774pup Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 774pup ("we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you" or "your") who access or use the 774pup online gaming platform at https://774pup.com ("the Platform").

774pup operates under the regulatory framework of PAGCOR (Philippine Amusement and Gaming Corporation) and is committed to full compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations. This Policy applies to all personal data collected through the Platform, including data collected during registration, gameplay, financial transactions, customer support interactions, and marketing communications.

By registering an account or using the 774pup Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must not use the Platform.

2. Data Controller

774pup is the data controller responsible for the personal information collected through the Platform. As data controller, 774pup determines the purposes and means of processing your personal data. 774pup has appointed a Data Protection Officer ("DPO") in accordance with the requirements of the Data Privacy Act of 2012. You may contact the DPO regarding any privacy-related concerns by reaching out to our support team via live chat or at [email protected].

3. Data We Collect

774pup collects the following categories of personal data:

3.1 Identity Data

• Full legal name
• Date of birth (for 21+ age verification)
• Government-issued identification number (e.g., PhilSys ID, passport, driver's license)
• Nationality and country of residence
• Profile photograph (where submitted for KYC)

3.2 Contact Data

• Email address
• Mobile phone number
• Residential address (city, province, postal code)

3.3 Financial Data

• GCash or PayMaya account details
• Bank account information (BPI, BDO, Metrobank, or other Philippine banks)
• Payment card details (processed securely via PCI-DSS compliant gateways; full card numbers are not stored by 774pup)
• Transaction history, deposit and withdrawal records

3.4 Technical Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session data and login timestamps
• Cookies and similar tracking technologies (see Section 10)

3.5 Gaming Data

• Game history, bet records, and wagering activity
• Bonus and promotion usage
• Responsible gaming settings and self-exclusion status

3.6 Communications Data

• Records of customer support interactions (live chat transcripts, email correspondence)
• Marketing preferences and communication opt-in/opt-out status

4. How We Collect Your Data

774pup collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-money laundering screening services; payment data from payment processors (GCash, PayMaya, banks, card networks).

5. How We Use Your Data

774pup uses your personal data for the following purposes:

• Account management: Creating and maintaining your 774pup account, verifying your identity, and managing your login credentials.
• Age verification: Confirming that you meet the 21+ age requirement mandated by PAGCOR regulations and Philippine law.
• KYC compliance: Fulfilling our legal obligations under PAGCOR regulations and anti-money laundering laws to verify player identities.
• Transaction processing: Processing deposits, withdrawals, and bonus credits through GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard.
• Platform operation: Delivering games, calculating results, maintaining game history, and ensuring platform integrity.
• Fraud prevention: Detecting and preventing fraudulent activity, money laundering, multi-accounting, and other prohibited conduct.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior and administering self-exclusion and limit-setting tools.
• Customer support: Responding to your inquiries, resolving disputes, and providing technical assistance.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications.
• Legal compliance: Meeting our obligations under PAGCOR regulations, the Data Privacy Act of 2012, anti-money laundering laws, and other applicable Philippine legislation.
• Platform improvement: Analyzing usage patterns to improve the Platform's features, performance, and user experience.

6. Legal Basis for Processing

774pup processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to when registering your account (e.g., account management, transaction processing, game delivery).
• Legal obligation: Processing required to comply with PAGCOR regulations, anti-money laundering laws, KYC requirements, and other applicable Philippine legislation.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications, where you have provided explicit opt-in consent. You may withdraw this consent at any time.

7. Data Sharing & Disclosure

774pup does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly as necessary:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and other payment service providers for transaction processing.
• KYC and identity verification providers: Third-party services used to verify your identity and age in compliance with PAGCOR requirements.
• Anti-fraud and AML screening services: Providers used to detect and prevent money laundering, fraud, and other prohibited activities.
• IT and platform service providers: Cloud hosting, data storage, and technical infrastructure providers who process data on our behalf under strict data processing agreements.
• Regulatory authorities: PAGCOR and other Philippine government agencies, where disclosure is required by law or regulatory obligation.
• Law enforcement: Philippine law enforcement agencies, where disclosure is required by a valid legal order or to prevent serious harm.

All third-party service providers who process personal data on behalf of 774pup are required to maintain appropriate data security standards and to process data only in accordance with our instructions.

8. Data Retention

774pup retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years in compliance with anti-money laundering regulations.
• KYC documentation: Retained for a minimum of five (5) years following the end of the business relationship.
• Customer support records: Retained for three (3) years following the resolution of the relevant inquiry or dispute.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.

9. Data Security

774pup implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• AES-256 encryption for data stored at rest
• TLS 1.3 encryption for all data transmitted between your device and the Platform
• PCI-DSS compliant payment processing infrastructure
• Multi-factor authentication options for player accounts
• Regular security audits and penetration testing
• Strict access controls limiting employee access to personal data on a need-to-know basis
• Comprehensive staff training on data protection obligations

While 774pup takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 774pup will notify you and the National Privacy Commission in accordance with the requirements of the Data Privacy Act of 2012.

10. Cookies & Tracking Technologies

774pup uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Essential cookies: Required for the Platform to function correctly, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language settings, game preferences) to improve your experience.
• Analytics cookies: Collect anonymized data about how players use the Platform to help us improve performance and features.
• Marketing cookies: Used to deliver relevant promotional content to players who have opted in to marketing communications.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies in your browser, refer to your browser's help documentation.

11. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 774pup:

• Right to be informed: You have the right to be informed of how your personal data is being collected and processed, as described in this Policy.
• Right to access: You have the right to request a copy of the personal data that 774pup holds about you, along with information about how it is being used.
• Right to correction: You have the right to request correction of any inaccurate or incomplete personal data held by 774pup. You may update basic account information directly through your account settings.
• Right to erasure: You have 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 our legal retention obligations under PAGCOR regulations and anti-money laundering laws.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to our overriding legal obligations.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that your data privacy rights have been violated.

To exercise any of these rights, please contact the 774pup support team via live chat or at [email protected]. We will respond to all verified requests within thirty (30) days in accordance with the Data Privacy Act of 2012. We may require you to verify your identity before processing any data rights request.

12. Children's Privacy

The 774pup Platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with PAGCOR regulations and Philippine law. 774pup does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from an individual under 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please contact our support team immediately.

13. International Data Transfers

774pup's primary operations and data storage are based within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines (for example, cloud infrastructure providers or international payment networks). Where such transfers occur, 774pup ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses consistent with the requirements of the Data Privacy Act of 2012 and the standards set by the National Privacy Commission.

14. Changes to This Privacy Policy

774pup reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. When material changes are made, we will notify registered players via email or through a prominent notice on the Platform. The date of the most recent revision is displayed at the top of this page. Your continued use of the Platform following the posting of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how 774pup protects your personal data.

15. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact the 774pup Data Protection Officer through the following channels:

• Live Chat: Available 24/7 through the Platform
• Email: [email protected]

Our support team serves players across Manila, Cebu, Davao, Quezon City, Makati, and all other areas of the Philippines, and is available around the clock to address your privacy concerns.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.