728pub Privacy Policy

This Privacy Policy ("Policy") describes how 728pub collects, processes, stores, and protects the personal data of individuals who use the 728pub online gaming platform, accessible at 728pub.net, including all related subdomains, mobile applications, and associated digital services (collectively, the "Platform").

This Policy applies to all registered 728pub members, prospective members who browse the Platform without registering, and individuals who contact 728pub through any communication channel. It covers all personal data processing activities carried out by 728pub in connection with the operation and improvement of the Platform.

728pub is committed to protecting personal data in compliance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC). This Policy should be read alongside the 728pub Terms & Conditions.

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, 728pub acts as the personal information controller in respect of all personal data collected through the Platform. 728pub is responsible for determining the purposes and means of personal data processing described in this Policy.

728pub has designated a Data Protection Officer (DPO) responsible for overseeing compliance with data privacy obligations, handling data subject requests, and serving as the primary point of contact for the National Privacy Commission. Members may contact the 728pub DPO through the support channel detailed in Article 15 of this Policy.

728pub collects only the personal data that is necessary, adequate, and not excessive relative to the purposes for which it is processed. The categories of personal data 728pub may collect include:

3.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identification
• Date of birth (for age verification — you must be 21 or older to use 728pub)
• Email address and mobile phone number
• Residential address (city, province, postal code)
• Nationality and country of residence

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, UMID, SSS ID, PhilHealth ID, driver's license, or voter's ID)
• Proof of address documents (e.g., utility bills, bank statements, or barangay clearance)
• Proof of payment method ownership (e.g., GCash account screenshot or bank confirmation)
• Source of funds declarations where required for high-value transactions

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records including amounts, timestamps, and payment method references
• Account balance history and bonus credit/debit records
• GCash account details, PayMaya account details, BPI/BDO/Metrobank account details (reference numbers only — 728pub does not store full bank account credentials)

3.4 Gaming Activity Data

• Game session logs including game type, wager amounts, outcomes, and session duration
• Sports betting slip history and settlement records
• Bonus usage, wagering progress, and promotional participation history

3.5 Technical & Device Data

• IP address and approximate geographic location derived from IP
• Device type, operating system, and browser type and version
• Login timestamps, session duration, and platform navigation data
• Cookie identifiers and similar tracking technology data (see Article 8)

3.6 Communications Data

• Records of customer support interactions including chat transcripts and email correspondence
• Feedback and survey responses voluntarily submitted by members
• Records of marketing consent and communication preferences

728pub collects personal data through the following means:

4.1 Direct Collection

Data you provide directly to 728pub when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, participate in a promotion, or respond to a survey or feedback request.

4.2 Automated Collection

Data collected automatically as you interact with the 728pub platform, including through cookies, web beacons, server logs, and similar technologies that record your device information, IP address, session activity, and platform navigation behavior.

4.3 Third-Party Sources

728pub may receive personal data from third-party sources in limited circumstances, including:

• Payment processors (e.g., GCash, PayMaya, BPI, BDO, Metrobank, InstaPay) who confirm transaction status and payment method ownership
• Identity verification and fraud prevention service providers who assist 728pub in validating member-submitted KYC documents
• Regulatory bodies including PAGCOR where disclosure is required in connection with licensing compliance or dispute resolution

728pub processes your personal data on one or more of the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform the contract between 728pub and the member — including account creation, transaction processing, bonus management, and customer support.
• Legal Obligation: Processing required to comply with applicable Philippine law, PAGCOR regulations, and Anti-Money Laundering Act (AMLA) obligations — including KYC verification, transaction monitoring, and regulatory reporting.
• Legitimate Interests: Processing necessary for 728pub's legitimate interests in fraud prevention, platform security, responsible gaming enforcement, and service improvement — where these interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

728pub uses the personal data collected for the following purposes:

• Account Management: Creating, maintaining, and managing your 728pub account, including processing login authentication and account security.
• Identity & Age Verification: Confirming that you meet the 21+ age requirement and verifying your identity in accordance with PAGCOR and AMLA requirements.
• Transaction Processing: Processing deposits and withdrawals in PHP through GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay.
• Bonus & Promotion Administration: Crediting, tracking, and administering promotional bonuses and ensuring fair use of 728pub promotional offers.
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, account takeovers, money laundering, and other prohibited conduct.
• Responsible Gaming: Monitoring gaming behavior to identify potential problem gambling indicators and administering deposit limits, cool-off periods, and self-exclusion tools.
• Customer Support: Responding to enquiries, resolving disputes, and processing complaints submitted through 728pub's support channels.
• Platform Improvement: Analyzing aggregate usage data to improve the 728pub platform's features, performance, and user experience.
• Legal & Regulatory Compliance: Fulfilling 728pub's obligations under applicable Philippine law, PAGCOR regulations, and AMLA requirements, including mandatory reporting to relevant authorities.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to members who have opted in — subject to your communication preferences.

728pub does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 728pub may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

7.1 Service Providers

Third-party service providers engaged by 728pub to assist in operating the platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank, InstaPay), identity verification providers, fraud detection services, IT infrastructure and hosting providers, and customer support platform operators. These providers are contractually bound to process your data only on 728pub's instructions and to maintain appropriate data security standards.

7.2 Regulatory & Law Enforcement Authorities

728pub may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent Philippine authorities where required by law, court order, regulatory direction, or legitimate law enforcement request.

7.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 728pub's business, your personal data may be transferred to the acquiring entity as part of that transaction. 728pub will notify affected members of any such transfer that materially affects their data rights.

7.4 Professional Advisers

728pub's legal counsel, auditors, and compliance consultants may access member data on a confidential basis where necessary to obtain professional advice or conduct audits.

728pub uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit a website. The types of cookies used by 728pub include:

You can manage or disable non-essential cookies through your browser's settings. Please note that disabling essential cookies will impair the functionality of the 728pub platform and may prevent you from accessing your account.

728pub retains personal data for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, accounting, and reporting requirements. The key retention periods applied by 728pub are as follows:

• Active Account Data: Retained for the duration of your 728pub membership and for a period of five (5) years following account closure, in compliance with AMLA and PAGCOR record-keeping requirements.
• KYC Documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later.
• Transaction Records: Retained for a minimum of five (5) years in accordance with Anti-Money Laundering Act obligations.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution.
• Marketing Consent Records: Retained for three (3) years from the date of last consent action (opt-in or opt-out) as evidence of lawful processing.
• Technical Logs: Retained for twelve (12) months for security monitoring and fraud investigation purposes.

Upon expiry of the applicable retention period, 728pub will securely delete or anonymize your personal data in accordance with its data disposal procedures.

728pub implements appropriate technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. The security measures applied by 728pub include:

• Encryption: All data transmitted between your device and the 728pub platform is encrypted using Transport Layer Security (TLS). Sensitive data at rest is encrypted using industry-standard algorithms.
• Access Controls: Access to member personal data within 728pub's systems is restricted to authorized personnel on a strict need-to-know basis. Access rights are reviewed periodically and revoked promptly upon role change or departure.
• Infrastructure Security: The 728pub platform is hosted on secure infrastructure with firewalls, intrusion detection systems, and regular vulnerability assessments.
• Incident Response: 728pub maintains a data breach response procedure. In the event of a personal data breach that poses a risk to data subjects, 728pub will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected members without undue delay.

Under Republic Act No. 10173 and its Implementing Rules and Regulations, you have the following rights in relation to your personal data held by 728pub:

• Right to Be Informed: The right to be informed of how your personal data is being processed — fulfilled through this Privacy Policy.
• Right of Access: The right to obtain confirmation of whether 728pub processes your personal data and to receive a copy of that data.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected without undue delay.
• Right to Erasure: 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 728pub's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing or profiling purposes.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission if you believe 728pub has violated your data privacy rights.

To exercise any of these rights, please contact the 728pub Data Protection Officer using the contact details provided in Article 15. 728pub will respond to all verified data subject requests within thirty (30) calendar days of receipt.

The 728pub platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with PAGCOR regulations governing online gaming in the Philippines. 728pub does not knowingly collect personal data from individuals under 21 years of age.

If 728pub becomes aware that personal data has been collected from a person under the age of 21, it will promptly close the account, void all transactions, and delete the personal data collected, subject to any mandatory regulatory retention requirements. Parents and guardians who believe their child may have registered a 728pub account should contact us immediately at the details provided in Article 15.

728pub's primary data processing and storage infrastructure is located within or operationally linked to the Philippines. In limited circumstances, personal data may be transferred to or accessed by service providers operating in other jurisdictions — for example, cloud infrastructure providers or fraud detection platforms.

Where such transfers occur, 728pub ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Data Privacy Act of 2012, including through contractual clauses requiring recipient organizations to comply with applicable data protection standards.

728pub does not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate contractual or technical safeguards.

728pub reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or our data processing practices. Where changes are material, 728pub will provide reasonable prior notice to members through the Platform or by email to the address registered on the member's account.

The effective date at the top of this Policy will be updated each time a revised version is published. Your continued use of the 728pub platform following the publication of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the amended Policy, you should cease using the Platform and may request account closure in accordance with the 728pub Terms & Conditions.

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way 728pub handles your personal data, please contact the 728pub Data Protection Officer:

• Support Email: [email protected]
• Subject Line: Data Privacy Enquiry — [Your Full Name]
• Response Time: 728pub will acknowledge all privacy enquiries within twenty-four (24) hours and provide a substantive response within thirty (30) calendar days.
• Support Hours: 24 hours a day, 7 days a week, including Philippine public holidays

If you are not satisfied with 728pub's response to your privacy complaint, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official website.