pub444 Privacy Policy

1.1 For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, hereinafter "DPA") and its Implementing Rules and Regulations, the Data Controller responsible for your personal data is pub444, the operator of the online gaming platform accessible at pub444.vip.

1.2 pub444 operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). Our operations, including our data collection and processing activities, are subject to PAGCOR's regulatory requirements in addition to the DPA.

1.3 pub444 has appointed a Data Privacy Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the DPA. Contact details for the DPO are provided in Section 15 of this Policy.

1.4 This Privacy Policy applies to all personal data collected by pub444 through the pub444.vip platform, including data collected during account registration, KYC verification, gameplay, transactions, customer support interactions, and any other use of pub444's services.

2.1 pub444 collects the following categories of personal data from Players and prospective Players:

2.1 Identity and Contact Data

• Full legal name (as it appears on your government-issued Philippine identification document);
• Date of birth;
• Philippine mobile number;
• Email address;
• Residential address (required for certain KYC verification levels);
• Nationality.

2.2 Identity Verification (KYC) Data

• Copies of government-issued Philippine identification documents (Passport, UMID, SSS ID, Driver's Licence, PhilSys National ID, PRC ID, Voter's ID);
• Selfie photographs submitted for facial identity matching;
• Proof of address documents where required by pub444's KYC level framework.

2.3 Financial and Transaction Data

• GCash account reference (where GCash is used as a deposit or withdrawal method);
• PayMaya/Maya account reference;
• Bank account numbers and bank names for BPI, BDO, UnionBank, and Metrobank transactions;
• Cryptocurrency wallet addresses (USDT TRC20, Coins.ph);
• Deposit history, withdrawal history, and current account balance;
• Transaction reference numbers.

2.4 Gaming Activity Data

• Game session history, including games played, session durations, bet amounts, and game outcomes;
• Wagering history and bet placement records;
• Bonus and promotion usage history;
• Self-exclusion and responsible gaming tool settings and usage history.

2.5 Technical and Device Data

• IP address at the time of access;
• Device type, operating system, and browser type and version;
• Session timestamps and duration;
• Cookie identifiers and session tokens (see Section 7).

2.6 Communications Data

• Records of all communications between you and pub444's support team, including live chat transcripts, email correspondence, and support ticket records.

3.1 pub444 collects your personal data through the following means:

4.1 pub444 processes your personal data only where there is a lawful basis for doing so. Under the Philippine Data Privacy Act, the lawful bases applicable to pub444's processing activities are: (a) performance of a contract; (b) compliance with a legal obligation; (c) legitimate interests of pub444 that do not override your fundamental rights; and (d) your consent, where specifically sought.

4.2 Where pub444 relies on your consent as the legal basis for processing — specifically for marketing communications — you have the right to withdraw that consent at any time by contacting support at [email protected] or by using the opt-out mechanism provided in any marketing communication. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

5.1 KYC documents submitted to pub444 — including copies of government-issued Philippine identification documents and selfie photographs — are treated with heightened care as sensitive personal data under the DPA. KYC data is collected solely for the purposes of PAGCOR-mandated identity verification, age verification (confirming the 21+ minimum age requirement), and anti-money laundering compliance.

5.2 KYC documents are stored in encrypted form on pub444's secure document management system, access to which is strictly limited to pub444's compliance team on a need-to-know basis. KYC documents are never shared with third parties except: (a) where required by PAGCOR or other Philippine regulatory authorities; (b) where required by a lawfully issued court order or law enforcement directive; or (c) where pub444 engages a PAGCOR-approved third-party KYC verification service provider operating under a data processing agreement that ensures DPA-equivalent data protection standards.

5.3 Once KYC verification is completed and the Account is in good standing, pub444 does not display or routinely re-access your KYC documents. They are retained for the period specified in Section 9 of this Policy to satisfy regulatory record-keeping requirements.

6.1 pub444 does not store full payment card numbers or complete GCash/PayMaya account credentials on its own systems. Financial data processed through pub444's Cashier is handled by the relevant payment gateway or e-wallet provider (GCash, PayMaya/Maya, BPI, BDO, UnionBank, Metrobank, Coins.ph, 7-Eleven Cliqq) under their own applicable terms, privacy policies, and security frameworks.

6.2 pub444 retains transaction reference data — including deposit and withdrawal amounts, timestamps, payment method types, and associated account references (such as partial GCash numbers used for transaction reconciliation) — for the purposes of account balance maintenance, dispute resolution, and PAGCOR/AMLC transaction reporting obligations.

