Privacy Policy

1. Introduction

This Privacy Policy ("Policy") explains how 701 pub ("701 pub," "we," "us," "our"), the operator of the online gaming platform available at 701pub.app, collects, uses, stores, discloses, and otherwise processes personal information about individuals ("you," "your") who access or use our website, mobile platform, games, and related services (collectively, the "Platform").

701 pub is committed to protecting your privacy and handling your personal data with transparency, integrity, and in full compliance with the Republic Act No. 10173 — the Data Privacy Act of 2012 (DPA) — and its Implementing Rules and Regulations (IRR), as administered by the National Privacy Commission (NPC) of the Republic of the Philippines.

By registering an account, accessing, or otherwise using the 701 pub Platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform immediately.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, 701 pub is the personal information controller in respect of all personal data collected through the Platform. Our designated Data Privacy Officer (DPO) is responsible for overseeing compliance with this Policy and applicable data protection legislation.

You may contact our Data Privacy Officer at any time using the contact details provided in Section 14 of this Policy.

3. Information We Collect

3.1 Information You Provide Directly

When you register, verify your identity, contact support, or use certain features of the 701 pub Platform, you may provide the following categories of personal information:

• Identity data: Full legal name, date of birth, gender, nationality;
• Contact data: Philippine mobile number (in +63 format), email address, residential address;
• Identity verification documents: Government-issued Philippine ID (SSS, GSIS, UMID, PhilHealth card, driver's licence, passport), SELFIE photographs where required for KYC;
• Financial data: GCash account reference, Maya account reference, bank account details (BPI, BDO, Metrobank) where used for deposits or withdrawals — stored as tokenized references, never as raw account numbers;
• Account credentials: Username and hashed password (we never store plaintext passwords);
• Communications: Records of your live chat conversations, emails, and support tickets with 701 pub.

3.2 Information Collected Automatically

When you access the Platform, we automatically collect certain technical and usage data:

• IP address, device type, operating system, browser type and version;
• Geolocation data (city/region level, derived from IP address);
• Session data including login timestamps, session duration, pages visited, and navigation paths;
• Game activity: game titles played, wager amounts, outcomes, session times;
• Device identifiers used for fraud prevention and responsible gaming monitoring;
• Cookie and tracking technology data as described in Section 6.

3.3 Information from Third Parties

701 pub may receive personal information about you from third-party sources, including:

• Payment processors (GCash, Maya) confirming transaction completion — limited to transaction reference numbers and amounts;
• Identity verification service providers used for KYC and AML compliance;
• Fraud prevention and risk management service providers;
• Publicly available sources for AML/CTF due diligence, including sanction screening databases.

4. How We Use Your Personal Data

701 pub uses your personal data for the following purposes:

701 pub does not use your personal data for automated decision-making processes that produce legal or similarly significant effects on you without human review.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 701 pub processes your personal data on one or more of the following lawful bases:

• Consent: Where you have given clear, informed, and specific consent to processing for a defined purpose (e.g., receiving promotional communications);
• Contractual necessity: Processing is necessary to perform the contract with you (i.e., the Terms & Conditions governing your use of the Platform);
• Legal obligation: Processing is required to comply with Philippine law, including AML regulations, KYC requirements under PAGCOR, and data reporting obligations under the DPA;
• Legitimate interests: Processing is necessary for 701 pub's legitimate interests (e.g., fraud prevention, platform security, responsible gaming monitoring), where these are not overridden by your privacy rights.

6. Cookies and Tracking Technologies

701 pub uses cookies and similar tracking technologies (such as web beacons and local storage) on the Platform. Cookies are small data files placed on your device that help the Platform function correctly and enable us to improve your experience.

Categories of Cookies Used

• Strictly necessary cookies: Essential for the Platform to operate — session management, authentication tokens, security controls. These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language, display settings) to personalize your experience.
• Analytics cookies: Collect aggregated, anonymized data about how players navigate the Platform, helping us identify areas for improvement.
• Security and fraud prevention cookies: Help identify and prevent fraudulent activity and unauthorized access to accounts.

You may control non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of some Platform features. 701 pub does not use third-party advertising or behavioral tracking cookies.

7. Sharing Your Personal Data

701 pub does not sell your personal data. We may share your personal information with the following categories of recipients only to the extent necessary and subject to appropriate data protection obligations:

• Payment processors: GCash (GXI), Maya (Voyager Innovations), BancNet, and other licensed Philippine payment service providers, for processing deposits and withdrawals;
• KYC and identity verification providers: Third-party identity verification services engaged to assist with document verification and biometric checks;
• Game software providers: Where game providers operate their own servers to deliver live dealer content, limited session data necessary for game delivery may be shared;
• Fraud prevention and security providers: Third-party fraud detection platforms that help protect the Platform and its players;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government agencies, where disclosure is required by law;
• Professional advisers: Legal counsel, auditors, and accountants, bound by confidentiality obligations, where required for legal compliance or dispute resolution.

8. International Data Transfers

Some of the third-party service providers engaged by 701 pub — particularly certain game software providers and cloud infrastructure services — may process personal data outside the Republic of the Philippines. Where such transfers occur, 701 pub ensures that appropriate safeguards are in place, including contractual clauses that impose data protection obligations equivalent to those required under the Data Privacy Act of 2012 and consistent with NPC guidance on cross-border data transfers.

By using the 701 pub Platform, you acknowledge that your personal data may be processed in countries outside the Philippines. 701 pub will only transfer your data internationally where a lawful basis and adequate protections exist.

9. Data Retention

701 pub retains personal data for the following periods, after which data is securely deleted or anonymized:

• Account and identity data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, as required by Philippine AML law;
• Financial transaction records: Retained for a minimum of five (5) years in compliance with the Anti-Money Laundering Act and PAGCOR regulations;
• Game activity logs: Retained for three (3) years for dispute resolution and responsible gaming monitoring purposes;
• Customer support communications: Retained for two (2) years from the date of the interaction;
• Device and session logs: Retained for ninety (90) days for security and fraud prevention purposes.

Where a legal obligation, active dispute, or regulatory investigation requires extended retention, data will be retained for as long as necessary to resolve the matter.

10. Security Measures

701 pub implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:

• TLS 1.3 encryption for all data in transit between your device and 701 pub servers;
• AES-256 encryption for sensitive data at rest;
• One-way cryptographic hashing (bcrypt) for all stored passwords — 701 pub staff cannot read your password;
• Tokenized payment processing — raw GCash, Maya, or bank account details are never stored on 701 pub servers;
• Role-based access controls limiting internal staff access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing;
• SMS-based two-factor authentication available to all players.

While we implement industry-standard security measures, no transmission over the internet is 100% secure. Players are responsible for maintaining the security of their own devices and login credentials.

11. Your Rights Under the Data Privacy Act

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 701 pub:

• Right to be informed: You have the right to know how your personal data is being collected and processed;
• Right of access: You have the right to request a copy of the personal data 701 pub holds about you;
• Right to correction: You have the right to request correction of inaccurate or incomplete personal data;
• Right to erasure or blocking: You have the right to request deletion or blocking of personal data that is unlawfully processed or no longer necessary for the original purpose, subject to 701 pub's legal retention obligations;
• Right to object: You have the right to object to the processing of your personal data for certain purposes, including direct marketing;
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to damages: You have the right to be indemnified for damages sustained as a result of inaccurate, incomplete, outdated, false, or unlawfully obtained personal data;
• Right to file a complaint: You have the right to lodge a complaint with the National Privacy Commission if you believe your data rights have been violated.

To exercise any of these rights, contact 701 pub's Data Privacy Officer using the details in Section 14. We will respond to verified requests within fifteen (15) business days.

12. Children's Privacy

The 701 pub Platform is strictly intended for individuals aged 21 years and above. 701 pub does not knowingly collect personal data from persons under 21 years of age. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that information and close the associated account. If you believe a minor has registered on the Platform, please notify us immediately at the contact address in Section 14.

13. Changes to This Privacy Policy

701 pub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform functionality. Material changes will be communicated to registered players via the email address associated with their account and/or through a prominent notice on the Platform at least fourteen (14) days prior to the effective date of the changes, unless a shorter notice period is required by law.

The "Last updated" date at the top of this page reflects the most recent revision. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the updated Policy.

14. Contact and Data Privacy Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 701 pub, please contact our Data Privacy Officer:

Data Privacy Officer — 701 pub

Email: [email protected]

Subject line: Data Privacy Request

Response time: Within 15 business days of receiving a verified request.

If you are not satisfied with 701 pub's response to your privacy concern, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines.