669 pub Privacy Policy

1. Data Controller

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, the data controller responsible for your personal information collected through the 669 pub platform at 669pub.club is:

669 pub acts as both data controller and data processor for the personal information collected directly through the Platform. Where third-party service providers process data on our behalf, appropriate data processing agreements are in place.

2. Personal Data We Collect

669 pub collects the following categories of personal data from players and visitors, depending on how they interact with the Platform:

2.1 Identity Data

• Full legal name as appearing on government-issued identification;
• Date of birth (required for 21+ age verification under PAGCOR rules);
• Nationality and country of residence;
• Government-issued ID number (e.g., PhilSys number, passport number, driver's licence number) — collected during KYC verification;
• Selfie or facial image submitted for identity verification purposes.

2.2 Contact Data

• Philippine mobile number (used as primary login identifier and for OTP authentication);
• Email address (where provided for account communications);
• Residential address (collected during full KYC verification).

2.3 Financial Data

• Payment method identifiers (e.g., GCash account number, Maya wallet ID, bank account details for BPI, BDO, UnionBank);
• Transaction history, including deposits, withdrawals, bonus credits, and wagering activity;
• Account balance information.

2.4 Technical & Usage Data

• IP address and approximate geographic location;
• Device type, operating system, and browser;
• Login timestamps and session duration;
• Pages visited, games played, and features used on the 669 pub Platform;
• Cookies and similar tracking technologies (see Section 10).

2.5 Communications Data

• Records of customer support interactions, including chat transcripts and emails;
• Feedback and complaints submitted to 669 pub;
• Marketing preferences and consent records.

3. How We Collect Your Data

669 pub collects personal data through the following means:

• Direct collection: Information you provide when registering, completing KYC, making a deposit or withdrawal, contacting customer support, or updating your account details.
• Automated collection: Technical data collected automatically when you access or use the Platform, including through cookies, server logs, and analytics tools.
• Third parties: Identity verification and KYC providers, payment processors (including GCash, Maya, and bank partners), fraud prevention services, and where applicable, PAGCOR reporting systems.

4. Purposes of Processing

669 pub processes your personal data for the following purposes:

1. Account management: Creating, maintaining, and operating your 669 pub player account, including login authentication via OTP.
2. Age and identity verification: Confirming that you meet the 21+ age requirement mandated by PAGCOR and that you are who you claim to be — essential for legal compliance.
3. Payment processing: Facilitating deposits and withdrawals via GCash, Maya, and other supported Philippine payment methods.
4. Anti-money laundering (AML) compliance: Monitoring transactions and account activity for patterns that may indicate financial crime, as required by PAGCOR and Philippine AML law.
5. Fraud prevention and platform security: Detecting and preventing unauthorised access, cheating, bonus abuse, and other forms of fraudulent activity.
6. Customer support: Responding to your queries, complaints, and requests.
7. Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviours and, where appropriate, reaching out to offer support tools.
8. Marketing communications: Sending you promotional offers, game announcements, and platform updates — only where you have given your consent or where a legitimate interest applies.
9. Legal and regulatory compliance: Meeting 669 pub's obligations under Philippine law, including PAGCOR reporting requirements and the Data Privacy Act of 2012.
10. Platform improvement: Analysing aggregated usage data to improve the 669 pub platform, games library, and user experience.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to fulfil our obligations under the 669 pub Terms and Conditions, including account management, game delivery, and payment processing.
• Legal obligation: Processing required to comply with PAGCOR licensing requirements, AML regulations, and other applicable Philippine law.
• 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 direct marketing communications, where we have obtained your prior consent. You may withdraw consent at any time.

6. Sharing Your Personal Data

669 pub does not sell your personal data to third parties. We share your data only in the following limited circumstances:

• Payment processors: GCash, Maya, BPI, BDO, UnionBank, and other payment partners require transaction data to process deposits and withdrawals. They act as independent data controllers for their own services.
• KYC and identity verification providers: Third-party services used to verify your identity and age during account registration and ongoing compliance checks.
• Fraud and AML detection services: Service providers who assist 669 pub in identifying suspicious activity on the Platform.
• PAGCOR and regulatory authorities: 669 pub may be required by law to disclose player account and transaction data to PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine regulatory bodies upon lawful request.
• Customer support tools: Third-party customer relationship management systems used to manage and respond to support queries, subject to appropriate data processing agreements.
• Legal proceedings: Where required to comply with a court order, legal process, or the lawful request of a government authority in the Philippines.

7. Data Retention

669 pub retains personal data for as long as is necessary for the purposes described in this Privacy Policy, subject to the following principles:

• Active player account data is retained for the lifetime of the account and for a minimum of five (5) years following account closure, in compliance with PAGCOR AML record-keeping requirements.
• Transaction records are retained for a minimum of five (5) years as required by Philippine AML regulations.
• Customer support communications are retained for three (3) years after resolution.
• Marketing consent records are retained for the duration of the marketing relationship and for a reasonable period thereafter to demonstrate compliance.

Where data is no longer required for any lawful purpose, 669 pub will securely delete or anonymise it. Anonymised, aggregated data may be retained indefinitely for statistical and platform improvement purposes.

8. Security Measures

669 pub implements technical and organisational security measures proportionate to the risks associated with processing your personal data. These include:

• 256-bit SSL/TLS encryption for all data in transit between your device and the 669 pub Platform;
• Encryption of sensitive stored data, including password hashing using industry-standard algorithms;
• Access controls limiting internal access to personal data on a need-to-know basis;
• Multi-factor authentication for administrative access to systems holding player data;
• Regular security assessments and penetration testing of Platform infrastructure;
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with the National Privacy Commission's breach notification requirements.

Notwithstanding these measures, no data transmission over the internet is completely secure. You use the 669 pub Platform at your own risk in this respect, and you are responsible for maintaining the confidentiality of your login credentials.

9. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by 669 pub:

• Right to be informed: The right to know what personal data 669 pub collects about you and how it is used — as provided by this Privacy Policy.
• Right of access: The right to request a copy of the personal data 669 pub holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure / blocking: The right to request deletion or blocking of your personal data where processing is no longer necessary, where consent has been withdrawn, or where processing is unlawful — subject to 669 pub's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe 669 pub has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, please submit a written request to [email protected]. 669 pub will respond within fifteen (15) business days of receiving a verifiable request. We may require identity verification before processing your request.

10. Cookies & Tracking Technologies

669 pub uses cookies and similar tracking technologies on the Platform to enable functionality, analyse usage, and personalise your experience. The categories of cookies used include:

• Strictly necessary cookies: Required for the Platform to function, including session authentication, login persistence, and security tokens. These cannot be disabled.
• Performance cookies: Collect anonymised data about how players use the Platform (e.g., pages visited, time on page) to help us improve. No personally identifiable information is collected in this category.
• Functional cookies: Remember your preferences (e.g., language, game settings) to improve your 669 pub experience.
• Marketing cookies: Used to deliver relevant promotional content within the Platform based on your gaming preferences and activity. These are used only with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to use the 669 pub Platform.

11. Minors & Age Restrictions

12. International Data Transfers

Some of 669 pub's third-party service providers — including certain payment processors, KYC providers, and cloud infrastructure partners — may be located outside the Philippines. Where personal data is transferred to recipients in other countries, 669 pub ensures that appropriate safeguards are in place, including contractual data transfer agreements that require overseas recipients to protect your data to a standard equivalent to that required under Philippine law.

By using the 669 pub Platform, you acknowledge and consent to the transfer of your personal data to overseas recipients where necessary for the purposes described in this Privacy Policy and subject to the safeguards described above.

13. Changes to This Privacy Policy

669 pub reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, the Platform, or applicable law. Material changes will be notified to registered players via a notice on the Platform or by SMS or email to your registered contact details.

The "Last Updated" date at the top of this page indicates when the Privacy Policy was most recently revised. Your continued use of the 669 pub Platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised terms.

We encourage you to review this Privacy Policy periodically to stay informed about how 669 pub protects your personal information.

14. Contact & Data Privacy Inquiries

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 669 pub, please contact us: