Privacy Policy
of 720pub

1.1 This Privacy Policy ("Policy") describes how 720pub ("we," "us," "our") collects, uses, stores, discloses, and protects the personal data of individuals ("you," "Member," "user") who access or use the 720pub online gaming platform available at 720pub.club ("Platform") and all associated services ("Services").

1.2 This Policy applies to all personal data processed by 720pub in connection with the Services, regardless of whether that data is collected through the Platform website, mobile browser interface, customer support communications, or payment processing channels.

1.3 This Policy does not apply to third-party websites, applications, or services that may be linked to or from the Platform. 720pub is not responsible for the privacy practices of any third party, and we encourage Members to review the privacy policies of any external service they interact with.

1.4 This Policy should be read alongside the Terms & Conditions and the Responsible Gaming Policy of 720pub, which together govern your use of the Platform.

2.1 For the purposes of the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, 720pub acts as the personal information controller in respect of the personal data it processes in connection with the Platform and Services.

2.2 720pub has appointed a Data Protection Officer (DPO) to oversee compliance with this Policy and applicable data protection legislation. Contact details for the DPO are set out in Section 16 of this Policy.

2.3 Where 720pub engages third-party service providers to process personal data on its behalf, such providers act as personal information processors under binding data processing agreements that require them to process data only on 720pub's documented instructions and to implement appropriate security measures.

720pub collects the following categories of personal data from Members and prospective Members:

3.2 720pub does not collect sensitive personal information as defined under R.A. 10173 — including racial or ethnic origin, political opinions, religious beliefs, health data, or genetic data — unless specifically required for compliance purposes and only to the minimum extent necessary.

720pub collects personal data through the following channels:

Data you provide directly when you register a 720pub Account, complete the KYC verification process, make a deposit or withdrawal request, contact our support team, or respond to a survey or promotion.

Technical and usage data collected automatically when you access the 720pub Platform, including through cookies, web beacons, device fingerprinting, and server logs. See Section 11 for detailed information on cookies and tracking technologies.

720pub may receive personal data from third parties in limited circumstances, including:

• Identity verification and KYC partners who cross-reference the documents you submit against official Philippine databases;
• Payment processors (GCash, Maya, BPI, BDO, Metrobank) confirming transaction completion or flagging suspicious activity;
• Fraud prevention and anti-money laundering (AML) screening services against watch-list databases required for AMLA compliance.

720pub processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform the contract between you and 720pub, including account management, payment processing, game delivery, and customer support;
• Legal Obligation: Processing necessary to comply with applicable law, including anti-money laundering obligations under the AMLA, age verification requirements under PAGCOR regulations, and data retention requirements under Philippine law;
• Legitimate Interests: Processing carried out for 720pub's legitimate business interests where those interests are not overridden by your data protection rights, including fraud detection, platform security, and product improvement;
• Consent: Processing based on your freely given, specific, and informed consent, primarily for the delivery of marketing communications and the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

720pub uses the personal data it collects for the following purposes:

• Account Registration & Management: Creating and maintaining your 720pub Member account, verifying your identity, managing your Wallet balance, and processing your login credentials;
• Payment Processing: Facilitating deposits and withdrawals via GCash, Maya, InstaPay, BPI, BDO, Metrobank, GrabPay, and card networks, and maintaining transaction records as required by AMLA;
• Identity Verification (KYC): Confirming that you are at least 21 years of age and are who you claim to be, as required by PAGCOR guidelines and 720pub's anti-fraud policies;
• Fraud Prevention & Security: Detecting, investigating, and preventing fraudulent activity, money laundering, collusion, multi-accounting, and other prohibited conduct on the 720pub Platform;
• Responsible Gaming: Monitoring your gaming activity to identify potential problem gambling patterns and enabling you to use deposit limits, cooling-off periods, and self-exclusion tools;
• Customer Support: Responding to your queries, resolving disputes, and providing technical assistance through live chat and email channels;
• Platform Improvement: Analyzing usage patterns and technical data to fix bugs, improve performance, and develop new features that better serve Filipino players;
• Legal & Regulatory Compliance: Fulfilling record-keeping and reporting obligations under Philippine law, including submission of suspicious transaction reports to the AMLC where required;
• Marketing Communications (consent-based): Sending you promotional offers, bonus notifications, and platform updates via SMS or email, exclusively where you have given explicit consent and until you withdraw it.

7.1 720pub does not sell, rent, or trade your personal data to unaffiliated third parties for their own commercial purposes. Data is shared only in the circumstances described below.

720pub shares personal data with the following categories of third-party service providers who process it exclusively on our behalf and under binding data processing agreements:

• Payment processing partners (GCash/Maya settlement services, BancNet, card payment gateways);
• KYC and identity verification providers;
• Fraud detection and AML screening services;
• Cloud hosting and infrastructure providers;
• Customer support platform providers;
• Email and SMS communication delivery services.

720pub may disclose personal data to government authorities, law enforcement agencies, the Anti-Money Laundering Council (AMLC), or PAGCOR when required to do so by applicable Philippine law, court order, or legitimate regulatory request. We will, where legally permissible, notify affected Members of such disclosure.

In the event of a merger, acquisition, restructuring, or sale of all or part of 720pub's business, personal data held by 720pub may be transferred to the acquiring entity as part of that transaction, subject to equivalent privacy protections being in place.

720pub may share aggregated, anonymized data — from which no individual Member can be identified — with business partners, analytics providers, or for research purposes. This does not constitute disclosure of personal data.

8.1 720pub's primary operations serve the Philippine market, and the majority of data processing occurs within systems hosted in data centers in or accessible from the Philippines and the broader Asia-Pacific region.

8.2 Where personal data is transferred to a jurisdiction outside the Philippines — for example, to a cloud infrastructure provider or a third-party software service with servers in another country — 720pub ensures that such transfers are protected by appropriate safeguards, including:

• Contractual clauses requiring the recipient to maintain data protection standards equivalent to those required under R.A. 10173;
• Transfer to countries recognized by the National Privacy Commission (NPC) as providing an adequate level of data protection;
• Binding corporate rules where applicable within a corporate group.

9.1 720pub retains personal data for as long as is necessary to fulfil the purpose for which it was collected and to comply with our legal and regulatory obligations. The following retention periods apply as a general guide:

9.2 When data reaches the end of its retention period, 720pub will securely delete or anonymize it. Anonymized data, from which no individual can be identified, may be retained indefinitely for statistical and research purposes.

10.1 720pub implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure:

• Encryption in Transit: All data transmitted between your browser or device and the 720pub Platform is encrypted using TLS 1.2 or higher (256-bit SSL);
• Encryption at Rest: Sensitive personal data, including payment references and identity documents, is stored in encrypted form on 720pub's servers;
• Access Controls: Access to personal data within 720pub is restricted on a strict need-to-know basis using role-based access controls. Staff with access to Member data are subject to confidentiality obligations;
• Two-Factor Authentication: Administrative access to systems containing personal data requires multi-factor authentication. Members are also offered 2FA for their own Account security;
• Security Audits: 720pub conducts regular internal security reviews and engages third-party penetration testing services on a periodic basis;
• Incident Response: 720pub maintains a data breach response plan. In the event of a breach that poses a risk to Members' rights, we will notify affected Members and the National Privacy Commission in accordance with applicable law.

11.1 720pub uses cookies and similar technologies (such as web beacons and local storage) on the Platform to enable essential functionality, improve user experience, and — where you have given consent — deliver relevant marketing.

11.2 The following categories of cookies are used on the 720pub Platform:

• Strictly Necessary Cookies: Required for the Platform to function. These include session cookies that keep you logged in during a browsing session and security tokens that protect against CSRF attacks. These cookies cannot be disabled.
• Functional Cookies: Store your preferences (language, display settings, "remember me" login status) to improve your experience on subsequent visits.
• Analytics Cookies: Collect anonymized information about how Members interact with the Platform, including which pages are visited most and where errors occur. This helps 720pub improve the Platform.
• Marketing Cookies: Used to understand which promotional campaigns are most effective. These cookies are only activated where you have given explicit consent via our cookie consent prompt.

11.3 You can manage your cookie preferences at any time through your browser settings. Disabling cookies may affect the functionality of certain features on the 720pub Platform. Essential session cookies are required for account access and cannot be disabled without logging out.

12.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 720pub. To exercise any of these rights, please contact the 720pub Data Protection Officer at the details provided in Section 16.

12.2 720pub will respond to verified data rights requests within thirty (30) calendar days of receipt. Where a request is complex or numerous, we may extend this period by a further thirty (30) days, notifying you of the extension within the initial response window.

12.3 If you are not satisfied with 720pub's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for data protection in the Philippines.

13.1 The 720pub Platform is strictly for individuals aged 21 years and older, in accordance with PAGCOR's minimum gambling age requirements for the Philippines.

13.2 720pub does not knowingly collect personal data from persons under the age of 21. If we become aware that personal data has been collected from a person under 21, we will immediately close the Account, delete the associated data to the extent permitted by law (retaining only the minimum required for AMLA reporting), and return any remaining real-money balance to the depositing payment source.

13.3 If you believe that 720pub has inadvertently collected personal data from a person under the age of 21, please notify us immediately at the contact address provided in Section 16 so that we can take prompt corrective action.

14.1 The 720pub Platform may contain references to third-party payment providers (such as GCash and Maya). When you initiate a transaction through these payment channels, you are interacting with their respective platforms, which are governed by their own privacy policies.

14.2 720pub is not responsible for the data protection practices of third-party payment providers, game content providers, or any other external service referenced in connection with the Platform. We encourage you to review the privacy policies of any third party whose services you use in connection with your 720pub Account.

15.1 720pub reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The "Last Updated" date displayed at the top of this page will be revised accordingly.

15.2 Where changes are material — meaning they significantly affect how your personal data is processed or your rights as a data subject — 720pub will notify registered Members by email to their registered address and/or by a prominent notice on the Platform at least seven (7) days before the changes take effect.

15.3 Your continued use of the 720pub Platform following the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree with a material change, you may close your Account in accordance with the procedures in the Terms & Conditions.

16.1 If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a concern about how 720pub handles your personal data, please contact our Data Protection Officer (DPO) using the details below.

16.2 For general account support — questions about your deposit history, game balance, or login access — please use the live chat available within your 720pub Account dashboard, which is staffed 24 hours a day, 7 days a week.

16.3 For complaints that remain unresolved after contact with the 720pub DPO, you have the right to escalate to the National Privacy Commission (NPC) of the Philippines, the authority responsible for enforcing R.A. 10173.