pub444 Privacy Policy

1. Introduction

pub444 ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of every player who uses pub444.net. This Privacy Policy describes our practices for collecting, using, processing, disclosing, and safeguarding the personal information you provide or that is generated when you access or use the pub444 platform.

This policy applies to all users of pub444 — including registered players, visitors who browse the platform without registering, and individuals who contact our support team. By accessing pub444 or creating an account, you acknowledge that you have read and understood this Privacy Policy.

This Privacy Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines.

2. Data Controller

The data controller responsible for your personal information in connection with pub444 is the operating entity behind pub444.net. For all data privacy matters, including data subject access requests and complaints, the Data Protection Officer may be contacted at:

• Email: [email protected] (subject line: "Data Privacy Request")
• Response time: pub444 will acknowledge data subject requests within five (5) business days and provide a substantive response within fifteen (15) business days of acknowledgement.

3. Personal Data We Collect

pub444 collects personal data through multiple channels. The categories of data collected and their sources are set out below:

3.1 Data You Provide Directly

• Registration data: Full legal name, date of birth, nationality, residential address, mobile number, and email address.
• KYC documents: Government-issued Philippine identification (PhilSys National ID, driver's licence, passport, UMID, SSS/GSIS ID, or equivalent), selfie/liveness verification images, and where required, source of funds documentation.
• Payment data: GCash mobile number, Maya account details, bank account details (BPI, BDO, UnionBank, Metrobank, etc.), and cryptocurrency wallet addresses for USDT TRC20 transactions. pub444 does not store full card numbers; payment instrument data is handled by PCI-compliant processors.
• Support communications: The content of messages sent to pub444 support via live chat, email, or any other communication channel.

3.2 Data Collected Automatically

• Device and connection data: IP address, device type, operating system, browser type and version, and mobile network operator.
• Usage data: Pages visited, games played, bet amounts and outcomes, session duration, login and logout timestamps, and feature interactions within the pub444 platform.
• Geolocation data: General location derived from IP address for regulatory compliance and fraud prevention. pub444 does not collect precise GPS coordinates without explicit consent.
• Cookie and tracking data: As described in Section 8 of this policy.

3.3 Data Received from Third Parties

• Identity verification results from third-party KYC service providers.
• Payment transaction confirmation data from GCash, Maya, BPI, BDO, and other payment processors.
• Fraud screening signals from anti-fraud and anti-money laundering service providers.

4. How pub444 Uses Your Personal Data

pub444 processes your personal data for the following purposes:

5. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, pub444 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between pub444 and the Player — including account management, game delivery, and payment processing.
• Legal obligation: Processing required to comply with PAGCOR regulations, AML obligations under RA 9160, and other applicable Philippine law.
• Legitimate interests: Fraud prevention, platform security, responsible gaming monitoring, and internal analytics — where such interests are not overridden by the Player's rights.
• Consent: Marketing communications and any processing not covered by the above bases. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Data Sharing & Disclosure

pub444 does not sell, rent, or trade your personal data. We may share your information only in the following circumstances:

• Service providers: Third-party vendors who process data on pub444's behalf under binding data processing agreements — including KYC providers, payment processors (GCash/Maya APIs, bank payment gateways), game software providers, fraud prevention services, and cloud infrastructure providers. All such providers are contractually obligated to process data only for the specified purpose and in accordance with RA 10173.
• Regulatory and law enforcement: Where required by PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or any competent Philippine court or law enforcement authority.
• Business transfers: In the event of a merger, acquisition, or sale of substantially all of pub444's assets, your data may be transferred to the acquiring entity, subject to equivalent data protection commitments.
• With your consent: Any other sharing specifically authorised by you.

7. Data Retention

pub444 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and transaction records: A minimum of five (5) years following account closure, as required by AML regulations and PAGCOR compliance obligations.
• KYC documentation: A minimum of five (5) years from the date of last transaction, or longer if required by applicable law.
• Support communications: Two (2) years from the date of the last interaction, unless subject to an active dispute.
• Marketing data: Until consent is withdrawn, after which it is deleted within thirty (30) days.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised so that it can no longer be attributed to an identifiable individual.

