Privacy Policy

This Privacy Policy applies to all personal data processed by 999pub in connection with the operation of the online gaming and sports betting platform accessible at 999pub.one, including all associated mobile browser experiences, live chat support, and email communications.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act 10173), 999pub is the personal information controller with respect to the personal data of registered members and website visitors described in this Policy.

This Policy does not apply to third-party websites, game providers, or payment processors that may be accessible through or integrated with the 999pub platform. Those parties maintain their own privacy policies governing their independent data processing activities. 999pub encourages you to review the privacy practices of any third party with whom you interact in connection with your use of our platform.

999pub collects and processes the following categories of personal data:

999pub collects personal data through the following means:

• Direct Submission: Data you provide during account registration, KYC verification, payment transactions, support interactions, or when completing any form or profile update on the platform;
• Automated Technical Collection: Data collected automatically through your use of the platform, including through cookies, web beacons, server logs, and similar tracking technologies that capture device, session, and behavioral data;
• Third-Party Sources: Identity verification results from KYC service providers; payment confirmation data from payment processors (GCash, PayMaya, BPI, BDO, Metrobank); fraud and AML screening results from compliance service providers; and age verification confirmations;
• Regulatory Sources: Information received from PAGCOR or other Philippine regulatory bodies in connection with compliance obligations or investigations.

999pub processes your personal data on the following legal grounds under the Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary to perform our agreement with you as set out in the Terms & Conditions — including operating your account, processing deposits and withdrawals, delivering games and services, and providing customer support;
• Legal Obligation: Processing required to comply with PAGCOR operating regulations, the Anti-Money Laundering Act (Republic Act 9160 as amended), the Data Privacy Act, National Internal Revenue Code reporting requirements, and other applicable Philippine laws;
• Legitimate Interests: Processing necessary for 999pub's legitimate interests including platform security, fraud prevention, responsible gaming enforcement, service improvement, and internal analytics — where these interests are not overridden by your privacy rights;
• Consent: Where 999pub relies on your consent for specific processing activities (such as marketing communications), you may withdraw that consent at any time by contacting support or updating your account notification preferences.

The primary purposes for which 999pub processes your personal data include: account creation and management; identity verification and KYC compliance; payment processing; game delivery; customer support; fraud detection and AML compliance; responsible gaming monitoring; platform security; and where consent is given, promotional communications about 999pub offers.

999pub does not sell your personal data. We may share your data with the following categories of recipients in specific circumstances:

• PAGCOR and Philippine Regulatory Authorities: We are required to share certain player activity data, financial transaction records, and identity information with PAGCOR as part of our operating license obligations. We may also be required to disclose data to the Anti-Money Laundering Council (AMLC), Bureau of Internal Revenue (BIR), National Privacy Commission (NPC), or law enforcement agencies pursuant to lawful orders or requirements;
• KYC and Identity Verification Providers: We share identity data with accredited third-party KYC verification services for the purpose of verifying your identity and age. These providers are contractually bound to process your data only for this purpose;
• Payment Processors: We share necessary financial data with payment processors (GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency networks) to complete deposit and withdrawal transactions. These processors operate under their own privacy policies and financial regulation requirements;
• Game Software Providers: Game providers integrated into the 999pub platform may receive limited session and bet data necessary to deliver their games and calculate game outcomes. Providers are contractually prohibited from using this data for independent marketing;
• IT and Platform Infrastructure Providers: Cloud hosting, cybersecurity, and data analytics service providers who process data on 999pub's behalf under data processing agreements that impose equivalent privacy obligations;
• Professional Advisers: Legal, accounting, or auditing professionals bound by confidentiality obligations, where necessary for 999pub's legal compliance or business operations.

999pub uses cookies and similar tracking technologies on the platform. Cookies are small text files placed on your device that help the platform function correctly, remember your preferences, and collect analytical information about platform usage.

