Privacy Policy

1. Introduction

Welcome to the 855pub Privacy Policy. This document governs the collection, processing, storage, and protection of personal information provided by users (hereinafter "you," "your," or "User") to 855pub (hereinafter "we," "us," "our," or "the Company") through the website https://855pub.cam and associated mobile applications (collectively, "the Platform").

855pub is an online gaming platform licensed and regulated by the Philippine Amusement and Gaming Corporation (PAGCOR). We operate in full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all circulars issued by the National Privacy Commission of the Philippines. Additionally, we adhere to PAGCOR's data protection guidelines and international best practices in online gaming privacy standards.

By creating an account, accessing our Platform, or using any of our services, you expressly acknowledge that you have read, understood, and consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with any provision of this Privacy Policy, you must immediately discontinue use of the Platform and refrain from providing any personal information to 855pub.

2. Information We Collect

855pub collects various categories of personal information to provide gaming services, comply with regulatory obligations, prevent fraud, and enhance user experience. The types of information we collect include:

2.1 Information You Provide Directly

• Registration Information: When you create an account on 855pub, we collect personal details including your full legal name, date of birth, residential address, email address, mobile phone number, and chosen username and password. This information is required to establish your account and verify your identity in compliance with PAGCOR regulations.
• Verification Documents: To comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) requirements, we collect copies of government-issued identification documents such as Philippine passports, driver's licenses, national IDs, proof of address documents (utility bills, bank statements, or government correspondence), and proof of payment method ownership. These documents are used solely for identity verification and regulatory compliance.
• Financial Information: When you deposit or withdraw funds, we collect payment method details including bank account information, e-wallet account details (GCash, PayMaya), cryptocurrency wallet addresses, and transaction histories. We do not store complete credit card numbers or sensitive authentication data; such information is processed securely by our licensed payment service providers.
• Communication Records: We retain records of all communications between you and our customer support team, including live chat transcripts, email correspondence, and phone call recordings (where permitted by law and with prior notice). These records help us improve service quality, resolve disputes, and maintain regulatory compliance.
• Marketing Preferences: We collect information about your communication preferences, including whether you wish to receive promotional emails, SMS messages, or push notifications regarding bonuses, tournaments, and new game releases.

2.2 Information Collected Automatically

• Device Information: When you access 855pub, we automatically collect technical information about your device including IP address, device type and model, operating system and version, browser type and version, screen resolution, device identifiers (IMEI, UDID, advertising ID), and mobile network information.
• Usage Data: We collect detailed information about how you interact with the Platform, including pages visited, games played, bet amounts and frequencies, session duration, navigation patterns, click-through rates, time spent on specific pages, features used, and errors encountered. This data helps us understand user behavior, optimize platform performance, and detect unusual activity patterns that may indicate fraud or problem gambling.
• Location Data: We collect geolocation information through IP address analysis and, with your explicit permission, GPS data from mobile devices. Location information helps us comply with jurisdictional gambling regulations, prevent unauthorized access from restricted territories, and provide localized content and promotions.
• Cookies and Similar Technologies: 855pub uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance user experience, maintain session persistence, analyze platform performance, and deliver targeted advertising. Detailed information about our cookie practices is provided in Section 6 of this Privacy Policy.

2.3 Information from Third-Party Sources

We may receive additional information about you from third-party sources including credit reference agencies for payment verification, fraud prevention services that screen accounts against databases of known fraudsters, identity verification providers that authenticate government documents, payment processors that confirm transaction details, and advertising partners that provide demographic and interest information. This third-party data is combined with information we collect directly to create a more comprehensive understanding of our users and ensure platform security.

3. How We Use Your Data

855pub processes your personal information for specific, legitimate purposes that are essential to our gaming operations, regulatory compliance, and service improvement. We use your data for the following purposes:

3.1 Account Management and Service Delivery

We use your personal information to create and maintain your gaming account, authenticate your identity during login, process deposits and withdrawals, credit winnings to your account, manage account balances, facilitate participation in games and tournaments, provide customer support, and communicate important account-related information such as transaction confirmations, security alerts, and policy updates.

3.2 Regulatory Compliance and Legal Obligations

As a PAGCOR-licensed operator, 855pub is subject to extensive regulatory requirements. We use your data to verify your age and ensure you meet the minimum gambling age requirement of 21 years, conduct Know Your Customer (KYC) and Anti-Money Laundering (AML) checks, detect and prevent fraudulent activities, respond to lawful requests from government authorities and regulatory bodies, comply with court orders and legal process, maintain required records for regulatory audits, and report suspicious transactions as mandated by law.

3.3 Fraud Prevention and Platform Security

We analyze user behavior patterns, transaction histories, and device information to detect potentially fraudulent activities, identify multiple accounts created by the same individual, prevent unauthorized account access, block users from restricted jurisdictions, monitor for collusion between players, identify betting patterns indicative of bonus abuse or advantage play, and protect the integrity of our gaming operations. Advanced analytics and machine learning algorithms assist in real-time fraud detection without manual review of every transaction.

3.4 Responsible Gaming and Player Protection

855pub is committed to promoting responsible gaming practices. We use your data to monitor betting patterns that may indicate problem gambling behavior, enforce deposit limits, loss limits, and session time restrictions you have set, facilitate self-exclusion requests, provide access to responsible gaming tools and resources, and, where appropriate, intervene when we identify concerning gambling patterns by contacting affected users and offering support resources.

3.5 Marketing and Personalization

With your consent, we use your information to send promotional communications about bonuses, free spins, cashback offers, and tournament invitations, personalize your gaming experience by recommending games based on your preferences, deliver targeted advertising through our Platform and third-party networks, conduct market research and surveys to understand user preferences, and analyze the effectiveness of marketing campaigns. You can opt out of marketing communications at any time through your account settings or by clicking unsubscribe links in emails.

3.6 Platform Improvement and Analytics

We analyze aggregated and anonymized data to improve Platform performance and user experience, optimize game selection and placement, identify and fix technical issues, develop new features and services, conduct A/B testing of interface elements, understand demographic trends among our user base, and make data-driven business decisions. This analytics processing typically uses de-identified or aggregated data that cannot be traced back to individual users.

4. Data Sharing and Disclosure

855pub does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your data with trusted third parties under specific circumstances and with appropriate safeguards:

4.1 Service Providers and Business Partners

We share necessary personal information with third-party service providers who assist in operating the Platform, including payment processors (banks, e-wallet providers, cryptocurrency payment gateways), game developers and software providers who power our casino games and live dealer studios, cloud hosting providers who store our databases and applications, customer support platforms that manage our live chat and ticketing systems, identity verification services that authenticate your documents, fraud prevention and cybersecurity firms, marketing and analytics partners, and email and SMS communication platforms. All service providers are contractually obligated to protect your data, use it only for specified purposes, and comply with applicable data protection laws.

4.2 Regulatory Authorities and Law Enforcement

We disclose personal information to regulatory bodies when required by law, including PAGCOR for license compliance audits, the National Privacy Commission of the Philippines in response to lawful requests, the Anti-Money Laundering Council (AMLC) for suspicious transaction reporting, law enforcement agencies investigating criminal activities, tax authorities for tax compliance verification, and courts in response to subpoenas or court orders. We disclose only the minimum information necessary to fulfill legal obligations.

4.3 Corporate Transactions

In the event of a merger, acquisition, corporate reorganization, sale of assets, or bankruptcy, your personal information may be transferred to the acquiring or successor entity. We will notify you via email and prominent notice on the Platform before your information is transferred and becomes subject to a different privacy policy. You will have the opportunity to request account closure and data deletion before such transfer occurs.

4.4 Consent-Based Sharing

We may share your information with other third parties when you provide explicit consent for specific purposes, such as participating in third-party promotions, linking your account to social media platforms, or opting into partner offers. Such sharing is always optional and clearly disclosed at the point of consent.

5. Data Security Measures

855pub employs industry-leading security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our comprehensive security framework includes:

5.1 Technical Security Controls

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS encryption protocols. Sensitive data stored in our databases is encrypted at rest using AES-256 encryption standards.
• Access Controls: We implement strict role-based access control (RBAC) systems that limit employee access to personal data based on job responsibilities. Multi-factor authentication is required for all administrative access to sensitive systems.
• Network Security: Our infrastructure is protected by enterprise-grade firewalls, intrusion detection and prevention systems (IDS/IPS), DDoS mitigation services, and regular vulnerability scanning. All systems are patched and updated according to industry best practices.
• Secure Development: Our software development lifecycle incorporates security-by-design principles, including secure coding standards, regular security code reviews, penetration testing, and third-party security audits conducted by independent cybersecurity firms.

5.2 Organizational Security Measures

All 855pub employees and contractors with access to personal data undergo background checks and sign confidentiality agreements. Regular security awareness training ensures staff understand their data protection responsibilities. We maintain incident response procedures to quickly identify, contain, and remediate security breaches, with mandatory breach notification procedures in compliance with Philippine law.

5.3 Data Security Limitations

While we implement robust security measures, no system is completely impenetrable. You share responsibility for account security by choosing strong passwords, not sharing login credentials, logging out after gaming sessions on shared devices, keeping your devices and software updated, being vigilant against phishing attempts, and immediately reporting suspected unauthorized access to our support team.

6. Cookies and Tracking Technologies

855pub uses cookies, web beacons, pixel tags, and similar technologies to enhance platform functionality, personalize user experience, and analyze traffic patterns. Understanding how these technologies work helps you make informed decisions about your privacy preferences.

6.1 Types of Cookies We Use

• Essential Cookies: These cookies are necessary for basic platform functionality including maintaining your login session, remembering your language preference, enabling secure transactions, and routing traffic for load balancing. Essential cookies cannot be disabled as they are critical to platform operation.
• Performance and Analytics Cookies: We use analytics cookies to understand how users interact with the Platform, which pages are most visited, where users encounter errors, average session duration, and conversion rates. This helps us optimize user experience and identify technical issues. We use both first-party analytics and third-party services like Google Analytics.
• Functionality Cookies: These cookies remember your preferences and choices such as favorite games, bet amounts, display settings, and notification preferences, providing a more personalized experience across sessions.
• Advertising Cookies: With your consent, we use advertising cookies to deliver targeted promotional content, limit the frequency of ad displays, measure campaign effectiveness, and enable retargeting campaigns on third-party platforms. You can opt out of personalized advertising through your account settings.

6.2 Managing Cookie Preferences

Most web browsers automatically accept cookies by default, but you can modify browser settings to decline cookies or receive notifications when cookies are being sent. Note that disabling cookies may impair certain platform features and prevent you from accessing all functionality. You can manage cookie preferences through your browser settings, our cookie consent tool displayed on your first visit, and opt-out mechanisms provided by third-party advertising networks.

7. Data Retention

855pub retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal and regulatory obligations, resolve disputes, enforce agreements, and protect our legitimate business interests.

7.1 Retention Periods

Active account information is retained throughout the duration of your account relationship with 855pub. Following account closure, we retain certain information for regulatory compliance periods mandated by PAGCOR and Philippine law, typically five (5) years from the date of the last transaction. Financial transaction records, including deposits, withdrawals, and gaming histories, are retained for seven (7) years to comply with anti-money laundering regulations and tax laws. Identity verification documents are securely archived for the duration required by KYC regulations. Marketing communications records are retained until you withdraw consent or for two (2) years after the last interaction, whichever is earlier.

7.2 Data Deletion

After applicable retention periods expire, we securely delete or anonymize your personal information using industry-standard data destruction methods. Anonymized data that cannot be linked back to you may be retained indefinitely for statistical analysis and business intelligence purposes.

8. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have specific rights regarding your personal information. 855pub is committed to facilitating the exercise of these rights:

8.1 Right to Access

You have the right to request confirmation of whether we process your personal data and to obtain a copy of your information. You can access most of your data directly through your account dashboard, which displays your profile information, transaction history, gaming activity, and communication preferences. For comprehensive data exports, contact our Data Protection Officer.

8.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most information directly through account settings. For changes requiring verification (such as name or date of birth), contact customer support with supporting documentation.

8.3 Right to Erasure

You may request deletion of your personal information when it is no longer necessary for the purposes for which it was collected, you withdraw consent on which processing is based, you object to processing and there are no overriding legitimate grounds, or the data has been unlawfully processed. Note that we may retain certain information when required by law or for legitimate business purposes such as fraud prevention and regulatory compliance.

8.4 Right to Restrict Processing

You can request restriction of processing when you contest the accuracy of data (pending verification), processing is unlawful but you prefer restriction over deletion, we no longer need the data but you require it for legal claims, or you have objected to processing (pending verification of legitimate grounds).

8.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, and machine-readable format (typically CSV or JSON) and to transmit that data to another service provider where technically feasible.

8.6 Right to Object

You may object to processing of your personal data for direct marketing purposes at any time. We will cease marketing communications immediately upon receiving your objection. You can also object to processing based on legitimate interests, though we may continue processing if we demonstrate compelling legitimate grounds that override your interests.

8.7 Right to Withdraw Consent

Where we process your data based on consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted prior to withdrawal.

8.8 Exercising Your Rights

To exercise any of these rights, contact our Data Protection Officer at [email protected] or through the contact form on our website. We will respond to requests within thirty (30) days as required by Philippine law. We may request additional information to verify your identity before fulfilling requests involving sensitive data.

9. Third-Party Services and Links

The 855pub Platform may contain links to third-party websites, services, or applications operated by our game providers, payment processors, and advertising partners. This Privacy Policy applies only to information collected by 855pub. We are not responsible for the privacy practices of third-party services, even if accessed through our Platform.

Before providing personal information to third-party services, we encourage you to review their privacy policies and terms of service. Third-party game providers may collect additional information through their games, subject to their own privacy policies. Payment processors collect financial information directly and are bound by PCI DSS security standards. Social media platforms may track your interactions with embedded content or social sharing buttons on our Platform.

10. International Data Transfers

855pub primarily operates within the Philippines and stores data on secure servers located in Philippine data centers. However, some of our service providers and technology partners are located outside the Philippines, which may result in your personal information being transferred to, stored in, or processed in other jurisdictions.

When we transfer data internationally, we ensure appropriate safeguards are in place including standard contractual clauses approved by data protection authorities, certification under recognized privacy frameworks, and verification that recipient countries provide adequate data protection levels. We transfer only the minimum information necessary to our international partners and require them to maintain security standards consistent with Philippine law.

11. Changes to This Privacy Policy

855pub reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, business operations, or technological developments. Material changes will be communicated through email notification to your registered address and prominent notice on the Platform at least fourteen (14) days before the changes take effect.

We encourage you to periodically review this Privacy Policy to stay informed about how we protect your information. The "Effective Date" at the top of this document indicates when the policy was last updated. Continued use of the Platform following policy changes constitutes acceptance of the updated Privacy Policy.

12. Contact Information

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us through the following channels: