Privacy Policy

1. Data Controller

The data controller responsible for personal information collected through the 790pub platform is the operator of 790pub.co, a PAGCOR-licensed online gaming operator incorporated and operating under the laws of the Republic of the Philippines.

790pub has appointed a Data Protection Officer (DPO) in accordance with Republic Act No. 10173 (Data Privacy Act of 2012) and the implementing rules issued by the National Privacy Commission. The DPO may be contacted at the address provided in Section 13 of this Policy.

This Privacy Policy applies to all personal data collected by 790pub through: (a) the 790pub website at 790pub.co; (b) any mobile-optimized web interface operated by 790pub; (c) 790pub's live chat and customer support channels; and (d) any correspondence between you and 790pub, including email, SMS, and in-platform messaging.

2. Personal Data We Collect

790pub collects personal data through various means during your registration, account use, and customer support interactions. The categories of personal data we collect are described below:

2.1 Registration and Identity Data

• Full legal name as it appears on your government-issued ID
• Date of birth (collected for 21+ age verification compliance)
• Philippine mobile phone number
• Email address
• Username chosen at registration
• Residential address (province, city/municipality)

2.2 KYC and Verification Data

• Copy of a valid Philippine government-issued ID (UMID, PhilSys ID, Passport, or Driver's License) including the ID number
• Selfie photograph taken at the time of KYC submission for liveness verification
• Source of funds declaration (for high-value accounts, as required by AMLC regulations)

2.3 Financial and Payment Data

• GCash or Maya account number linked to your 790pub wallet
• Bank account details provided for bank transfer withdrawals (account name, bank, account number)
• Transaction history including deposits, withdrawals, bet amounts, wins, and losses
• Cryptocurrency wallet addresses used for USDT TRC20 transactions

2.4 Gameplay and Behavioral Data

• Game session logs including games played, bet amounts, and game outcomes
• Login timestamps and session duration data
• Bonus and promotion redemption records
• Responsible gaming tool usage (deposit limits set, self-exclusion requests, cool-off periods)

2.5 Technical and Device Data

• IP address at time of login and transaction
• Device type, operating system, and browser type
• Mobile network operator (e.g., Globe, Smart, DITO) where detectable
• Cookie identifiers and session tokens (see Section 6)

2.6 Communication Data

• Content of live chat conversations with 790pub support agents
• Email correspondence with 790pub
• SMS verification records

3. How We Use Your Personal Data

790pub uses personal data collected from Players for the following purposes:

790pub does not use automated decision-making that produces legal or similarly significant effects on Players without human review, except for real-time fraud detection systems where immediate automated action is required to prevent financial loss to the Player or 790pub. Where such automated systems flag an account, a human review is initiated within 24 hours.

4. Legal Bases for Processing

790pub processes personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform the contract between 790pub and the Player, including account management, game provision, and payment processing.
• Legal Obligation: Processing required to comply with PAGCOR regulations, anti-money laundering obligations under RA 9160 (AMLA), and other applicable Philippine law.
• Legitimate Interests: Processing for fraud prevention, security monitoring, platform improvement, and abuse prevention, where such interests do not override the Player's fundamental rights.
• Consent: Processing for optional purposes such as marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of prior processing or your ability to continue using 790pub's services.

5. Data Sharing and Disclosure

5.1 Service Providers

790pub shares personal data with third-party service providers who assist in operating the platform. These include: payment processors (GCash / Maya APIs, banking APIs), KYC verification service providers, game software providers who operate certified RNG games on the 790pub platform, cloud hosting providers, and customer support software providers. All service providers are bound by data processing agreements requiring them to process data only for the purposes specified and in compliance with Philippine data protection law.

5.2 Regulatory Disclosures

790pub is legally obligated to disclose Player data to: PAGCOR, pursuant to its regulatory oversight authority; the Anti-Money Laundering Council (AMLC) when transactions meet mandatory reporting thresholds; and any Philippine court or law enforcement authority pursuant to a valid subpoena, court order, or other lawful process.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or a material portion of 790pub's business, Player personal data may be transferred to the successor entity. Players will be notified of any such transfer and of any material changes to data processing arrangements that may result.

5.4 No Sale of Personal Data

790pub does not sell, rent, or commercially license Player personal data to any third party for marketing or commercial purposes. This prohibition applies without exception.

6. Cookies and Tracking Technologies

790pub uses cookies and similar tracking technologies to maintain session authentication, detect fraud, and improve platform performance. The categories of cookies used are:

• Strictly Necessary Cookies: Required for login session management, security token authentication, and platform functionality. These cannot be disabled without rendering the platform unusable.
• Performance Cookies: Used to collect aggregated, anonymized data on page load times, error rates, and feature usage to improve platform performance. No personally identifiable information is collected through performance cookies.
• Fraud Prevention Cookies: Used by our security systems to identify unusual access patterns that may indicate account takeover attempts or fraudulent transactions.

790pub does not use third-party advertising cookies or behavioral tracking cookies for retargeting purposes. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will prevent you from logging in to 790pub.

7. Data Retention

790pub retains personal data for the following periods:

• Account and KYC data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR regulations and Philippine anti-money laundering law.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with RA 9160 (AMLA) record-keeping requirements.
• Communication data (support chats, emails): Retained for two (2) years from the date of communication, or longer where the communication relates to an unresolved dispute or regulatory inquiry.
• Gameplay session logs: Retained for two (2) years for responsible gaming monitoring and regulatory reporting purposes.
• Marketing consent records: Retained for three (3) years from the date of consent or withdrawal of consent, to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification.

8. Data Security

790pub implements the following technical and organizational security measures to protect your personal data:

• 256-bit TLS encryption for all data in transit between your device and 790pub servers.
• AES-256 encryption for sensitive personal data stored at rest, including KYC documents and payment account details.
• Passwords are stored using bcrypt hashing with per-user salts; plaintext passwords are never stored or logged.
• Multi-factor authentication is available to all Players and is mandatory for staff accounts with access to Player data.
• Access to Player personal data is restricted to 790pub personnel who require it for their job functions, governed by role-based access controls.
• Regular penetration testing and vulnerability assessments are conducted on the platform infrastructure.
• All 790pub personnel with access to personal data are subject to confidentiality obligations and receive data privacy training.

In the event of a personal data breach that is likely to result in significant harm to affected Players, 790pub will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected Players without undue delay, in accordance with NPC Circular 16-03.

9. Your Data Subject Rights

Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by 790pub:

• Right to be Informed: The right to be informed whether 790pub holds personal data about you, and to receive this Privacy Policy prior to the collection of your data.
• Right of Access: The right to request a copy of the personal data 790pub holds about you.
• Right to Rectification: The right to require 790pub to correct inaccurate or incomplete personal data held about you.
• Right to Erasure (Right to be Forgotten): The right to request deletion of personal data that is no longer necessary for the purpose for which it was collected, or where your consent has been withdrawn and there is no other legal basis for processing. This right is subject to 790pub's legal retention obligations under PAGCOR and AMLA regulations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. This right is absolute and may be exercised at any time.
• Right to Data Portability: The right to receive a copy of personal data you have provided to 790pub in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe 790pub has processed your personal data in violation of RA 10173.

To exercise any of the above rights, submit a written request to 790pub's Data Protection Officer at the contact details provided in Section 13. 790pub will respond to data subject requests within fifteen (15) business days of receipt.

10. Children's Privacy and Age Restriction

The 790pub platform is strictly restricted to individuals aged 21 years and above. 790pub does not knowingly collect, process, or retain personal data from individuals under 21 years of age. The 21+ age requirement is a mandatory condition of 790pub's PAGCOR authorization.

If 790pub discovers that an account has been created by or on behalf of an individual under 21 years of age, that account will be immediately and permanently suspended, all balances will be forfeited in accordance with 790pub's Terms and Conditions, and any personal data collected from the minor will be securely deleted from 790pub's systems as promptly as technically feasible, except where retention is required by applicable law.

If you believe that a minor has registered on the 790pub platform, please contact us immediately at [email protected] so that we can take immediate action.

11. Cross-Border Data Transfers

790pub's primary servers and data processing infrastructure are located within the Philippines or in jurisdictions that provide adequate data protection standards. Where personal data is transferred to service providers located outside the Philippines (for example, game software providers or cloud infrastructure services that operate regional data centers), such transfers are governed by data transfer agreements that incorporate the standard contractual clauses recognized by the National Privacy Commission or equivalent protective mechanisms.

790pub will not transfer your personal data to a jurisdiction that does not provide adequate data protection guarantees without first obtaining your consent or implementing appropriate safeguards as required by RA 10173.

12. Changes to This Privacy Policy

790pub reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, regulatory requirements, or platform features. When material changes are made, 790pub will: (a) update the "Last Updated" date at the top of this Policy; (b) notify registered Players by email at the address registered to their account; and (c) display a prominent notice on the 790pub platform for a minimum of fourteen (14) days prior to the changes taking effect.

Your continued use of the 790pub platform following the effective date of any revised Privacy Policy constitutes your acknowledgment of and agreement to the updated terms. If you do not agree with the revised Policy, you should cease using the platform and contact us to close your account.

13. Contact and Data Protection Officer

For any privacy-related inquiries, data subject rights requests, or concerns about 790pub's data handling practices, please contact:

• Data Protection Officer, 790pub
• Email: [email protected] — Subject line: "Privacy / DPO Request – [Your Username]"
• Live Chat: Available 24/7 via the 790pub account dashboard. Reference "Privacy Request" at the start of your chat.
• Response Time: DPO correspondence is acknowledged within 2 business days and substantively responded to within 15 business days.

Players who are not satisfied with 790pub's response to a data subject rights request may escalate their complaint to the National Privacy Commission of the Philippines (privacy.gov.ph). 790pub will cooperate fully with any NPC investigation or inquiry.