6.3 Financial transaction records at pub444 are subject to the retention period specified in Section 9 of this Policy, consistent with applicable Philippine anti-money laundering record-keeping requirements.

7.1 pub444 uses cookies and similar tracking technologies on the pub444.vip platform. A cookie is a small data file placed on your device by your browser when you visit a website. pub444 uses the following categories of cookies:

• Strictly Necessary Cookies: Essential to the operation of pub444.vip. These cookies enable core functions such as account login sessions, security tokens, and navigation. They cannot be disabled without impairing the Platform's basic functionality.
• Functional Cookies: Remember your preferences (such as your preferred language, display settings, and responsible gaming tool configurations) to improve your experience across sessions.
• Analytics Cookies: Collect anonymised or pseudonymised data about how Players use pub444 — which pages are visited most frequently, session durations, and navigation paths — to help pub444 improve the Platform's design and performance.
• Security Cookies: Used to detect and prevent fraudulent account access, including device fingerprinting for multi-account detection and suspicious login activity monitoring.

7.2 pub444 does not use third-party advertising cookies or behavioural tracking cookies that would share your browsing data with advertising networks. All cookies used on pub444.vip are first-party or serve direct operational and security purposes.

7.3 You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to log in and use pub444's services. Disabling functional or analytics cookies may affect your experience but will not prevent basic Platform access.

8.1 pub444 does not sell, rent, or trade your personal data to any third party for commercial purposes. Personal data is shared only in the following limited circumstances, each of which is necessary for pub444 to fulfil its legal obligations or operational requirements:

• PAGCOR: pub444 is required to report player account data, transaction data, and responsible gaming information to PAGCOR in accordance with its licence conditions and applicable gaming regulations. Data shared with PAGCOR is governed by PAGCOR's own data handling obligations as a Philippine government agency.
• Anti-Money Laundering Council (AMLC): pub444 is required by the Anti-Money Laundering Act (RA 9160 as amended) to report covered and suspicious transactions to the AMLC. Such reporting is mandatory and takes precedence over confidentiality obligations.
• Payment Service Providers: Transactional data necessary to process your deposits and withdrawals is shared with the relevant payment service provider (GCash, PayMaya, BPI, BDO, UnionBank, Metrobank, etc.) solely for the purpose of executing the transaction.
• KYC Verification Providers: Where pub444 uses an authorised third-party KYC verification service, your identity documents may be processed by that provider under a data processing agreement ensuring DPA-compliant data protection standards.
• IT and Security Service Providers: pub444 may engage third-party IT infrastructure, cybersecurity, and fraud detection service providers. Such providers process data only as data processors under pub444's instruction and are bound by contractual data protection obligations.
• Legal and Regulatory Compliance: pub444 may disclose personal data where required by a valid court order, subpoena, or directive from a competent Philippine law enforcement or regulatory authority.

8.2 All third parties who receive personal data from pub444 as data processors are required to process that data only for the specific purpose for which it was shared, under confidentiality obligations consistent with the DPA.

9.1 pub444 retains your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy or as required by applicable law. The following retention periods apply:

9.2 Upon expiry of the applicable retention period, pub444 will securely delete or anonymise your personal data in accordance with its internal data destruction procedures. Data that has been anonymised (such that you can no longer be identified from it) may be retained indefinitely for aggregate statistical purposes.

10.1 pub444 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS Encryption: All data transmitted between your browser and pub444.vip is encrypted using industry-standard TLS protocol. The presence of HTTPS in the pub444.vip URL confirms active encryption.
• Data Encryption at Rest: Sensitive personal data — including KYC documents and financial data — is encrypted at rest on pub444's storage systems using AES-256 or equivalent encryption standards.
• Access Controls: Access to personal data within pub444's systems is restricted on a need-to-know basis. Staff with access to personal data are subject to confidentiality obligations and data protection training.
• Two-Factor Authentication: pub444's internal systems that handle player personal data are protected by multi-factor authentication requirements for all authorised staff.
• Intrusion Detection and Monitoring: pub444 operates continuous monitoring systems to detect and respond to unauthorised access attempts, data breaches, and anomalous system behaviour.
• Vulnerability Management: pub444's platform undergoes regular security assessments and penetration testing by qualified security professionals to identify and remediate vulnerabilities.

10.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, pub444 will notify the National Privacy Commission (NPC) of the Philippines within seventy-two (72) hours of becoming aware of the breach, as required under Section 20(f) of the DPA. Affected individuals will be notified without undue delay where the breach is likely to result in a high risk to their rights and freedoms.

11.1 As a data subject under Republic Act No. 10173 (Philippine Data Privacy Act of 2012), you have the following rights with respect to your personal data held by pub444:

• Right to be Informed: You have the right to be informed whether pub444 processes your personal data and of the details of such processing, including the purposes, legal basis, and retention period — all of which are set out in this Policy.
• Right of Access: You have the right to request a copy of the personal data pub444 holds about you. Requests will be responded to within fifteen (15) business days of verification of your identity.
• Right to Correction: You have the right to request the correction of any inaccurate, incomplete, or outdated personal data pub444 holds about you. You may update some information directly through your Account settings.
• Right to Erasure / Right to be Forgotten: You have the right to request the deletion or removal of your personal data where there is no compelling lawful basis for its continued retention. Note that pub444 is subject to regulatory retention obligations (see Section 9) which may require data to be retained notwithstanding a deletion request.
• Right to Restriction of Processing: You have the right to request that pub444 restrict the processing of your personal data in certain circumstances — for example, while the accuracy of data you have disputed is being verified.
• Right to Data Portability: Where technically feasible and where processing is based on contract or consent, you have the right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Object: You have the right to object to pub444's processing of your personal data for direct marketing purposes at any time. You also have the right to object to processing based on pub444's legitimate interests, subject to a balancing assessment.
• Right to Damages: You have the right to be indemnified for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data by pub444.

11.2 To exercise any of the above rights, please submit a written request to pub444's Data Privacy Officer at the contact details in Section 15. pub444 will verify your identity before processing any rights request. There is no charge for submitting a rights request. pub444 will respond within fifteen (15) business days of receiving a valid, verified request.

11.3 If you are not satisfied with pub444's response to a rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the independent supervisory authority for data protection in the Republic of the Philippines.

12.1 pub444 does not knowingly collect, process, or retain personal data from individuals under the age of twenty-one (21) years. Age verification is conducted as part of the mandatory KYC process for all Account holders before full platform access is granted.

12.2 If pub444 becomes aware that it has inadvertently collected personal data from a person under 21 years of age — whether through failure of the KYC verification process, provision of false information during registration, or any other means — pub444 will immediately close the Account, withhold or return any balance in accordance with PAGCOR guidelines, and securely delete the associated personal data to the extent not prohibited by applicable law.

12.3 If you are a parent or guardian and believe that a minor has accessed pub444 using false age information, please contact pub444's support team immediately at [email protected]. pub444 will investigate and act promptly on all such reports.

13.1 The pub444.vip platform may contain references to, or integrations with, third-party payment services (such as GCash and PayMaya). While these services are integrated into pub444's Cashier, the data you provide directly to GCash, PayMaya, or other payment platforms within their own application environments is governed by those providers' own privacy policies and terms of service.

13.2 pub444 is not responsible for the privacy practices of third-party payment providers, and we recommend that you review their respective privacy policies before using their services in connection with your pub444 account. pub444's Privacy Policy applies only to data processed within the pub444.vip platform environment.

14.1 pub444 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, new regulatory requirements, or improvements to our privacy framework. The "Effective Date" at the top of this Policy will be updated to reflect the date on which any revised version takes effect.

14.2 Material changes to this Privacy Policy — such as changes to the categories of data collected, the purposes for which data is used, or the rights available to you — will be communicated to registered Players via email to the address on file at least seven (7) days before the changes take effect, where reasonably practicable.

14.3 Continued use of the pub444 Platform following the effective date of a revised Privacy Policy constitutes your acknowledgement of and agreement to the revised Policy. We encourage you to review this Policy periodically to stay informed about how pub444 protects your personal data.

15.1 For any questions, concerns, or requests relating to this Privacy Policy or pub444's data processing activities, please contact pub444's Data Privacy Officer using the following details:

15.2 You may also contact pub444's general support team for non-DPO enquiries at [email protected] during support hours of 8:00 AM to 12:00 AM Philippine Standard Time, seven days a week.

15.3 For escalated data privacy complaints that have not been resolved through pub444's internal process, you have the right to contact the National Privacy Commission of the Philippines (NPC) through its published regulatory channels. The NPC is the independent supervisory authority responsible for the enforcement of the Philippine Data Privacy Act.

15.4 For responsible gaming concerns, self-exclusion requests, or mental health and gambling support resources, please visit pub444's Responsible Gaming page. For the full contractual terms governing your use of pub444, please refer to the Terms & Conditions.