134 pub Privacy Policy

1 Introduction

134 pub ("we", "us", "our") is committed to protecting the privacy and personal data of all users of the 134 pub platform, accessible at 134pub.org. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in connection with your use of the 134 pub website, games, promotions, and related services (collectively, the "Platform").

This policy is written in plain English to make it as clear and accessible as possible for our Filipino players. We want you to understand exactly what happens to your data when you interact with 134 pub — from the moment you register an account to the day you request its closure.

This Privacy Policy should be read alongside the 134 pub Terms & Conditions, which govern your use of the Platform. Together, these documents form the complete agreement between you and 134 pub regarding your rights and obligations as a registered player.

2 Data Controller

For the purposes of applicable data protection legislation, including the Philippine Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, 134 pub is the data controller responsible for your personal information collected through the Platform.

As data controller, 134 pub determines the purposes and means of processing your personal data. We are responsible for ensuring that your data is handled lawfully, fairly, and transparently in accordance with this Privacy Policy and applicable Philippine data protection law.

3 Personal Data We Collect

134 pub collects the following categories of personal data from users of the Platform:

134 pub does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by law (for example, in connection with responsible gaming assessments or legal compliance obligations).

4 How We Collect Your Data

134 pub collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated technologies: Technical and usage data collected automatically through cookies, web beacons, server logs, and similar tracking technologies when you access the Platform;
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-money laundering screening services; payment data from GCash, Maya, and banking partners as required to process transactions;
• Publicly available sources: Information from public records or databases where required for legal compliance or fraud prevention purposes.

5 How We Use Your Personal Data

134 pub uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your 134 pub account, including processing your registration, verifying your identity, and managing your login credentials;
• Service delivery: To provide access to games, process deposits and withdrawals, award bonuses, and deliver the full range of 134 pub Platform services;
• Legal compliance: To comply with Philippine anti-money laundering laws, PAGCOR regulatory requirements, tax obligations, and other applicable legal duties, including mandatory reporting to authorities;
• Fraud prevention & security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, and other prohibited conduct on the Platform;
• Responsible gaming: To monitor gaming behaviour, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of problem gambling;
• Customer support: To respond to your enquiries, resolve disputes, and improve the quality of our support services;
• Platform improvement: To analyse usage patterns, conduct research, and improve the features, performance, and content of the 134 pub Platform;
• Marketing communications: To send you promotional offers, bonus notifications, and news about 134 pub — only where you have given your consent or where we have a legitimate interest to do so, and always with an easy opt-out option.

134 pub will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent.

6 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 134 pub processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your account, process transactions, and deliver Platform services;
• Legal obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR licensing conditions, and tax reporting requirements;
• Legitimate interests: Processing necessary for 134 pub's legitimate business interests, including fraud prevention, Platform security, and service improvement, where these interests are not overridden by your privacy rights;
• Consent: Processing based on your freely given, specific, and informed consent — primarily for direct marketing communications. You may withdraw consent at any time by contacting support or using the opt-out mechanism in any marketing email.

7 Data Sharing & Disclosure

134 pub does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your data with the following categories of recipients only to the extent necessary for the purposes described in this policy:

• KYC & identity verification providers: To verify your identity and age in compliance with regulatory requirements;
• Payment processors: GCash, Maya, and Philippine banking partners, to process deposits and withdrawals on your behalf;
• Game providers: Licensed game software providers whose titles are available in the 134 pub lobby, to the extent necessary to deliver game services;
• Fraud prevention & AML screening services: To screen transactions and account activity against sanctions lists and fraud databases as required by Philippine law;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where disclosure is required by law or court order;
• Professional advisers: Lawyers, auditors, and accountants, where necessary for legal, compliance, or financial reporting purposes, subject to strict confidentiality obligations;
• Business transfers: In the event of a merger, acquisition, or sale of all or part of 134 pub's business, your data may be transferred to the acquiring entity, subject to equivalent privacy protections.

8 Data Retention

134 pub retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

• Active account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required by Philippine anti-money laundering regulations;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• KYC documents: Retained for a minimum of five (5) years after account closure or the end of the business relationship;
• Support communications: Retained for three (3) years from the date of the last interaction;
• Marketing consent records: Retained until you withdraw consent, plus one (1) year thereafter for compliance documentation purposes.

When your data is no longer required, 134 pub will securely delete or anonymise it in accordance with our internal data retention and disposal procedures.

9 Data Security

134 pub implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 134 pub Platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Two-factor authentication (2FA) available for all registered accounts;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Secure, access-controlled data centres with physical security measures;
• Staff training on data protection and information security best practices.

While 134 pub takes all reasonable steps to protect your data, no method of electronic transmission or storage is 100% secure. In the event of a personal data breach that poses a risk to your rights and freedoms, 134 pub will notify the National Privacy Commission and affected individuals in accordance with the requirements of the Data Privacy Act of 2012.

10 Cookies & Tracking Technologies

134 pub uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and support fraud prevention. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled;
• Functional cookies: Remember your preferences, such as language settings and display options, to personalise your experience;
• Analytics cookies: Collect anonymised data about how users interact with the Platform to help us improve performance and content;
• Fraud prevention cookies: Help us detect and prevent fraudulent activity, including the use of multiple accounts and bonus abuse.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 134 pub Platform. 134 pub does not use third-party advertising cookies or share cookie data with external advertising networks.

11 Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 134 pub:

To exercise any of these rights, please contact our Data Privacy Officer at [email protected]. We will respond to all verified requests within thirty (30) calendar days. We may need to verify your identity before processing your request. If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

12 Minors & Age Verification

134 pub employs mandatory age verification procedures during the account registration process. All players are required to confirm that they are at least 21 years of age and to provide valid government-issued identification as part of the KYC process.

If 134 pub becomes aware that personal data has been collected from a person under the age of 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the 134 pub Platform, please contact us immediately at [email protected].

13 Changes to This Privacy Policy

134 pub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. The date of the most recent revision is displayed at the top of this page.

When material changes are made to this policy, 134 pub will notify registered players via email or through a prominent notice on the Platform. Your continued use of the 134 pub Platform after any amendments have been posted constitutes your acknowledgement of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how 134 pub protects your personal data.

14 Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or the way 134 pub handles your personal data, please contact our Data Privacy Officer:

We take all privacy complaints seriously and will respond within thirty (30) calendar days of receiving your complaint. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.