pub333 Privacy Policy

Who We Are — The Data Controller

pub333 operates the online casino and sports betting platform accessible at pub333.club. For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, pub333 acts as the personal information controller in respect of the personal data of Filipino players and visitors to pub333.club.

pub333 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable Philippine data privacy law. Contact details for the DPO are provided at the end of this document in Section 16.

Scope & Consent

This Privacy Policy applies to all personal data collected by pub333 in connection with your use of pub333.club — including account registration, gaming activity, deposits and withdrawals, customer support interactions, promotional participation, and all other interactions with the Platform.

By creating a pub333 account or continuing to use the Platform after being directed to this Privacy Policy, you acknowledge that you have read and understood this document and consent to the collection, use, and processing of your personal data as described herein. Where processing is based on consent, you have the right to withdraw that consent at any time by contacting pub333 support, subject to the limitations described in Section 11.

Personal Data We Collect

pub333 collects personal data through several channels — directly from you when you register or interact with the Platform, automatically through technical systems as you use the site, and from third parties where required for verification or payment processing. The categories of data we collect are outlined below.

How pub333 Uses Your Personal Data

pub333 processes personal data only for specific, declared purposes that are directly connected to the operation of the Platform and our obligations under Philippine law. We do not process personal data for purposes incompatible with those declared below.

Legal Basis for Processing

pub333 processes personal data on one or more of the following legal bases as recognised under the Data Privacy Act of 2012:

• Contract Performance: Processing your identity, contact, and financial data is necessary to operate your pub333 account and deliver the gaming services you have contracted to receive.
• Legal Obligation: KYC verification, AML transaction monitoring, and regulatory reporting are required by Philippine law regardless of consent.
• Legitimate Interest: Processing for security, fraud prevention, responsible gaming monitoring, and improvement of platform services is pursued on the basis of pub333's legitimate interests, balanced against your rights and freedoms as a data subject.
• Consent: Marketing communications and non-essential cookies are processed on the basis of your consent, which may be withdrawn at any time without affecting the lawfulness of prior processing.

Cookies & Technical Tracking

pub333 uses cookies and similar tracking technologies to enable core Platform functionality, maintain your login session, prevent fraud, and analyse Platform performance. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled without preventing you from using pub333.
• Functional Cookies: Remember your preferences such as language settings, game view preferences, and whether you have acknowledged certain notices. These improve your experience but are not strictly required.
• Analytics Cookies: Used to collect aggregated, anonymised data about how players navigate and use pub333, helping us identify performance issues and improve the platform. Individual player journeys are not profiled for commercial purposes through analytics cookies.
• Security Cookies: Used to detect suspicious login attempts, prevent CSRF attacks, and ensure session integrity. These are essential to account protection and cannot be disabled.

You can manage non-essential cookies through your browser settings. Note that disabling strictly necessary or security cookies will impair your ability to log in and use pub333 normally.

Data Sharing & Third-Party Disclosure

pub333 does not sell, rent, or trade personal data. Data is shared with third parties only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Processors: GCash (GXI), Maya, BPI, BDO, Metrobank, and other payment partners receive transactional data necessary to process deposits and withdrawals. These partners maintain their own privacy policies and are independently regulated in the Philippines.
• KYC & Identity Verification Providers: Third-party verification services receive identity documents and facial verification data to perform regulatory compliance checks. These providers are contractually bound to process data only for verification purposes.
• Game Content Providers: Game studios whose titles are hosted on pub333 may receive anonymised session and outcome data for game performance and RNG audit purposes. No identifiable player data is shared with game providers.
• Regulatory Authorities: pub333 is required by law to share personal data with PAGCOR, the AMLC, the NPC, and other Philippine government bodies when legally compelled to do so. pub333 will not notify you of such disclosures where prohibited by law.
• Legal Proceedings: Personal data may be disclosed to courts, legal advisers, or law enforcement agencies in connection with legal proceedings, the exercise of legal rights, or the protection of pub333's legitimate interests.
• Business Transfers: In the event of a merger, acquisition, or business transfer involving pub333, personal data may be transferred to the successor entity subject to equivalent privacy protections and notification to affected players.

Data Retention

pub333 retains personal data for as long as is necessary for the purposes for which it was collected, subject to the following retention considerations:

• Account data (identity, contact, and registration records) is retained for the duration of the active account relationship plus a minimum of five (5) years following account closure, in line with Philippine AML statutory requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC documents (ID images, facial verification records) are retained for the same period as financial transaction records and are subject to the same access controls.
• Gaming activity logs are retained for a rolling period of two (2) years from the date of the session, unless a longer period is required for an open dispute or investigation.
• Customer support communications are retained for two (2) years from the date of the last interaction, unless linked to a dispute that extends that period.
• Marketing consent records are retained for the period during which consent is active plus sufficient additional time to demonstrate compliance if challenged.