We use the following categories of cookies:

• Essential Cookies: Strictly necessary for the platform to function — maintaining your logged-in session, remembering your game preferences, and ensuring security features operate correctly. These cannot be disabled without disrupting core platform functionality;
• Analytical Cookies: Used to understand how players navigate and use the platform — which pages are visited, how long sessions last, and which features are most used. This data informs platform improvements. Analytical cookies are aggregated and do not identify individual players;
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized login attempts, and automated bot activity by tracking device and session characteristics;
• Preference Cookies: Store your language preferences, interface settings, and other personalisation choices so you don't have to reset them each session.

You may control non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the 999pub platform, including your ability to remain logged in or access certain game types. 999pub does not use third-party advertising cookies for the purpose of targeting you with advertisements on other websites.

999pub implements appropriate technical and organisational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security framework includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 999pub servers;
• Encryption at rest for stored personal data and financial records;
• Multi-factor authentication requirements for account access on new or unrecognized devices;
• Role-based access controls limiting employee access to personal data to those with a legitimate operational need;
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists;
• Intrusion detection systems and 24/7 security monitoring;
• Staff training on data privacy and security obligations;
• Vendor security assessments for all third-party processors with access to player data.

999pub retains your personal data for the periods necessary to fulfil the purposes described in this Policy, or as required by law:

• Account and Identity Data: Retained for the duration of your account plus five (5) years following account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act;
• Financial Transaction Records: Retained for five (5) years from the date of each transaction, in compliance with AML reporting obligations and BIR requirements;
• Gaming Activity Data: Retained for three (3) years from the date of activity for PAGCOR compliance and responsible gaming monitoring purposes;
• KYC Documents: Retained for five (5) years following account closure or the last transaction, whichever is later;
• Support Communication Records: Retained for two (2) years from the date of the interaction;
• Technical and Device Logs: Retained for twelve (12) months for security monitoring purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual. Anonymised data may be retained indefinitely for aggregate statistical and business analysis purposes.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 999pub:

999pub employs age verification measures during registration and KYC verification to prevent underage access. If 999pub discovers that personal data has been collected from an individual under 21 years of age, the relevant account will be immediately closed and all associated personal data securely deleted in accordance with our data retention procedures, except where retention is required by law.

If you are a parent or guardian and believe a person under 21 has registered a 999pub account, please contact us immediately at [email protected] and we will investigate and act promptly.

Some of 999pub's service providers — including cloud infrastructure providers, game software suppliers, and cybersecurity vendors — may be located outside the Philippines and may process your data in other jurisdictions including Singapore, Hong Kong, or the European Union.

Where personal data is transferred outside the Philippines, 999pub ensures that appropriate safeguards are in place to protect your data to a standard equivalent to Philippine data privacy requirements. These safeguards include data processing agreements with contractual provisions that replicate the protections of the Data Privacy Act, and transfers only to countries or processors with demonstrated adequate data protection frameworks.

999pub does not transfer personal data to jurisdictions that are subject to sanctions or that lack any recognized framework for personal data protection without first implementing additional contractual and technical safeguards approved by the National Privacy Commission.

999pub reserves the right to amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. Material changes will be communicated to registered members through in-platform notifications or email to the registered mobile number or address.

The "Last Updated" date at the top of this document reflects the date of the most recent revision. We encourage you to review this Policy periodically. Continued use of the 999pub platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy.

Where a proposed change would materially diminish your privacy rights under applicable law, 999pub will seek your consent before applying such changes to existing account data where required by the Data Privacy Act.

999pub has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and with the Data Privacy Act of 2012. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact:

• Data Protection Officer: 999pub Compliance Team
• Email: [email protected] — subject line: "Data Privacy — [Your Account Reference]"
• Live Chat: Available 24/7 on the 999pub platform (English and Tagalog)
• Response Time: We aim to acknowledge all data privacy requests within 3 business days and resolve them within 15 business days.

If you are not satisfied with our response to your data privacy request or complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the independent regulatory body responsible for enforcing the Data Privacy Act. Information on filing a complaint with the NPC is available at the NPC's official government website.