pub 504 Privacy Policy

1. About This Policy

This Privacy Policy ("Policy") describes how pub 504 ("we", "us", "the Platform", "pub 504") collects, uses, stores, shares, and protects the personal information of individuals ("you", "data subject", "member") who access or use the pub 504 website, mobile interface, and related gaming services.

This Policy applies to all personal data collected from you in the course of your relationship with pub 504 — from initial site visit and registration through identity verification, gaming activity, financial transactions, customer support interactions, and up to and including account closure. It applies to all channels through which pub 504 may collect your data, including the platform website, support email, live chat, and marketing communications where applicable.

This Policy should be read alongside the pub 504 Terms & Conditions and Responsible Gaming policy, both of which form part of your contractual relationship with pub 504.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, pub 504 is the Personal Information Controller (PIC) in respect of the personal data it collects and processes. pub 504 is responsible for ensuring that personal data is processed in accordance with RA 10173 and all applicable National Privacy Commission guidelines.

pub 504 operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). Data processed for PAGCOR reporting and regulatory compliance purposes is processed under a legal obligation basis as described in Section 5 of this Policy.

If you have questions about how pub 504 handles your personal data, you may contact our designated Data Protection Officer (DPO) using the contact details set out in Section 16 of this Policy.

3. Data We Collect

pub 504 collects the following categories of personal data from and about you:

4. How We Collect Your Data

pub 504 collects your personal data through the following means:

4.1 Direct Collection

You provide data directly when you register an account, complete KYC verification, make deposits or withdrawals, contact support via live chat or email, respond to surveys or promotions, or update your account profile.

4.2 Automated Collection

When you access the pub 504 platform, we automatically collect certain technical and usage data through cookies, session logs, and server-side analytics. This includes your IP address, device identifiers, browser type, referring URL, pages visited within pub 504, and session duration. See Section 8 for more detail on cookies.

4.3 Third-Party Sources

In limited circumstances, pub 504 may receive data about you from third parties, including:

• Payment providers (GCash, PayMaya, BPI, BDO, Metrobank) who confirm transaction status and the registered name on a payment account.
• Identity verification service providers who assist in cross-referencing your submitted identification documents against authoritative databases for KYC purposes.
• Fraud prevention and AML screening services that check submitted details against sanctions lists, politically exposed person (PEP) databases, and adverse media sources as required under Philippine AMLA obligations.

5. Legal Basis for Processing

pub 504 processes your personal data under one or more of the following legal bases as recognised under RA 10173:

• Contractual Necessity: Processing is required to perform our contract with you — including operating your account, processing bets, and executing withdrawals. Without this processing, pub 504 cannot provide the services you have requested.
• Legal Obligation: Processing is required to comply with applicable Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act (RA 10173), and PAGCOR's responsible gaming framework.
• Legitimate Interests: Processing is necessary for pub 504's legitimate interests, including platform security, fraud detection, responsible gaming monitoring, and business analytics, provided these interests do not override your fundamental rights.
• Consent: Where required by law and where no other basis applies, pub 504 will request your explicit consent before processing your personal data for a specific purpose. You may withdraw consent at any time by contacting the Data Protection Officer, without affecting the lawfulness of processing carried out prior to withdrawal.

6. How We Use Your Personal Data

pub 504 uses the personal data it collects for the following purposes:

• To create, manage, and operate your pub 504 account, including authentication and account security.
• To verify your identity and age in compliance with PAGCOR's KYC requirements and the 21+ age restriction applicable under Philippine gaming law.
• To process your deposits, wagers, and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other accepted payment methods.
• To operate all gaming services available on pub 504, including live casino, slots, sports betting, sabong, bingo, and card games.
• To comply with AML obligations — including transaction monitoring, suspicious transaction reporting to the AMLC, and customer due diligence as required under RA 9160.
• To provide customer support, investigate disputes, and resolve complaints related to your pub 504 account or gameplay experience.
• To monitor gaming activity for responsible gaming purposes, including detecting patterns that may indicate problem gambling behaviour and triggering responsible gaming interventions as required by PAGCOR.
• To detect, prevent, and investigate fraud, identity theft, bonus abuse, collusion, match-fixing, and other prohibited activities as defined in the pub 504 Terms & Conditions.
• To manage the pub 504 VIP loyalty programme, calculate tier eligibility, and administer tier-related benefits.
• To send transactional and account communications — including deposit confirmations, withdrawal notifications, and security alerts — via SMS, email, or in-platform notification.
• To improve the platform, personalise your experience, and conduct internal analytics and business reporting.
• To comply with reporting obligations to PAGCOR and other competent Philippine regulatory or law enforcement authorities.

7. Data Sharing & Disclosure

pub 504 does not sell your personal data to third parties. We share personal data only where necessary and under controlled conditions, with the following categories of recipients:

7.1 Service Providers & Processors

pub 504 engages certified third-party service providers who process personal data on our behalf under written data processing agreements. These include payment processors (GCash, PayMaya, bank transfer partners), identity verification providers, live casino streaming providers, game studios, cloud hosting providers, and customer support infrastructure providers. These parties are permitted to use your data only to provide services to pub 504 and are contractually bound to maintain data security standards consistent with RA 10173.

7.2 Regulatory & Law Enforcement Authorities

pub 504 will disclose personal data to competent Philippine authorities — including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies — where required by law, court order, or regulatory instruction. Such disclosures are made in strict accordance with applicable Philippine legal requirements.

7.3 Business Transfers

In the event of a merger, acquisition, sale of assets, or corporate restructuring involving pub 504, personal data may be transferred to the acquiring entity. You will be notified of any such transfer and the identity of the new data controller, and your rights under RA 10173 will be preserved.

8. Cookies & Tracking Technologies

pub 504 uses cookies and similar tracking technologies to operate the platform, maintain session continuity, support security features, and analyse platform performance. The following categories of cookies are used:

8.1 Strictly Necessary Cookies

These cookies are essential for the pub 504 platform to function. They maintain your login session, store your language and display preferences, and enable core security features such as CSRF protection. These cookies cannot be disabled without affecting your ability to use the platform. No opt-out is available for this category.

8.2 Analytical Cookies

pub 504 uses server-side analytics to understand aggregate platform usage patterns — including which game categories are most accessed, peak usage times, and common support inquiry types. These analytics are processed on pub 504 infrastructure and do not involve sharing your individual usage data with third-party analytics platforms.

8.3 Security Cookies

Certain cookies are used to support fraud detection and account security, including device fingerprinting elements that help pub 504 identify unusual login patterns or suspicious account access attempts. These cookies are essential and cannot be opted out of.

pub 504 does not use third-party advertising or behavioural tracking cookies. By continuing to use the pub 504 platform, you consent to the use of strictly necessary and security cookies as described above.

9. Data Retention

pub 504 retains personal data for the duration necessary to fulfil the purpose for which it was collected, as required by applicable law, or as necessary to defend legal claims. The following retention guidelines apply:

Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised such that it can no longer be attributed to any identifiable individual.

10. Data Security

pub 504 implements a comprehensive information security programme designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security measures include:

• Encryption in Transit: All data transmitted between your device and the pub 504 platform is encrypted using TLS 1.2 or higher (HTTPS). Sensitive data fields — including passwords — are never transmitted in plaintext.
• Encryption at Rest: Personal data and sensitive account information stored in pub 504 databases is encrypted at rest using AES-256 encryption or equivalent.
• Access Controls: Access to personal data within pub 504 is restricted on a need-to-know basis. Staff access is role-based, logged, and subject to regular access reviews. All staff with access to personal data are bound by confidentiality obligations.
• Password Security: Account passwords are stored as irreversible hashed values using bcrypt or equivalent. pub 504 cannot retrieve your password — only reset it through a secure verification process.
• Infrastructure Security: The pub 504 platform operates on cloud infrastructure that maintains ISO 27001 or equivalent security certifications. Regular penetration testing and vulnerability assessments are conducted.
• Incident Response: pub 504 maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights, pub 504 will notify the NPC within 72 hours of becoming aware of the breach, and will notify affected data subjects without undue delay as required under RA 10173.

11. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pub 504. You may exercise any of these rights by contacting the pub 504 Data Protection Officer using the details in Section 16.

pub 504 will respond to all data subject requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, in which case you will be notified of the extension and the reason for it. pub 504 may require you to verify your identity before processing a data subject request to ensure that personal data is not disclosed to an unauthorised party.

12. Minors & Age Restrictions

The pub 504 platform is strictly restricted to persons who are at least twenty-one (21) years of age, as required under PAGCOR licensing conditions and applicable Philippine gaming law. pub 504 does not knowingly collect personal data from persons under the age of 21.

All registration submissions are subject to age verification as part of the KYC process. If pub 504 discovers or has reason to believe that a registered account is held by a person under 21 years of age, the account will be immediately suspended, all balances and bonuses will be voided, and the matter will be escalated to PAGCOR in accordance with our regulatory obligations.

If you are a parent or guardian and believe that your child has created an account on pub 504, please contact our Data Protection Officer immediately. We will investigate and close the account, and delete any personal data collected from the minor, as swiftly as possible consistent with our regulatory obligations.

13. International Data Transfers

pub 504 primarily processes and stores personal data within the Republic of the Philippines. In certain circumstances, personal data may be transmitted to or processed by service providers located outside the Philippines — for example, game studio servers hosted in other Asian jurisdictions, or cloud infrastructure providers with regional data centres.

Where personal data is transferred outside the Philippines, pub 504 ensures that an appropriate level of protection is maintained through one or more of the following safeguards:

• Contractual clauses requiring the overseas recipient to apply data protection standards equivalent to those required under RA 10173.
• Use of service providers operating under internationally recognised security certifications (ISO 27001, SOC 2) that provide equivalent protection.
• Transfer to jurisdictions that the NPC has determined to provide an adequate level of data protection.

You may request information about the specific international transfers applicable to your data and the safeguards in place by contacting the Data Protection Officer.

14. Third-Party Links

The pub 504 platform may contain links to third-party websites or services — for example, links to PAGCOR's official responsible gaming resources or payment provider portals. These third-party sites operate independently of pub 504 and maintain their own privacy policies. pub 504 is not responsible for the privacy practices or content of third-party websites.

When you leave the pub 504 platform by following an external link, you are subject to the privacy policy of the destination site. We encourage you to review the privacy policies of any third-party sites you visit.

15. Policy Updates

pub 504 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, NPC guidance, regulatory requirements, or our data processing practices. When material changes are made, we will notify registered members via email or prominent in-platform notification prior to the effective date of the revised policy.

The "Last Updated" date at the top of this Policy reflects the most recent revision. We encourage you to review this Policy periodically to stay informed about how pub 504 handles your personal data. Your continued use of the platform following the effective date of a revised policy constitutes your acceptance of the changes.

If you do not agree with the revised Policy, you must cease using the pub 504 platform and contact support to request account closure. Any personal data collected prior to the policy change will continue to be handled in accordance with the policy in effect at the time of collection, except where a legal basis requires otherwise.

16. Contact & Complaints

If you wish to exercise any of your data subject rights, raise a privacy concern, or file a formal complaint regarding pub 504's handling of your personal data, please contact our Data Protection Officer through the following channels:

If your concern relates to a potential data breach or urgent security matter, please mark your communication "URGENT – DATA SECURITY" to ensure it is escalated to the appropriate team without delay.

If you are not satisfied with pub 504's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information on how to file an NPC complaint is available on the NPC's official website.