8. Cookies & Tracking Technologies

pub444 uses cookies and similar tracking technologies (such as web beacons and local storage) to operate and improve the platform. The categories of cookies we use are:

• Essential cookies: Required for pub444 login authentication, session management, and security features. These cannot be disabled without affecting platform functionality.
• Performance cookies: Collect anonymised data on how players use pub444 — such as page load times and error rates — to support platform improvements.
• Functional cookies: Remember your preferences, such as language settings, preferred payment method, and game history, to personalise your pub444 experience.
• Analytics cookies: Help pub444 understand aggregate user behaviour patterns to improve the platform. These do not identify individual players.

You may control non-essential cookies through your browser settings. Note that disabling essential cookies will prevent you from accessing your pub444 account. pub444 does not use advertising cookies or sell cookie data to third-party advertising networks.

9. Security Measures

pub444 implements a multi-layered approach to data security:

• Encryption: All data transmitted between your device and pub444's servers is encrypted using TLS 1.2 or higher (256-bit SSL). Sensitive data at rest is encrypted using industry-standard algorithms.
• Access controls: Personal data is accessible only to pub444 staff and systems that require it to perform their function. All staff with data access undergo privacy and security training.
• Two-factor authentication: pub444 strongly encourages all players to enable 2FA on their accounts. Internal administrative access to player data requires multi-factor authentication.
• Fraud monitoring: pub444 operates continuous automated monitoring for suspicious login attempts, unusual transaction patterns, and other security anomalies.
• Breach response: In the event of a personal data breach that poses a risk to your rights, pub444 will notify the National Privacy Commission within 72 hours and affected players without undue delay, as required by NPC regulations.

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 pub444:

• Right to be informed: The right to know how your data is being collected and processed — fulfilled by this Privacy Policy.
• Right of access: The right to obtain a copy of the personal data pub444 holds about you and information about how it is processed.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected. You may update basic account details directly through your pub444 account settings; other corrections require a written request to our DPO.
• Right to erasure ("right to be forgotten"): The right to request deletion of your personal data where there is no legal basis for continued retention. Note that AML and regulatory obligations require pub444 to retain certain transaction and identity records for a minimum period regardless of an erasure request.
• Right to object: The right to object to processing based on legitimate interests or for direct marketing purposes.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, submit a written request to [email protected] with the subject line "Data Subject Rights Request." pub444 will respond within the timeframes required by the NPC.

11. Children's Privacy

pub444 is strictly an adults-only platform. Real-money gaming services are available exclusively to individuals who are 21 years of age or older, consistent with PAGCOR's mandatory age requirement for all casino and online gaming activities in the Philippines.

pub444 does not knowingly collect personal data from any individual under the age of 21. If pub444 discovers that a player has provided false information to circumvent age verification and is in fact below the minimum age, the account will be immediately closed, all associated balances will be voided, and any personal data collected will be securely deleted from pub444's systems, subject to any legal obligations to retain records of the underage registration for regulatory reporting purposes.

If you have reason to believe that a minor has registered on pub444, please contact us immediately at [email protected].

12. International Data Transfers

pub444's primary data processing infrastructure is located within the Asia-Pacific region. In some cases, personal data may be processed by service providers located outside the Philippines — for example, cloud infrastructure providers or KYC technology vendors.

Where such transfers occur, pub444 ensures that appropriate safeguards are in place to protect your personal data at a standard equivalent to that required under Philippine law, including through contractual data processing agreements with standard data protection clauses, as recognised by the National Privacy Commission.

13. Changes to This Privacy Policy

pub444 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or platform features. Material changes will be communicated to registered players via email or prominent notice on the pub444 platform at least seven (7) days before taking effect, where reasonably practicable.

The current version of the Privacy Policy will always be accessible at pub444.net/privacy-policy. The "Last Updated" date at the top of this document reflects the date of the most recent revision. Continued use of pub444 after the effective date of an updated Privacy Policy constitutes acceptance of the revised terms.

14. Contact & Data Protection Officer

For any questions, concerns, access requests, or complaints relating to this Privacy Policy or pub444's data processing practices, please contact our Data Protection Officer:

• Email: [email protected] — subject line: "Data Privacy Request"
• Live Chat: Available 24/7 via the pub444 platform
• Response commitment: Acknowledgement within 5 business days; substantive response within 15 business days

If you are not satisfied with pub444's response to your data privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint is available on the NPC's official website.