999pub Privacy
Policy

The following definitions apply throughout this Privacy Policy:

• "999pub," "we," "us," "our" refers to the operator of the 999pub platform at 999pub.co, its affiliates, and its authorized service providers.
• "Personal Data" refers to any information that identifies or could reasonably identify a natural person, directly or indirectly, including but not limited to name, mobile number, address, government ID numbers, financial account details, and gaming activity records.
• "Processing" refers to any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, and deletion.
• "Data Subject" refers to the individual whose Personal Data is being processed — primarily, registered members and visitors of the 999pub platform.
• "DPA 2012" refers to the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.
• "NPC" refers to the National Privacy Commission of the Philippines, the regulatory body responsible for enforcing the DPA 2012.
• "DPO" refers to 999pub's designated Data Protection Officer, responsible for overseeing compliance with the DPA 2012 and this Privacy Policy.
• "Sensitive Personal Information" has the meaning ascribed to it under Section 3(l) of the DPA 2012, and includes government-issued identification numbers, biometric data, health records, and financial information.

For the purposes of the Philippine Data Privacy Act of 2012, the Personal Data Controller for data collected through the 999pub platform is the operator of 999pub.co, a gaming platform operating under PAGCOR regulatory oversight within the Philippines.

999pub has registered its data processing activities with the National Privacy Commission and has appointed a designated Data Protection Officer (DPO) in accordance with the requirements of the DPA 2012 and NPC Circular 2017-01. Contact details for the 999pub DPO are provided in Section 15 of this Privacy Policy.

The categories of Personal Data that 999pub collects from its members and platform visitors are as follows:

4.1 Direct Collection

999pub collects Personal Data directly from you when you: register an Account; complete KYC identity verification; make a deposit or request a withdrawal; set responsible gaming preferences; contact 999pub customer support via live chat or email; participate in a promotion, survey, or feedback request; or voluntarily provide information through any other interaction with the 999pub platform.

4.2 Automated Collection

When you access the 999pub platform, certain technical data is automatically collected by our servers and analytics systems, including your IP address, device identifiers, browser configuration, operating system, session timestamps, and clickstream data. This data is collected primarily for security, fraud prevention, and platform performance optimization purposes. See Section 7 for details on cookies and tracking technologies.

4.3 Third-Party Sources

In limited circumstances, 999pub may receive Personal Data about you from third parties, including: payment processors and e-wallet providers (GCash, PayMaya) for transaction verification; identity verification service providers engaged by 999pub for KYC processing; and fraud detection and anti-money laundering screening services. Data received from third parties is used only for the purposes consistent with this Privacy Policy.

Under the Philippine Data Privacy Act of 2012, 999pub processes your Personal Data on the following legal bases:

• Contractual Necessity: Processing required to fulfill the Terms & Conditions of your 999pub membership, including account management, game provision, deposit and withdrawal processing, and customer support;
• Legal Obligation: Processing required to comply with applicable Philippine law, including PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the Anti-Terrorism Financing Act, and any lawful order from a competent Philippine regulatory or law enforcement authority;
• Legitimate Interest: Processing conducted for 999pub's legitimate business interests, including fraud prevention, platform security, IT system maintenance, and internal analytics — subject to your interests and rights not overriding those interests;
• Consent: Processing for marketing communications, personalized promotional offers, and optional platform features — where consent is the legal basis, you have the right to withdraw your consent at any time without affecting the lawfulness of prior processing.

999pub uses the Personal Data it collects for the following purposes:

• To create, manage, verify, and operate your 999pub Account;
• To process deposits, withdrawals, and gaming transactions in Philippine Peso;
• To perform age verification and confirm that you meet the 21+ eligibility requirement under Philippine law and PAGCOR regulations;
• To conduct KYC identity verification as required by PAGCOR and AMLC compliance obligations;
• To detect, investigate, and prevent fraudulent activity, cheating, collusion, bonus abuse, and money laundering;
• To enforce 999pub's Terms & Conditions and Responsible Gaming policies, including processing self-exclusion requests and deposit limit settings;
• To respond to your customer support inquiries, complaints, and dispute submissions;
• To send transactional communications — including account notifications, deposit confirmations, OTP codes, and withdrawal status updates — to your registered Philippine mobile number or email address;
• To send promotional and marketing communications about 999pub bonuses, tournaments, and new games, where you have opted in to receive such communications;
• To analyze platform usage patterns and improve the 999pub user experience, game selection, and technical performance;
• To comply with any applicable legal obligation, regulatory request, or lawful court order.

7.1 What Are Cookies?

Cookies are small text files placed on your device by the 999pub platform when you access the website. They enable the platform to recognize your device, maintain your session state, remember your preferences, and collect analytical data about how the platform is used.

7.2 Types of Cookies Used by 999pub

• Strictly Necessary Cookies: Essential for the operation of the 999pub platform. These include session authentication cookies that maintain your logged-in state and security tokens that protect against cross-site request forgery (CSRF). These cookies cannot be disabled without impairing your ability to use the platform;
• Functional Cookies: Remember your language preferences, currency display settings, responsible gaming limits, and game preferences. These improve your experience but are not required for core platform function;
• Analytical Cookies: Collect anonymous data about how visitors use the 999pub platform — which pages are visited, how long sessions last, and which features are used most. This data helps 999pub improve platform performance and user experience;
• Security Cookies: Support 999pub's fraud detection and bot-prevention systems by analyzing device fingerprinting, IP addresses, and login patterns to identify suspicious activity.

7.3 Managing Cookies

You may adjust your browser settings to refuse cookies or to alert you when cookies are being set. Please note that disabling strictly necessary cookies will prevent you from logging into your 999pub Account or using core platform features. 999pub does not currently serve third-party advertising cookies.

999pub does not sell, rent, or commercially transfer your Personal Data to unaffiliated third parties. Personal Data is shared with third parties only in the following circumstances:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers receive the transaction data necessary to process your deposits and withdrawals. These providers are contractually bound to process data only for payment facilitation purposes;
• Identity Verification Providers: Third-party KYC service providers accredited for use under PAGCOR guidelines receive the identity data necessary to verify your government-issued identification documents. They are prohibited from using this data for any purpose other than verification;
• Fraud & AML Screening Services: PAGCOR-mandated anti-money laundering and fraud screening services may receive transaction data for compliance screening purposes. 999pub is required by the AMLC to report certain transactions to the Anti-Money Laundering Council;
• Game Content Providers: JILI, and other game providers integrated into the 999pub platform may receive anonymized session and gameplay data necessary to deliver and maintain their games. These providers do not receive personally identifiable information beyond what is necessary for technical game delivery;
• Regulatory Authorities: PAGCOR, the NPC, the AMLC, the Bureau of Internal Revenue (BIR), and other Philippine government agencies may receive Personal Data as required by applicable law, regulation, or lawful order;
• Legal Proceedings: Personal Data may be disclosed to Philippine courts, law enforcement, or legal advisers in connection with litigation, investigation, or the protection of 999pub's legal rights, to the extent permitted by the DPA 2012.

999pub implements a comprehensive information security program designed to protect Personal Data against unauthorized access, disclosure, alteration, and destruction. The security measures in place include, but are not limited to:

• Encryption in Transit: All data transmitted between your device and 999pub's servers is protected by TLS 1.3 with 256-bit AES encryption. The 999pub platform enforces HTTPS connections at all times;
• Encryption at Rest: Personal Data stored in 999pub's databases is encrypted using AES-256 encryption. Passwords are stored as salted cryptographic hashes using bcrypt — they cannot be recovered in plaintext by any 999pub employee;
• Access Controls: Access to systems containing Personal Data is restricted to authorized 999pub personnel on a need-to-know basis, enforced through role-based access control (RBAC) and multi-factor authentication (MFA) for administrative access;
• Security Monitoring: 999pub maintains 24/7 security monitoring of its systems, including intrusion detection systems (IDS), anomaly detection for login patterns, and automated alerting for suspicious activities;
• Penetration Testing: The 999pub platform undergoes regular penetration testing by qualified third-party security firms to identify and remediate vulnerabilities before they can be exploited;
• Employee Training: All 999pub staff with access to Personal Data receive mandatory training on data privacy obligations under the DPA 2012 and internal security procedures.

Notwithstanding these measures, no data transmission over the internet or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with 999pub is no longer secure, please contact 999pub support immediately.

999pub retains Personal Data for the period necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods mandated by Philippine law and PAGCOR regulations:

Upon expiry of the applicable retention period, Personal Data will be securely deleted or anonymized in accordance with NPC guidelines on data disposal. Where anonymization is not technically feasible, data will be destroyed using secure deletion methods that prevent recovery.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your Personal Data held by 999pub. These rights are available to all 999pub members and can be exercised by contacting the 999pub Data Protection Officer using the details provided in Section 15.

999pub will respond to all verified data subject rights requests within fifteen (15) business days of receipt, in accordance with the NPC's guidance on response timelines. Where the request is complex or involves large volumes of data, 999pub may extend this period by a further fifteen (15) business days, with written notice of the extension and the reasons for it.

If you believe that 999pub has not adequately addressed your privacy concerns or has processed your data in violation of the DPA 2012, you have the right to lodge a complaint with the National Privacy Commission at privacy.gov.ph (do not link externally — please search independently).

The 999pub platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine law and PAGCOR regulations governing online gaming. 999pub does not knowingly collect Personal Data from any individual under 21 years of age.

If 999pub discovers that an Account has been created by a person under 21, or that Personal Data has been collected from a minor, 999pub will immediately close the Account, forfeit any balance, and securely delete all associated Personal Data to the extent permitted by applicable law. Any adult who believes that a minor under their care has created a 999pub Account is encouraged to contact 999pub support immediately.

The 999pub platform primarily stores and processes Personal Data within the Philippines. In limited circumstances, Personal Data may be transferred to service providers or infrastructure systems located outside the Philippines — for example, game content providers whose technical infrastructure is hosted in other jurisdictions.

Any transfer of Personal Data outside the Philippines is conducted in accordance with Section 21 of the DPA 2012, which requires 999pub to ensure that the recipient country or organization provides an adequate level of data protection. Where the recipient country does not provide comparable protection, 999pub will implement appropriate safeguards such as standard contractual clauses or binding corporate rules, and will notify the NPC as required.

999pub reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable Philippine law, new guidance from the NPC, or changes to the 999pub platform. When material changes are made, 999pub will notify registered Members via the contact details on their Account and will update the "Last Updated" date at the top of this document.

For minor or administrative amendments — including clarifications of existing provisions and corrections of typographical errors — 999pub may update the Privacy Policy with immediate effect. Your continued use of the 999pub platform following any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this page periodically.

If you have any questions, concerns, or requests relating to this Privacy Policy or 999pub's handling of your Personal Data, please contact the 999pub Data Protection Officer through the following channels:

• DPO Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 through the 999pub platform (accessible after login) — select "Privacy & Data" from the subject menu
• Response Commitment: The 999pub DPO will acknowledge all privacy-related inquiries within 2 business days and provide a substantive response within 15 business days

This Privacy Policy was last reviewed and approved by the 999pub Data Protection Officer on 1 January 2026 and supersedes all prior versions of the 999pub Privacy Policy.