135pub Privacy Policy

Data Controller

The data controller responsible for the personal information collected through the 135pub platform at 135pub.cam is 135pub (hereinafter referred to as "135pub," "we," "us," or "our"). As data controller, 135pub determines the purposes and means of processing personal data submitted by users of the platform ("you," "your," or "User").

135pub is operated for the Philippine market and processes personal data of Filipino users in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC) of the Philippines.

Personal Data We Collect

2.1 Data You Provide Directly

When you register an account, complete identity verification, deposit funds, or contact 135pub support, we collect personal data that you provide directly, including:

• Full legal name as it appears on your government-issued Philippine ID;
• Date of birth (used to verify the minimum age requirement of 21 years);
• Philippine mobile number used for account registration and OTP verification;
• Email address, if provided during registration or support contact;
• Residential address in the Philippines, required during KYC verification;
• Government-issued ID documents (e.g., PhilSys ID, UMID, driver's license, passport) uploaded for KYC;
• Selfie photographs submitted for facial identity verification;
• Payment method details, including GCash mobile number, e-wallet account names, bank account information, or cryptocurrency wallet addresses associated with your account.

2.2 Data Collected Automatically

When you access and use the 135pub platform, we automatically collect certain technical and behavioral data, including:

• IP address and approximate geographic location derived from it;
• Device type, operating system, and browser version;
• Session timestamps, login and logout times;
• Pages visited, game sessions accessed, and time spent on each section;
• Clickstream and interaction data within the platform;
• Connection type and mobile network operator (e.g., Smart, Globe) where applicable.

2.3 Transaction Data

All deposit and withdrawal transactions processed through your 135pub account are logged, including amount, method, timestamp, transaction reference, and outcome status. This data is retained for regulatory compliance purposes as described in Section 7 of this policy.

How 135pub Uses Your Personal Data

135pub uses the personal data we collect for the following purposes:

• Account Creation and Management — to register and maintain your 135pub account, authenticate your identity at login, and manage your account settings;
• Age and Identity Verification — to verify that you meet the minimum age requirement of 21 years and to comply with KYC obligations;
• Payment Processing — to process deposits and withdrawals through your chosen payment method, reconcile transactions, and manage your account balance;
• Platform Operation — to deliver game content, maintain service continuity, and optimize platform performance for Filipino users;
• Security and Fraud Prevention — to detect, investigate, and prevent unauthorized access, fraud, money laundering, and other prohibited activities;
• Legal and Regulatory Compliance — to fulfill obligations under Philippine law, PAGCOR-aligned requirements, anti-money laundering regulations, and any lawful requests from competent authorities;
• Responsible Gaming — to monitor gameplay patterns for indicators of problem gambling behavior, enforce self-exclusion requests, and provide access to responsible gaming tools;
• Customer Support — to respond to your queries, resolve disputes, and improve our support processes;
• Marketing Communications — to send promotional offers and platform updates, only where you have given explicit consent, and subject to your right to opt out at any time.

Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 135pub processes your personal data on the following lawful bases:

• Contractual Necessity — processing required to perform the contract between you and 135pub (i.e., providing platform access, processing transactions, operating your account);
• Legal Obligation — processing required for 135pub to comply with applicable Philippine law, regulatory obligations, and lawful governmental orders;
• Legitimate Interests — processing necessary for 135pub's legitimate interests, including fraud detection, platform security, and service improvement, where such interests are not overridden by your data rights;
• Consent — for marketing communications and any non-essential data collection, where you have given your explicit, freely given, specific, informed, and unambiguous consent.

Data Sharing and Disclosure

5.1 Service Providers

135pub engages third-party service providers to support platform operations, including payment processors (GCash, PayMaya, bank partners), identity verification services, game content providers, cloud infrastructure providers, and customer support systems. These providers access personal data only to the extent necessary to perform services on 135pub's behalf and are contractually bound to data protection obligations consistent with this policy.

5.2 Regulatory and Legal Disclosure

135pub may disclose personal data to Philippine government authorities, law enforcement agencies, PAGCOR, the Anti-Money Laundering Council (AMLC), or the National Privacy Commission where required by law, court order, or regulatory directive. 135pub cooperates fully with lawful investigations and will disclose the minimum data necessary to comply with each specific obligation.

5.3 No Commercial Data Sales

135pub does not sell, rent, or otherwise transfer your personal data to any third party for their independent commercial use or marketing purposes. Your data is not traded, licensed, or monetized outside of the operational and legal purposes described in this policy.

5.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 135pub's assets, your personal data may be transferred to the successor entity as part of the transaction. You will be notified of any such transfer and the successor entity will be required to honor the commitments in this Privacy Policy.

International Data Transfers

The 135pub platform and certain of its third-party service providers may process and store personal data on servers located outside the Philippines. Where such transfers occur, 135pub ensures that appropriate safeguards are in place consistent with the requirements of the Philippine Data Privacy Act, including contractual data protection clauses binding on the receiving entity.

By registering on the 135pub platform, you acknowledge that your personal data may be processed in jurisdictions outside the Philippines where data protection laws may differ from those applicable in the Philippines. 135pub takes reasonable steps to ensure that all cross-border transfers meet a standard of protection equivalent to that provided under Philippine law.

Data Retention

135pub retains personal data for the period necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

Upon expiry of the applicable retention period, personal data is either permanently deleted or irreversibly anonymized so that it can no longer be associated with an identifiable individual.

Security Measures

135pub implements technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• AES-256 encryption for data stored at rest on all 135pub systems;
• TLS 1.3 encryption for all data in transit between your device and 135pub servers;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Multi-factor authentication requirements for all internal 135pub system access;
• Regular third-party security audits and penetration testing of platform infrastructure;
• Automated intrusion detection and real-time anomaly monitoring;
• Incident response procedures for data breach notification consistent with NPC requirements.

While 135pub takes data security seriously and maintains robust protective measures, no online system is completely immune from risk. You are responsible for maintaining the confidentiality of your own account credentials. If you believe your account has been compromised, contact 135pub support immediately.

Cookies & Tracking Technologies

9.1 What We Use

The 135pub platform uses cookies and similar tracking technologies to maintain session continuity, authenticate returning users, analyze platform performance, and improve the user experience for Filipino players. The types of cookies used include:

• Strictly Necessary Cookies — required for the platform to function. These include session cookies that maintain your authenticated state while logged in to 135pub and cannot be disabled without impairing core functionality;
• Functional Cookies — remember your preferences such as language settings and display options;
• Analytics Cookies — collect aggregated, non-personally-identifying data about how players use the platform to help 135pub improve navigation, game discovery, and performance.

9.2 Your Cookie Choices

You may configure your browser to refuse or delete cookies. Note that disabling strictly necessary cookies will impair your ability to log in to and use the 135pub platform. Disabling analytics cookies will not affect your ability to use any platform features. Refer to your browser's help documentation for instructions on managing cookie settings.

Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012 and applicable regulations, you have the following rights with respect to your personal data held by 135pub:

• Right to Be Informed — to know what personal data 135pub holds about you and how it is used, as set out in this Privacy Policy;
• Right to Access — to request a copy of the personal data 135pub holds about you;
• Right to Rectification — to request correction of inaccurate or incomplete personal data;
• Right to Erasure ("Right to be Forgotten") — to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 135pub's legal retention obligations;
• Right to Object — to object to the processing of your personal data for direct marketing purposes at any time;
• Right to Data Portability — to receive your personal data in a structured, commonly used, machine-readable format;
• Right to Withdraw Consent — to withdraw consent for consent-based processing at any time without affecting prior lawful processing;
• Right to Lodge a Complaint — to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, contact the 135pub Data Protection Officer at [email protected]. We will respond to verified requests within fifteen (15) calendar days of receipt.

Minors and Age Restriction

The 135pub platform is strictly restricted to individuals aged 21 years and older under Philippine gambling regulations. 135pub does not knowingly collect, process, or retain the personal data of individuals under the age of 21.

If 135pub becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to close the relevant account, delete the associated personal data, and where required, notify relevant Philippine authorities. If you believe a minor has registered on the platform, please contact us at [email protected] immediately.

Third-Party Links and External Services

The 135pub platform may include references to or integrations with third-party game providers, payment processors, and service partners. These third parties operate under their own privacy policies, and 135pub is not responsible for their data practices. We encourage you to review the privacy policies of any third-party service you interact with in connection with your use of 135pub.

Cryptocurrency transactions conducted through blockchain networks (e.g., USDT on TRC-20, BTC, ETH) are recorded on public ledgers by nature of the underlying technology. 135pub has no control over data recorded on public blockchains and is not responsible for the immutable nature of on-chain transaction records.

Data Protection Officer

135pub has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. The DPO is the primary point of contact for data subjects wishing to exercise their rights or raise privacy-related concerns.

Changes to This Privacy Policy

135pub reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, platform features, or applicable legal requirements. The effective date at the top of this page will be updated whenever a material change is made.

Where changes are material, 135pub will provide advance notice to registered users via the platform notification system or to the mobile number associated with your account. Your continued use of the 135pub platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the changes. If you do not accept the updated policy, you must cease using the platform and may request account closure.

Contact and Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data 135pub holds about you, please contact us through any of the following channels:

• Email: [email protected] — use subject line "Privacy Request";
• Live Chat: Available 24/7 via the 135pub platform — average first response under 5 minutes;
• Formal Complaint: If you are not satisfied with our response, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines.