pubph will not use your personal data for purposes that are incompatible with those listed above without providing prior notice and, where required, obtaining your consent.

4.3 Where pubph sends you promotional communications about bonuses, new games, or platform features, you may opt out at any time by updating your communication preferences in your account dashboard or by contacting our support team. Opting out of marketing communications does not affect transactional communications necessary for the operation of your account.

5. Legal Basis for Processing

5.1 pubph processes your personal data on the following legal grounds under the Data Privacy Act of 2012 (Republic Act No. 10173):

• Contract performance: Processing necessary to register your account, provide gaming services, process payments, and fulfill obligations under the pubph Terms & Conditions;
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, anti-money laundering regulations under Republic Act No. 9160 as amended, and other applicable Philippine laws;
• Legitimate interests: Processing for fraud detection, security monitoring, platform analytics, and abuse prevention, where those interests are not overridden by your data protection rights;
• Consent: Processing for direct marketing and optional features, where you have given clear and freely given consent that you may withdraw at any time.

5.2 Where pubph relies on legitimate interests as the legal basis for processing, we have assessed that our interests in operating a secure, fraud-free, and well-functioning gaming platform do not unduly override the privacy rights and interests of Filipino players, given the safeguards and transparency measures described in this policy.

6. Data Security Measures

6.1 pubph implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• Encryption in transit: All data transmitted between your device and the pubph Platform is encrypted using TLS 1.2 or higher with 256-bit SSL certificates;
• Encryption at rest: Personal data stored in pubph's databases is encrypted at rest using AES-256 encryption;
• Access controls: Access to personal data is restricted on a strict need-to-know basis. Staff with access to player data undergo background screening and mandatory data protection training;
• Segregated storage: KYC identity documents and financial data are stored in segregated, access-controlled systems separate from general account data;
• Intrusion detection: pubph operates continuous network monitoring and intrusion detection systems to identify and respond to security threats in real time;
• Regular security audits: Third-party security assessments and penetration tests are conducted regularly to identify and remediate vulnerabilities;
• Two-factor authentication: pubph provides optional two-factor authentication (2FA) for player accounts and requires 2FA for all staff access to internal systems containing personal data.

6.2 In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected players, pubph will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, as required under the Data Privacy Act. Affected players will be notified without undue delay where the breach is likely to result in a high risk to their rights and interests.

7. Data Sharing and Third-Party Disclosure

7.1 pubph does not sell, rent, or trade your personal information to third parties for their own marketing purposes under any circumstances.

7.2 pubph may share your personal data with the following categories of recipients, strictly for the purposes outlined:

• Payment processors: GCash (Globe Fintech Innovations), Maya Philippines, and other licensed Philippine financial institutions are provided with transactional data necessary to process your deposits and withdrawals. These processors operate under their own privacy policies and applicable Bangko Sentral ng Pilipinas (BSP) regulations;
• KYC and identity verification services: Certified third-party identity verification providers may process your KYC documents on pubph's behalf under data processing agreements that bind them to the same data protection standards as pubph;
• Game providers: Third-party game studios and live dealer providers receive session tokens and anonymised game data necessary to operate the games you play. Game providers do not receive your full identity or financial details;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities may receive data as required by law or in response to a lawful request;
• Law enforcement: Personal data may be disclosed to law enforcement agencies where required by a lawful court order or where disclosure is necessary to prevent or detect a crime;
• Fraud prevention and security services: Anonymised or pseudonymised technical data may be shared with fraud detection service providers operating under contractual data protection obligations.

7.3 All third-party service providers that process personal data on pubph's behalf are bound by data processing agreements that require them to process that data only for the specified purpose, in accordance with pubph's instructions, and in compliance with applicable Philippine data protection law.

7.4 pubph does not transfer personal data to countries outside the Philippines except where necessary to provide gaming services through internationally certified game providers, and only where adequate protections consistent with the Data Privacy Act are in place.

8. Cookies and Tracking Technologies

8.1 pubph uses cookies and similar tracking technologies to operate the Platform, improve your experience, and analyse usage patterns. The types of cookies pubph uses are:

• Essential cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in, CSRF protection tokens, and preference cookies that remember your settings. These cookies cannot be disabled without impairing Platform functionality;
• Analytics cookies: Used to collect anonymised information about how players navigate the Platform, which features are used most, and where errors occur. This data is used to improve the Platform's design and performance;
• Security cookies: Used to detect fraudulent activity, identify unusual account access patterns, and support our anti-bot and intrusion detection systems;
• Preference cookies: Used to remember your language preference, display settings, and other personalisation choices.

8.2 Most web browsers allow you to control cookie settings through the browser preferences menu. You may choose to block non-essential cookies; however, disabling essential cookies will prevent you from logging into your pubph account or using core Platform features.

8.3 pubph does not use third-party advertising cookies or allow external advertising networks to place tracking cookies on the pubph Platform. We do not engage in behavioural advertising profiling.

9. Your Data Protection Rights

9.1 Under the Data Privacy Act of 2012 and applicable PAGCOR regulations, you have the following rights with respect to your personal data held by pubph:

• Right to be informed: The right to know that pubph is collecting and processing your personal data, and to understand the purposes and legal bases for that processing – as set out in this Privacy Policy;
• Right of access: The right to request a copy of the personal data pubph holds about you, including account information, transaction history, KYC records, and gameplay data;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. Some data fields may be corrected directly through your account dashboard; others require verification before amendment;
• 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 pubph's regulatory retention obligations under PAGCOR rules and anti-money laundering law;
• Right to object: The right to object to the processing of your personal data where pubph relies on legitimate interests as the legal basis, or to opt out of direct marketing communications at any time;
• Right to data portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format, and to request that it be transferred to another controller where technically feasible;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe pubph has processed your personal data in violation of the Data Privacy Act.

9.2 To exercise any of these rights, please contact pubph's Data Protection Officer using the details in Section 13. pubph will respond to data subject requests within 15 business days of receipt of a complete, verified request. We may need to verify your identity before processing a request.

9.3 Where pubph is unable to fulfil a data subject request due to a conflicting legal obligation (for example, regulatory record-keeping requirements under PAGCOR or anti-money laundering law), we will explain the reason for the limitation in writing.

10. Data Retention

10.1 pubph retains personal data for the following periods, or for longer periods where required by law:

• Active accounts: Personal data is retained for the full duration that your pubph account remains open and active;
• Closed accounts: Following account closure, pubph retains identity and KYC records, financial transaction data, and gameplay records for a minimum of five (5) years from the date of account closure, as required under PAGCOR licensing conditions and Republic Act No. 9160 (Anti-Money Laundering Act);
• Customer support records: Complaint records and support interaction logs are retained for three (3) years from the date of resolution;
• Technical and analytics data: Anonymised technical logs and aggregated analytics data may be retained indefinitely, as this data cannot be used to identify individual players;
• Marketing consent records: Records of marketing consent and opt-out requests are retained for the lifetime of the account plus three (3) years to demonstrate compliance.

10.2 Upon expiry of the applicable retention period, pubph will securely delete or anonymise personal data in a manner that prevents reconstruction of the original personal information. Secure deletion procedures include cryptographic erasure of encryption keys for data held in encrypted storage and verified deletion from backup systems within 30 days.

11. Children's Privacy and Underage Players

11.1 pubph verifies player age through the KYC process as a mandatory step before real-money play is permitted. Age verification documentation is reviewed by trained compliance staff and, where applicable, verified through third-party identity verification services.

11.2 If you are a parent or guardian and believe that a minor may have created an account on pubph or accessed the Platform, please contact our support team immediately at [email protected]. We will investigate and take appropriate action, including immediate account closure and data deletion, without delay.

12. Changes to This Privacy Policy

12.1 pubph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or the services we offer. The date of the most recent revision is displayed at the top of this page.

12.2 Where changes to this Privacy Policy are material – meaning they significantly affect your rights or the way pubph processes your personal data – pubph will notify registered players by email to the address on the account, or by a prominent notice on the Platform, at least 14 days before the changes take effect.

12.3 For minor or clarificatory updates that do not materially affect your rights, pubph will update the policy text and the revision date without separate notice. Your continued use of the Platform after any update constitutes your acknowledgment of the revised Privacy Policy.

12.4 We encourage you to review this Privacy Policy periodically to stay informed about how pubph protects your personal data.

13. Contact – Data Protection Officer

13.1 For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by pubph, please contact our Data Protection Officer through the following channel:

13.2 If you are not satisfied with pubph's response to a privacy concern or data subject request, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC), the authority responsible for enforcing the Data Privacy Act of 2012. Details of how to contact the NPC are available through the official Philippine government channels.

13.3 Please include your full registered name, account username, a clear description of your request or concern, and a copy of a valid ID when submitting a data subject request to allow for efficient and accurate processing.