774pup Privacy Policy

1. Introduction

774pup ("we," "us," "our," or "the Company") is committed to protecting the privacy and security of the personal information of every player who registers and plays on the 774pup platform. This Privacy Policy ("Policy") describes the types of personal data we collect from users in the Philippines, the purposes for which that data is used, the circumstances under which it may be disclosed to third parties, and the rights you hold as a data subject under Philippine law.

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012, and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines. It should be read together with the 774pup Terms & Conditions, which govern the broader contractual relationship between you and 774pup.

If you have questions about this Policy at any point, please contact our Data Privacy Officer at [email protected] before continuing to use the platform.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, 774pup is the Personal Information Controller responsible for the personal data you provide when registering for and using the 774pup platform. All data processing activities described in this Policy are conducted under the authority and accountability of 774pup's designated Data Privacy Officer (DPO).

Our Data Privacy Officer can be contacted directly at: [email protected]. All data rights requests, privacy complaints, and policy inquiries should be directed to this address. We aim to acknowledge all DPO correspondence within 72 hours and to resolve data subject requests within 15 business days of receipt.

3. Personal Data We Collect

774pup collects the following categories of personal data from players:

We do not collect sensitive personal information as defined under the Data Privacy Act — such as health data, political affiliations, religious beliefs, or biometric data — unless required for a specific legal compliance purpose and only with your explicit consent.

4. How We Collect Your Data

774pup collects personal data through the following channels:

• Direct Collection: Information you provide when registering your 774pup account, completing KYC verification, making deposits or withdrawals, contacting customer support, or responding to surveys and promotions;
• Automated Collection: Technical and usage data collected automatically when you access and interact with the 774pup platform, including through cookies, web beacons, and server logs;
• Third-Party Sources: Identity verification data from KYC providers; fraud screening data from anti-fraud services; payment confirmation data from GCash, Maya, and banking partners. All third-party data processors engaged by 774pup are bound by contractual data processing agreements consistent with Philippine law.

5. How We Use Your Personal Data

774pup uses the personal data described in Section 3 for the following purposes:

• To create, verify, maintain, and administer your 774pup player account;
• To process deposits and withdrawals via GCash, Maya, BPI, BDO, and other supported Philippine payment methods;
• To verify your identity and age in compliance with PAGCOR regulations and the Anti-Money Laundering Act (AMLA);
• To detect and prevent fraud, money laundering, account takeover, and other prohibited activities;
• To provide 24/7 customer support in English and Filipino;
• To personalize your gaming experience, including game recommendations and tailored promotions;
• To monitor your gaming behavior for responsible gambling purposes and to enforce any limits or exclusions you have set;
• To send transactional communications such as deposit confirmations, withdrawal notifications, and security alerts;
• To send marketing communications about 774pup promotions and new games, where you have consented to receive such communications;
• To improve the technical performance, security, and features of the 774pup platform;
• To comply with applicable Philippine laws, PAGCOR directives, NPC requirements, and court or regulatory orders.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, 774pup processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and 774pup — including account management, payment processing, and customer support;
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, AMLC reporting requirements, NPC mandates, and other applicable Philippine laws;
• Legitimate Interest: Processing for fraud detection, security monitoring, platform analytics, and responsible gaming oversight, where our legitimate interests are not overridden by your data protection rights;
• Consent: Processing for direct marketing communications, optional personalization features, and any other processing for which 774pup has explicitly requested and obtained your prior consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

774pup does not sell, rent, or otherwise commercially exploit your personal data. We may share your data with the following categories of third parties strictly for the purposes described in this Policy:

• Payment Processors: GCash, Maya, GrabPay, BPI, BDO, Metrobank, and other payment partners, solely for the purpose of processing deposits and withdrawals to and from your 774pup wallet;
• Identity Verification Providers: Licensed KYC and AML service providers who assist 774pup in verifying player identities and screening for prohibited persons;
• Game Providers: Licensed third-party game studios whose games are available on the 774pup platform, who may receive anonymized or pseudonymized gameplay data for game performance purposes;
• Fraud and Security Services: Anti-fraud and cybersecurity service providers who help protect the integrity of the 774pup platform and its player accounts;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and courts, where disclosure is required by applicable Philippine law or a valid legal order;
• Professional Advisors: Legal, accounting, and auditing professionals engaged by 774pup, subject to strict confidentiality obligations.

All third-party data processors engaged by 774pup are required to enter into data processing agreements that impose obligations consistent with the Data Privacy Act of 2012 and restrict the use of your data to the specific purpose for which it was shared.

8. Cookies & Tracking Technologies

The 774pup platform uses cookies and similar tracking technologies to enhance your browsing experience, maintain your session after login, detect fraud, and gather aggregate analytics about platform usage. The categories of cookies used are:

• Essential Cookies: Required for the 774pup platform to function. These include session authentication cookies, security tokens, and load balancing cookies. These cannot be disabled without impairing platform functionality;
• Analytics Cookies: Used to collect aggregated, anonymized data about how players navigate the 774pup platform. This data helps us identify technical issues and improve usability;
• Preference Cookies: Store your language preference, display settings, and other personalization choices you make on the platform;
• Security Cookies: Support fraud detection and account security monitoring functions.

You may manage cookie preferences through your browser settings. Please note that disabling essential cookies will prevent you from logging in and using the 774pup platform. 774pup does not use third-party advertising or cross-site tracking cookies.

9. Data Security

774pup implements a multi-layered security architecture to protect your personal data against unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• 256-bit TLS encryption for all data in transit between your device and 774pup servers;
• AES-256 encryption for sensitive data stored at rest, including KYC documents and financial information;
• Multi-factor authentication requirements for account access and administrative systems;
• Real-time intrusion detection and security event monitoring;
• Regular third-party penetration testing and security audits;
• Strict internal access controls — employee access to personal data is role-based and limited to what is necessary for each staff member's function;
• Mandatory data privacy and security training for all 774pup staff with access to personal data.

While 774pup takes all reasonable and practicable steps to protect your data, no internet-based system can guarantee absolute security. In the event of a data breach that poses a risk to your rights and freedoms, 774pup will notify you and the National Privacy Commission within 72 hours of becoming aware of the breach, in accordance with NPC Circular 16-03.

10. Data Retention

774pup retains personal data for the minimum period necessary to fulfill the purpose for which it was collected, taking into account applicable legal retention obligations. Our standard retention periods are:

• Account and Identity Data: Retained for the duration of your active 774pup account plus a minimum of 5 years after account closure, in compliance with PAGCOR licensing requirements and AMLA record-keeping obligations;
• Transaction Records: Retained for a minimum of 5 years from the date of the transaction, as required by Philippine anti-money laundering law;
• KYC Verification Documents: Retained for 5 years following account closure or the completion of the relevant verification procedure, whichever is later;
• Customer Support Communications: Retained for 2 years from the date of the last interaction;
• Analytics and Usage Data: Retained in aggregated, anonymized form indefinitely for platform improvement purposes; individual usage records are anonymized after 12 months.

When your data is no longer required and no legal obligation compels its retention, 774pup will securely delete or irreversibly anonymize the data using industry-standard procedures.

11. Your Data Rights

Under the Data Privacy Act of 2012 (R.A. 10173), you have the following rights with respect to your personal data held by 774pup:

• Right to Be Informed: The right to be notified when your personal data is being collected and processed, including the purposes and legal basis for such processing;
• Right of Access: The right to request a copy of the personal data 774pup holds about you, along with information about how it is processed;
• Right to Rectification: The right to request the correction of inaccurate or incomplete personal data held by 774pup;
• Right to Erasure: The right to request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to any overriding legal obligation to retain the data;
• Right to Object: The right to object to certain processing activities, including direct marketing and processing based on legitimate interest;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please submit a written request to our Data Privacy Officer at [email protected]. We will respond within 15 business days of receiving a valid request. We may request proof of identity before processing your request to protect against unauthorized access.

12. Children's Privacy

The 774pup platform is strictly intended for individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing online gaming in the Philippines. 774pup does not knowingly collect personal data from any person under the age of 21.

If 774pup becomes aware that personal data has been collected from a person under the age of 21 — whether through a false declaration during registration or any other means — we will immediately close the associated account, delete all related personal data to the extent not required for regulatory reporting, and retain only the minimum data necessary to prevent re-registration.

If you are a parent or guardian and believe that a person under the age of 21 has registered on the 774pup platform, please contact us immediately at [email protected].

13. International Data Transfers

In the ordinary course of operating the 774pup platform, your personal data may be transferred to, stored in, or processed by systems located outside the Philippines — for example, by cloud infrastructure providers or internationally-based game server operators. Such transfers occur only where necessary for the delivery of the 774pup service.

When personal data is transferred internationally, 774pup ensures that appropriate safeguards are in place to maintain a level of protection consistent with the Data Privacy Act of 2012. These safeguards may include contractual data processing agreements, adequacy assessments, and/or binding corporate rules as applicable. If you would like further information about the safeguards applicable to any specific international transfer, please contact our Data Privacy Officer.

14. Third-Party Services

The 774pup platform integrates with third-party services — including payment processors, game providers, identity verification services, and customer support tools — to deliver a complete gaming experience. Each of these third-party providers operates under its own privacy policy and data handling practices.

When you use a third-party payment method such as GCash or Maya to deposit or withdraw funds on 774pup, your transaction data is processed directly by that provider under their applicable terms and privacy policies. 774pup receives only the confirmation and reference data necessary to credit or debit your 774pup wallet and is not responsible for the data practices of third-party payment providers.

All third-party data processors engaged by 774pup for core platform functions are required to enter into data processing agreements that obligate them to handle your data in accordance with applicable Philippine law and the terms of this Privacy Policy.

15. Updates to This Privacy Policy

774pup reviews and updates this Privacy Policy periodically to reflect changes in applicable law, PAGCOR regulations, NPC guidance, our data processing practices, or the features available on the platform. The current version of this Policy, along with the "Last Updated" date, is always available on this page.

Where a change to this Policy materially affects how we process your personal data or reduces your data rights, we will notify you via email to your registered address and/or by a prominent in-platform notification prior to the change taking effect. Your continued use of the 774pup platform after an updated Policy has been published constitutes acceptance of the revised terms. If you do not accept the revised Policy, you should cease using the platform and contact us to request account closure.

16. Contact & Data Privacy Officer

For any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data by 774pup, please contact our Data Privacy Officer using the information below:

• Email (Privacy & DPO): [email protected]
• Email (General Support): [email protected]
• Live Chat: Available 24/7 via the 774pup platform (requires login)
• Response Commitment: DPO inquiries acknowledged within 72 hours; fully resolved within 15 business days

If you are not satisfied with our response to a privacy concern, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines, the independent authority responsible for enforcing the Data Privacy Act of 2012.