pubph Privacy Policy

1 Data Controller

pubph, operating through pubph.app, is the data controller responsible for the personal data collected through this platform. As data controller, pubph determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

pubph has appointed a Data Protection Officer (DPO) who is responsible for overseeing data protection strategy and implementation, and for ensuring compliance with applicable data privacy laws. Contact details for the DPO are provided in Section 14 of this Privacy Policy.

This Privacy Policy applies to all personal data collected by pubph through pubph.app, including data collected during account registration, gameplay, payment processing, customer support interactions, and use of any other features or services offered on the platform.

2 Data We Collect

pubph collects personal data that is necessary to provide you with a safe, secure, and compliant online gaming experience. The categories of personal data we collect include:

pubph does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by law (for example, in the context of responsible gaming assessments).

3 How We Use Your Data

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

• Account Management: To create, maintain, and manage your pubph account, including verifying your identity and age (21+) as required by Philippine law.
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver the full range of pubph services.
• Payment Processing: To process financial transactions via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels, and to maintain accurate transaction records.
• Legal Compliance: To comply with anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, PAGCOR regulatory requirements, and other applicable Philippine laws and regulations.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the platform.
• Responsible Gaming: To monitor gameplay patterns and identify players who may be at risk of problem gambling, and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Customer Support: To respond to your inquiries, complaints, and support requests, and to maintain records of our communications with you.
• Platform Improvement: To analyze usage patterns and technical data in order to improve the performance, security, and user experience of the pubph platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may withdraw this consent at any time.

pubph will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

4 Legal Basis for Processing

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

• Contractual Necessity: Processing is necessary to perform the contract between you and pubph — that is, to provide you with access to the platform and its services in accordance with our Terms & Conditions.
• Legal Obligation: Processing is necessary for pubph to comply with its legal obligations under Philippine law, including AML regulations, KYC requirements, and PAGCOR licensing conditions.
• Legitimate Interests: Processing is necessary for the legitimate interests of pubph, including fraud prevention, platform security, and responsible gaming monitoring, provided that such interests are not overridden by your rights and interests.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — pubph relies on your freely given, specific, informed, and unambiguous consent. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5 Data Sharing & Disclosure

pubph does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and age verification service providers who assist pubph in verifying the identity and age of players.
• Game Software Providers: Licensed game developers and studios whose games are available on the pubph platform, to the extent necessary to deliver gameplay services.
• Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other legal process.
• IT & Security Service Providers: Cloud hosting providers, cybersecurity firms, and technical support vendors who process data on behalf of pubph under strict data processing agreements.

All third parties with whom pubph shares personal data are required to handle that data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

6 Data Retention

pubph retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account Data: Retained for the duration of your account and for a period of five (5) years following account closure, in accordance with AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC Documents: Retained for five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Customer Support Records: Retained for three (3) years from the date of the last interaction.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of the consent given.
• Technical & Usage Data: Retained for up to two (2) years for platform analytics and security purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with pubph's data disposal procedures.

7 Data Security

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

• Encryption: All data in transit is protected by 256-bit SSL/TLS encryption. Sensitive data at rest, including passwords and financial information, is encrypted using industry-standard cryptographic algorithms.
• Access Controls: Access to personal data within pubph is restricted to authorized personnel who require access to perform their job functions. All access is logged and audited.
• Password Security: User passwords are stored using one-way cryptographic hashing with salting. pubph staff cannot view your password in plain text.
• Penetration Testing: pubph conducts regular security assessments and penetration tests to identify and remediate vulnerabilities in the platform.
• Incident Response: pubph maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, pubph will notify the National Privacy Commission (NPC) within 72 hours and will notify affected players without undue delay.
• Staff Training: All pubph personnel who handle personal data receive regular data protection and security training.

While pubph takes all reasonable steps to protect your personal data, no method of transmission over the internet or method of electronic storage is 100% secure. You are responsible for keeping your pubph account credentials confidential and for notifying pubph immediately if you suspect any unauthorized access to your account.

8 Cookies & Tracking Technologies

pubph uses cookies and similar tracking technologies on pubph.app to enhance your experience, maintain your session, and analyze platform usage. The following types of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for the operation of pubph.app. They enable core functions such as user authentication, session management, and security. These cookies cannot be disabled without affecting the functionality of the platform.
• Performance & Analytics Cookies: These cookies collect anonymized information about how players use pubph.app, such as which pages are visited most frequently and whether error messages are received. This data helps pubph improve the platform. These cookies require your consent.
• Functional Cookies: These cookies allow pubph.app to remember your preferences, such as your preferred language and display settings, to provide a more personalized experience.
• Marketing Cookies: These cookies may be used to deliver promotional content that is relevant to your interests. They require your explicit consent and may be withdrawn at any time.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of pubph.app. For more information on how to manage cookies, refer to your browser's help documentation.

9 Your Data Rights

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

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfils that obligation.
• Right of Access: You have the right to request a copy of the personal data that pubph holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data that pubph holds about you. You may update most of your account information directly through your pubph account settings.
• Right to Erasure: You have 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 legal obligations to retain certain data.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes. You may also object to processing based on legitimate interests, subject to pubph demonstrating compelling legitimate grounds.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that pubph has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact pubph's Data Protection Officer using the contact details provided in Section 14. pubph will respond to all verified data rights requests within thirty (30) days of receipt.

10 Protection of Minors

pubph is strictly an adult platform. Access to pubph is limited to individuals who are at least 21 years of age, in accordance with Philippine law governing online gambling and casino-style gaming. pubph does not knowingly collect personal data from any person under the age of 21.

If pubph becomes aware that personal data has been collected from a person under the age of 21, pubph will take immediate steps to delete that data and close the associated account. Any winnings or balances associated with an underage account will be forfeited.

If you are a parent or guardian and believe that your child has registered on pubph or provided personal data to pubph, please contact us immediately using the contact details in Section 14 so that we can take appropriate action.

11 International Data Transfers

pubph primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to, or accessed by, service providers located outside the Philippines — for example, cloud infrastructure providers or game software developers operating in other jurisdictions.

Where personal data is transferred outside the Philippines, pubph ensures that appropriate safeguards are in place to protect your data, including contractual clauses that require the recipient to process personal data in accordance with standards equivalent to those required by the Philippine Data Privacy Act of 2012.

By using pubph, you acknowledge and consent to the transfer of your personal data outside the Philippines where necessary for the provision of the pubph service, subject to the safeguards described above.

12 Third-Party Services

pubph.app may contain links to or integrations with third-party services, including payment gateways such as GCash and PayMaya. When you interact with these third-party services, you are subject to their own privacy policies and terms of service, which are separate from and independent of this Privacy Policy.

pubph is not responsible for the privacy practices of third-party services. We encourage you to review the privacy policies of any third-party services you use in connection with your pubph account. pubph does not endorse or make any representations about the privacy practices of third-party services.

13 Changes to This Privacy Policy

pubph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. The most current version of this Privacy Policy will always be available at pubph.app/privacy-policy, with the "Last Updated" date revised accordingly.

For material changes to this Privacy Policy, pubph will make reasonable efforts to notify registered players via email or in-platform notification at least seven (7) days before the changes take effect. Your continued use of pubph after the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy.

If you do not agree with any amendment to this Privacy Policy, you should stop using pubph and may close your account in accordance with the account termination provisions in the pubph Terms & Conditions.

14 Contact & Data Protection Officer

If you have 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 using the details below. All contact details are provided for informational purposes and must not be used as clickable links.

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Response Time: Within 30 days of receipt of a verified data rights request
• Support Hours: 24 hours a day, 7 days a week

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) if you believe that pubph has processed your personal data in a manner that violates the Data Privacy Act of 2012. Information about how to file a complaint with the NPC is available through official Philippine government channels.

For responsible gaming concerns or self-exclusion requests, please visit our Responsible Gaming page or contact the support team directly.