pub 202 Privacy Policy

This Privacy Policy ("Policy") is issued by pub 202 ("pub 202," "we," "us," or "our"), the operator of the online gaming platform at pub202.biz ("the Platform"). This Policy applies to all personal information collected from individuals ("you," "Player," or "User") who access, register on, or use the pub 202 Platform. pub 202 is committed to the protection of personal data in accordance with Republic Act No. 10173 (the Philippine Data Privacy Act of 2012) and its implementing rules, as well as applicable PAGCOR regulatory requirements.

By creating an Account or using the pub 202 Platform, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal information as described herein.

1. About This Policy

1.1 This Policy describes the types of personal information pub 202 collects, the purposes for which it is processed, the parties with whom it may be shared, and the rights available to you as a data subject under Philippine law.

1.2 This Policy should be read alongside the pub 202 Terms & Conditions, which govern your overall use of the Platform. Both documents together constitute pub 202's primary commitments to players regarding their account and data.

1.3 Where pub 202 uses third-party service providers to process personal data on our behalf, we ensure those providers are bound by contractual data processing obligations consistent with this Policy and applicable Philippine law.

2. Data Controller

pub 202 is the personal information controller in respect of all personal data collected through the Platform. Queries regarding the exercise of data subject rights or concerns about data processing practices should be directed to:

Data Protection Contact: [email protected]

pub 202 has designated a Data Protection Officer (DPO) as required under the Philippine Data Privacy Act. The DPO oversees pub 202's compliance with RA 10173 and is the primary point of contact for the National Privacy Commission (NPC) on matters of data privacy.

3. Personal Information We Collect

pub 202 collects personal information through multiple channels, including account registration, identity verification, Platform use, and customer support interactions. The categories of information we collect include:

Category	Examples	When Collected
Identity Data	Full legal name, date of birth, gender, government-issued ID (Passport, SSS/UMID, PhilSys ID, Driver's License)	Registration, KYC verification
Contact Data	Email address, Philippine mobile number, residential address	Registration, account updates
Financial Data	GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records in PHP	Deposit/withdrawal processing, AML compliance
Technical Data	IP address, device type, browser type and version, operating system, session tokens, login timestamps	Automated on Platform use
Usage Data	Games played, bet amounts, win/loss history, session duration, game preferences, feature interactions	Automated during Platform use
Communications Data	Support chat logs, email correspondence, feedback submissions	Customer support interactions
Responsible Gaming Data	Self-exclusion elections, deposit limit settings, session time limits, cool-off requests	When responsible gaming tools are used

3.1 pub 202 does not collect sensitive personal information beyond that required for identity verification and regulatory compliance (e.g., government ID numbers as part of KYC). We do not collect health, religious, or political affiliation data.

3.2 Where you provide personal information about another individual (for example, listing a beneficiary for a payment account), you represent that you have that person's consent to share their information with pub 202 for the stated purpose.

4. How We Use Your Personal Information

pub 202 processes personal information for the following purposes:

• Account creation and management: to register your Account, verify your identity, maintain your player profile, and manage your PHP Wallet on pub 202;
• Service delivery: to provide access to games, process bets and payouts, apply bonuses, and operate all Platform features;
• Payment processing: to process deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, and to maintain transaction records;
• Regulatory compliance: to comply with PAGCOR licensing requirements, anti-money laundering (AML) obligations, Know Your Customer (KYC) mandates, and reporting requirements under Philippine law;
• Responsible gaming: to enforce deposit limits, session limits, self-exclusion elections, and other responsible gaming controls selected by the Player;
• Fraud prevention and security: to detect, investigate, and prevent fraudulent activity, cheating, collusion, and unauthorized account access;
• Customer support: to respond to queries, resolve complaints, and manage account issues;
• Platform improvement: to analyze usage patterns and technical performance data to improve the Platform experience for Filipino players;
• Marketing communications: to send promotional offers, bonus notifications, and Platform updates to Players who have opted in to marketing communications. Players may withdraw consent at any time by updating their Account notification preferences.

5. Legal Basis for Processing

pub 202 processes your personal information on the following legal grounds under the Philippine Data Privacy Act:

• Contractual necessity: processing required to perform our obligations under the pub 202 Terms & Conditions, including account management, game provision, and payment processing;
• Legal obligation: processing required to comply with PAGCOR licensing conditions, AML regulations, KYC requirements, and other applicable Philippine legal obligations;
• Legitimate interests: processing for fraud prevention, platform security, and service improvement, where pub 202's interests do not override the rights of data subjects;
• Consent: processing for direct marketing communications and non-essential cookies, where you have provided specific, informed consent that may be withdrawn at any time.

6. Data Sharing and Disclosure

6.1 pub 202 does not sell, rent, or trade your personal information to any third party for commercial purposes.

6.2 pub 202 may share personal information with the following categories of recipients, strictly as necessary for the purposes described in this Policy:

• Payment processors: GCash (GXchange Inc.), PayMaya (PayMaya Philippines Inc.), BPI, BDO, and Metrobank — to process deposits and withdrawals;
• Identity verification providers: third-party KYC service providers who assist pub 202 in verifying government-issued IDs;
• Game providers: certified game studios and content providers whose games are hosted on the pub 202 Platform, to the extent necessary to deliver game sessions;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where disclosure is required by law;
• Technology and hosting providers: cloud infrastructure and IT service providers who process data on pub 202's behalf under binding data processing agreements.

6.3 All third-party processors engaged by pub 202 are contractually required to process personal data only as instructed by pub 202, to maintain appropriate security measures, and to comply with applicable Philippine data protection law.

7. Data Retention

7.1 pub 202 retains personal information only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable law and PAGCOR regulatory obligations.

7.2 Transaction records, KYC documentation, and AML-related data are retained for a minimum of five (5) years from the date of the last transaction, in accordance with the Anti-Money Laundering Act of the Philippines (RA 9160, as amended).

7.3 Where an Account is closed voluntarily, pub 202 will retain personal data for the minimum retention period required by law. Data that is no longer required will be securely deleted or anonymized.

8. Cookies and Tracking Technologies

8.1 The pub 202 Platform uses cookies and similar tracking technologies to maintain login sessions, remember player preferences, analyze site usage, and support fraud prevention systems.

8.2 The following categories of cookies are used:

• Strictly necessary cookies: required for Platform functionality, including session management and authentication. These cannot be disabled without affecting core Platform features.
• Analytical cookies: used to understand how players interact with the Platform in aggregate. Data collected is anonymized or pseudonymized.
• Preference cookies: used to remember display preferences, language settings, and last-visited game category.

8.3 Non-essential cookies are only placed with your consent. You may manage cookie preferences through your browser settings at any time. Note that disabling certain cookies may affect Platform functionality.

9. Data Security

9.1 pub 202 implements industry-standard technical and organizational security measures to protect personal information against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the pub 202 Platform;
• Encrypted storage of sensitive personal and financial data at rest;
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis;
• Regular security assessments and penetration testing as required by PAGCOR compliance obligations;
• Two-factor authentication (2FA) options for Player accounts to reduce unauthorized access risk.

9.2 While pub 202 applies robust security measures, no online platform can guarantee absolute security. Players are responsible for maintaining the confidentiality of their Account credentials and should immediately report any suspected unauthorized access to [email protected].

9.3 In the event of a personal data breach that is likely to result in high risk to data subjects, pub 202 will notify the National Privacy Commission and affected Players within the timeframes required by the Philippine Data Privacy Act.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act (RA 10173), you have the following rights in respect of your personal information held by pub 202:

• Right to be informed: to be notified of how your personal data is collected, used, and shared, as set out in this Policy;
• Right of access: to request a copy of the personal information pub 202 holds about you;
• Right to rectification: to request correction of inaccurate or incomplete personal information in your Account;
• Right to erasure (right to be forgotten): to request deletion of personal information that is no longer necessary, subject to pub 202's legal retention obligations;
• Right to object: to object to the processing of your personal data for direct marketing purposes at any time, with immediate effect;
• Right to data portability: to receive your personal data in a structured, commonly used format where technically feasible;
• 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 the above rights, contact pub 202's Data Protection contact at [email protected]. pub 202 targets response to data subject rights requests within fifteen (15) business days of receipt. Identity verification may be required before requests are fulfilled.

11. Minors

11.1 The pub 202 Platform is strictly intended for individuals aged 21 years and above, in compliance with PAGCOR's minimum age requirements for online gaming in the Philippines. pub 202 does not knowingly collect personal information from anyone under the age of 21.

11.2 Where pub 202 discovers that personal data has been collected from a person under 21 years of age, the Account will be immediately suspended and all personal data associated with the underage registration will be deleted, subject to any mandatory retention obligations.

12. Third-Party Links

The pub 202 Platform may contain links to third-party sites or services (for example, payment provider portals). These third-party sites operate under their own privacy policies, and pub 202 is not responsible for their data practices. Players are encouraged to review the privacy policies of any third-party sites they visit.

13. Updates to This Policy

13.1 pub 202 reserves the right to update this Privacy Policy at any time. Where changes are material, pub 202 will provide advance notice by posting the updated Policy on the Platform and, where practicable, notifying Players via their registered email address.

13.2 The "Last Updated" date at the top of this Policy reflects the most recent revision. Continued use of the pub 202 Platform following the effective date of any amendments constitutes your acceptance of the revised Policy.

14. Contact Us

For questions about this Privacy Policy, requests to exercise your data subject rights, or concerns about pub 202's data processing practices, please contact:

Email: [email protected] (plain text — not a clickable link)

You may also file a complaint with the National Privacy Commission of the Philippines if you are not satisfied with pub 202's response to a data privacy concern. Information on the NPC complaints process is available on the NPC's official government website.