Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") sets out the basis on which 554 pub ("554 pub", "we", "us", "our") collects, uses, discloses, and otherwise processes personal data relating to players, registered users, and visitors of 554pub.club (the "Platform").

1.2 This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), the issuances of the National Privacy Commission ("NPC"), and applicable PAGCOR data governance requirements.

1.3 By accessing or using the 554 pub Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must discontinue use of the Platform and contact us to close your account.

1.4 This Policy should be read alongside 554 pub's Terms & Conditions, which govern your use of the Platform in its entirety.

2. Who We Are — Data Controller

2.1 For the purposes of the DPA and this Policy, 554 pub is the Personal Information Controller ("PIC") in respect of personal data processed through the Platform. As PIC, 554 pub determines the purposes and means of processing your personal data and is responsible for ensuring that all processing is carried out in accordance with applicable law.

2.2 554 pub has appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with this Policy and the DPA. The DPO may be contacted through the support channels described in Section 15 of this Policy.

2.3 554 pub operates 554pub.club under the regulatory oversight of the Philippine Amusement and Gaming Corporation ("PAGCOR"). Certain data processing activities are mandated by PAGCOR regulations and cannot be waived by player consent or account closure.

3. Personal Data We Collect

554 pub collects the following categories of personal data, depending on your interaction with the Platform:

4. How We Collect Personal Data

554 pub collects personal data through the following means:

• Direct collection: Information you provide when registering a 554 pub Account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions.
• Automated collection: Technical and gaming activity data collected automatically through cookies, server logs, and the Platform's operational systems when you access or use 554 pub.
• Third-party sources: Identity and fraud-screening information from licensed KYC verification service providers; transaction data from GCash, Maya, and Philippine banking partners; regulatory data from PAGCOR or law enforcement agencies where legally required.

5. Purposes of Processing

554 pub processes your personal data for the following purposes:

• Account management: Creating and maintaining your 554 pub Account, authenticating your identity at login, and providing access to Platform features.
• Age and identity verification: Verifying that you meet the 21+ age requirement and confirming your identity as required by PAGCOR's KYC standards.
• Payment processing: Processing deposits from and withdrawals to your GCash, Maya, or Philippine bank account in connection with your gaming activity.
• Regulatory compliance: Meeting mandatory PAGCOR reporting obligations, AMLA suspicious transaction reporting, and compliance with NPC requirements under the DPA.
• Responsible gaming: Monitoring gaming behaviour patterns to identify potential problem gambling activity and administering self-exclusion and limit-setting tools in accordance with PAGCOR's responsible gaming framework.
• Security and fraud prevention: Detecting, investigating, and preventing fraudulent transactions, account takeovers, money laundering, and other prohibited activities on the Platform.
• Customer support: Responding to your enquiries, resolving disputes, and improving the quality of support services.
• Platform improvement: Analysing aggregate, anonymised usage data to improve the Platform's performance, game offering, and user experience.
• Marketing communications: Sending promotional offers and updates to players who have consented to receive marketing communications. You may withdraw this consent at any time by contacting support.

6. Legal Basis for Processing

554 pub relies on the following legal bases for processing personal data under the DPA and its IRR:

• Contractual necessity: Processing required to perform our contract with you — specifically, to operate your Account, process transactions, and provide gaming services as described in the Terms & Conditions.
• Legal obligation: Processing necessary to comply with mandatory PAGCOR requirements, AMLA reporting obligations, NPC directives, and other applicable Philippine law.
• Legitimate interests: Processing necessary for 554 pub's legitimate interests in fraud prevention, platform security, and responsible gaming monitoring, provided such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications, which is conducted only where you have given express, freely-given consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

7.1 Service Providers (Personal Information Processors)

554 pub engages the following categories of third-party service providers ("Personal Information Processors") who process data on our behalf, subject to written data processing agreements that require them to maintain equivalent data protection standards:

• Payment processors and e-wallet operators (GCash, Maya, and Philippine banking partners) — for transaction processing;
• KYC and identity verification providers — for age verification and fraud screening;
• IT infrastructure and cloud hosting providers — for Platform operation and data storage;
• Game software providers — to the extent necessary for live dealer operations and game platform integration;
• Customer support platform providers — for live chat and ticketing system operation.

7.2 Regulatory and Law Enforcement Disclosure

554 pub may be required to disclose personal data to PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission, the Bureau of Internal Revenue, or other government authorities where required by applicable Philippine law, a valid court order, or a lawful regulatory directive. 554 pub will notify affected players of such disclosures where legally permitted to do so.

7.3 No Sale of Data

554 pub does not sell, rent, or trade personal data to any third party for commercial purposes, including advertising networks, data brokers, or marketing agencies.

8. International Data Transfers

8.1 Some of 554 pub's service providers operate systems located outside the Philippines. Where personal data is transferred to a jurisdiction outside the Philippines, 554 pub ensures that such transfers are carried out only where:

• The receiving jurisdiction has been assessed as providing an adequate level of data protection consistent with Philippine DPA standards; or
• Appropriate contractual safeguards are in place between 554 pub and the receiving entity, including standard contractual clauses approved by the NPC; or
• The transfer is otherwise authorised under the DPA and its IRR.

8.2 Players may request information about the safeguards applied to specific international transfers by contacting 554 pub's Data Protection Officer.

9. Data Retention

554 pub retains personal data for the following periods, unless a longer retention period is required by applicable law:

Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymised. Anonymised, aggregate data may be retained indefinitely for statistical and Platform improvement purposes.

10. Security Measures

554 pub implements and maintains appropriate technical and organisational security measures to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, and unauthorised access. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between the Platform and player devices;
• Encryption of sensitive data at rest, including KYC documents and financial records;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Multi-factor authentication requirements for administrative access to data systems;
• Regular security vulnerability assessments and penetration testing;
• Incident response procedures for personal data breaches, including NPC notification protocols;
• Staff training on data privacy obligations and security best practices.

Notwithstanding these measures, no data transmission or storage system is unconditionally secure. Players are also responsible for maintaining the security of their own Account credentials, as described in 554 pub's Terms & Conditions.

11. Cookies & Tracking Technologies

11.1 What Cookies 554 pub Uses

554 pub uses the following categories of cookies and similar tracking technologies on the Platform:

• Strictly necessary cookies: Required for the Platform to function. These enable session management, login authentication, and security features. They cannot be disabled without impairing your ability to use the Platform.
• Functional cookies: Used to remember your preferences, such as preferred language or game display settings, to provide a more personalised experience.
• Analytics cookies: Used to collect aggregate, anonymised data about how players use the Platform — such as which pages are visited most frequently and how long sessions last. This data is used to improve the Platform and is not linked to individual identities.
• Security cookies: Used to detect and prevent fraudulent activity, including login attempts from unrecognised devices and automated bot activity.

11.2 Managing Cookies

You may control cookie settings through your browser preferences. Disabling strictly necessary cookies will affect Platform functionality. Disabling analytics or functional cookies will not prevent access to the Platform but may affect your user experience. 554 pub does not use third-party advertising or retargeting cookies.

12. Your Rights as a Data Subject

Under the DPA and its IRR, you have the following rights in relation to your personal data held by 554 pub. To exercise any of these rights, contact our Data Protection Officer using the details in Section 15.

554 pub will respond to verified data subject requests within thirty (30) calendar days. Complex or high-volume requests may require an extension of up to a further thirty (30) days, of which you will be notified.

13. Minors & Age Restriction

13.1 The 554 pub Platform is strictly intended for individuals aged 21 years and above. 554 pub does not knowingly collect personal data from individuals under the age of 21.

13.2 If 554 pub becomes aware that personal data has been collected from a person under 21 years of age, the Account will be immediately suspended, the data will be handled in accordance with applicable law, and the matter will be referred to PAGCOR's responsible gaming compliance team.

13.3 If you are a parent or guardian and believe that a person under 21 has registered an Account with 554 pub using your payment method or contact details, please contact our support team immediately via live chat or email. We will investigate and take appropriate action promptly.

14. Changes to This Privacy Policy

14.1 554 pub reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, or our data processing practices. The date at the top of this Policy reflects the date of the most recent revision.

14.2 Material changes to this Policy — particularly those affecting the legal basis for processing or the categories of data collected — will be communicated to registered players via email or in-platform notification with a minimum of fourteen (14) days' advance notice, except where immediate amendment is required by law or regulatory directive.

14.3 Continued use of the 554 pub Platform after the effective date of any amendment constitutes your acceptance of the revised Policy. If you do not agree with the changes, you may close your Account by contacting support and withdraw any remaining real-money balance.

15. Contact Us & Data Protection Officer

For any data privacy enquiry, to exercise your data subject rights, or to contact 554 pub's Data Protection Officer, please use the following channels. All data privacy requests will be logged, acknowledged within two (2) business days, and resolved within thirty (30) calendar days.

Where a data subject request concerns sensitive personal information or relates to potential data breach notification, 554 pub's DPO will handle the request directly and may require identity verification before disclosing or acting on any personal data.