Upon the expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with pub333's data destruction procedures. Anonymised aggregate data (with no possibility of re-identification) may be retained indefinitely for statistical and product improvement purposes.

Security Measures

pub333 implements a layered security approach to protect personal data against unauthorised access, loss, alteration, or disclosure. Key security measures include:

• TLS 1.2+ encryption for all data in transit between your device and pub333's servers.
• Encryption at rest for sensitive data categories including KYC documents and financial records.
• Role-based access control (RBAC) limiting employee access to personal data to only those whose job function requires it.
• Multi-factor authentication for internal system access by pub333 personnel.
• Regular security audits and penetration testing of Platform infrastructure.
• Comprehensive audit logging of all access to personal data records.
• Incident response procedures aligned with NPC Circular requirements for data breach notification.

Cross-Border Data Transfers

Some of pub333's service providers — including certain game content providers and technical infrastructure partners — are located outside the Philippines. Where personal data is transferred to entities in other countries, pub333 ensures that adequate safeguards are in place in accordance with NPC rules on cross-border data flows.

Such safeguards include contractual clauses that impose data protection standards equivalent to those required under Philippine law, and pre-transfer assessments of the recipient country's data protection framework. Personal data transferred cross-border is limited to the minimum necessary for the specific service function involved and is not used for purposes other than those stated in this Privacy Policy.

Your Rights as a Data Subject

Under the Data Privacy Act of 2012, Filipino players whose personal data is processed by pub333 have the following rights:

To exercise any of these rights, contact the pub333 Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request". pub333 will acknowledge your request within 3 business days and respond fully within 15 business days. You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

Children & Minors — 21+ Policy

pub333 is strictly for individuals aged 21 years and above. The Platform does not knowingly collect personal data from persons under 21 years of age. If pub333 discovers that personal data has been collected from an individual under the age of 21, all such data will be deleted immediately and the associated account will be closed without delay.

If you are a parent or guardian and have reason to believe that a person under 21 in your household has registered an account with pub333 or submitted personal data to the Platform, please notify pub333 immediately at [email protected] so that appropriate action can be taken. pub333 recommends that parents and guardians implement device-level parental controls to prevent minors from accessing online gambling platforms.

Third-Party Services & External Links

pub333 does not include external links to third-party websites within the Platform interface beyond those required for payment processing. However, game studios whose titles are hosted on pub333 operate within embedded frames and may collect technical data (such as game session identifiers) through their own systems in the course of delivering game content.

pub333 is not responsible for the privacy practices of its game content providers or payment partners operating under their own separate privacy policies. pub333 exercises due diligence in selecting partners with adequate data protection standards and requires contractual privacy commitments from all service providers.

Data Breach Response

In the event of a personal data breach — defined as a security incident resulting in the accidental or unlawful destruction, loss, alteration, or unauthorised disclosure of personal data — pub333 will:

• Activate its internal incident response procedures immediately upon discovery of the breach.
• Notify the National Privacy Commission (NPC) within 72 hours of becoming aware of a breach likely to result in risk to player rights, as required by NPC Circular No. 16-03.
• Notify affected players without undue delay where the breach is likely to result in a high risk to their rights and freedoms — including risks to their financial data, identity data, or account security.
• Provide affected players with a description of the nature of the breach, the categories of data involved, the likely consequences, and the measures taken or proposed to address the breach.
• Document the breach, its effects, and the remedial measures taken in pub333's internal breach register.

Players who believe their pub333 account or personal data has been compromised should contact [email protected] immediately. pub333's security team will investigate and respond as a priority matter.

Amendments to This Privacy Policy

pub333 may update this Privacy Policy from time to time to reflect changes in our data practices, new regulatory requirements, or improvements to how we protect player data. When material changes are made, pub333 will provide advance notice via a prominent notice on the Platform and, where possible, by email to registered players.

The date of the most recent revision is stated at the top of this document. Continued use of pub333 following notification of a material change constitutes your acknowledgement of the revised Privacy Policy. Where a change requires fresh consent under the Data Privacy Act, pub333 will obtain that consent before the change takes effect.

Contact & Data Protection Officer

Questions, complaints, data subject rights requests, or concerns regarding this Privacy Policy or pub333's data processing practices should be directed to the pub333 Data Protection Officer using the contact details below. All communications must be in writing (email or letter) to ensure a proper audit trail.

• DPO Email: [email protected] — Subject line: "Privacy / DPO"
• General Support: [email protected] — 24/7 live chat also available on Platform
• Response Target: Acknowledgement within 3 business days; full response within 15 business days
• NPC Complaints: If your concern is not resolved to your satisfaction, you may file a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph