pub 202 Privacy Policy

1 Introduction

pub 202 ("the Platform," "we," "us," or "our") operates the online gaming platform accessible at pub202.org. As a personal information controller under the Data Privacy Act of 2012, pub 202 is responsible for the personal data you provide to us and the data we collect about you through your use of the platform.

This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information. It applies to all users of the pub 202 platform, including registered account holders, visitors to pub202.org, and individuals who interact with pub 202 through any channel.

This Privacy Policy should be read together with the pub 202 Terms & Conditions. Capitalised terms not defined in this Privacy Policy have the meanings given to them in the Terms & Conditions.

If you have questions about how pub 202 handles your personal data, please refer to Section 14 (Contact Us) of this Privacy Policy.

2 Data We Collect

2.1 Identity and Contact Information

When you register for a pub 202 account, we collect personal information necessary to verify your identity and comply with our regulatory obligations, including:

• Full legal name as it appears on your government-issued identification
• Date of birth (to verify you are 21 years of age or older)
• Residential address, including barangay, city or municipality, province, and postal code
• Email address
• Mobile phone number
• Nationality and country of residence

2.2 Identity Verification Documents

As part of our Know Your Customer (KYC) process, we may collect copies of:

• Government-issued photo identification (e.g., Philippine passport, driver's licence, SSS ID, UMID, PhilSys National ID, Voter's ID, PRC ID)
• Proof of address documents (e.g., utility bills, bank statements, barangay certificate)
• Proof of payment method ownership
• Source of funds documentation where required by our compliance obligations

2.3 Financial Information

We collect information related to your financial transactions on the pub 202 platform, including deposit amounts, withdrawal requests, payment method details (such as GCash account references or bank account details), transaction history, and bonus activity. We do not store full payment card numbers on our servers.

2.4 Gaming Activity Data

We collect data about your gaming activity on the pub 202 platform, including games played, bet amounts, win and loss records, session durations, and responsible gaming tool usage. This data is used for regulatory compliance, fraud prevention, and to improve your gaming experience.

2.5 Technical and Device Data

When you access pub 202, we automatically collect certain technical information, including your IP address, device type and operating system, browser type and version, referring URLs, pages visited, and timestamps of your activity on the platform.

2.6 Communications Data

We retain records of communications between you and pub 202, including live chat transcripts, email correspondence, and support ticket records. This data is used to resolve disputes, improve our support services, and comply with our regulatory obligations.

3 How We Collect Data

pub 202 collects your personal data through the following means:

• Direct collection: Information you provide when registering, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical data collected automatically through cookies, web beacons, and similar tracking technologies when you access the pub 202 platform.
• Third-party sources: Information received from payment processors (such as GCash and Maya), identity verification service providers, fraud prevention services, and regulatory databases, where permitted by applicable law.
• Public sources: Publicly available information used for identity verification and fraud prevention purposes, including information from government databases and credit reference agencies.

4 How We Use Your Data

pub 202 uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your pub 202 account, including processing your registration, verifying your identity, and managing your account settings.
• Service delivery: To provide you with access to the pub 202 gaming platform, process your deposits and withdrawals, credit bonuses, and deliver the services you have requested.
• Regulatory compliance: To comply with our obligations under Philippine gaming regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable laws. This includes conducting KYC verification, monitoring transactions for suspicious activity, and reporting to PAGCOR and other regulatory authorities as required.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the pub 202 platform.
• Responsible gaming: To monitor gaming activity for signs of problem gambling, enforce responsible gaming tools you have activated, and comply with our responsible gaming obligations.
• Customer support: To respond to your enquiries, resolve disputes, and improve our support services.
• Platform improvement: To analyse usage patterns, identify technical issues, and improve the functionality and user experience of the pub 202 platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out of marketing communications at any time through your account settings.
• Legal proceedings: To establish, exercise, or defend legal claims involving pub 202.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, pub 202 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you, including account management, payment processing, and service delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AMLA compliance, PAGCOR reporting obligations, and tax requirements.
• Legitimate interests: Processing necessary for pub 202'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 explicit consent, including marketing communications and certain uses of cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6 Data Sharing and Disclosure

6.1 Service Providers

pub 202 shares personal data with trusted third-party service providers who assist us in operating the platform, including payment processors (GCash, Maya, and Philippine banking partners), identity verification providers, fraud detection services, cloud hosting providers, and customer support technology providers. All service providers are contractually required to process your data only as instructed by pub 202 and to maintain appropriate security measures.

6.2 Regulatory Authorities

pub 202 is required by law to disclose certain personal data to regulatory authorities, including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government agencies, where required by applicable Philippine law or a valid legal order.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of pub 202's business, your personal data may be transferred to the acquiring entity as part of the transaction. You will be notified of any such transfer and any changes to this Privacy Policy that may result.

6.4 No Sale of Personal Data

pub 202 does not sell, rent, or trade your personal data to third parties for their own marketing purposes.

7 Data Retention

pub 202 retains your personal data for as long as necessary to fulfil the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations. Specific retention periods include:

• Account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required by AMLA and PAGCOR regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with AMLA requirements.
• KYC documents: Retained for a minimum of five (5) years after the end of the business relationship, or longer if required by applicable law.
• Support communications: Retained for a minimum of two (2) years from the date of the communication.
• Marketing data: Retained until you withdraw your consent to receive marketing communications.

When personal data is no longer required for the purposes for which it was collected and no legal obligation requires its retention, pub 202 will securely delete or anonymise the data.

8 Data Security

pub 202 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our security measures include:

• SSL/T LS encryption for all data transmitted between your device and the pub 202 platform
• Encryption of sensitive data at rest, including identity documents and financial information
• Access controls limiting personal data access to authorised pub 202 personnel on a need-to-know basis
• Regular security assessments and penetration testing of the pub 202 platform
• Two-factor authentication options for account access
• Continuous monitoring for suspicious activity and potential data breaches

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, pub 202 will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay, in accordance with the Data Privacy Act of 2012.

While pub 202 takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the security of your account credentials and for notifying pub 202 immediately if you suspect any unauthorised access to your account.

9 Cookies and Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit the pub 202 platform. They allow the platform to recognise your device, remember your preferences, and provide a personalised experience. pub 202 also uses similar technologies such as web beacons and local storage for comparable purposes.

9.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the platform to function, including session management, login authentication, and security features. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, display options, and responsible gaming tool configurations.
• Analytics cookies: Collect anonymised data about how users interact with the pub 202 platform, helping us identify areas for improvement. No personally identifiable information is collected through analytics cookies.
• Marketing cookies: Used to deliver relevant promotional content within the pub 202 platform, based on your gaming activity and preferences. These are only activated with your consent.

9.3 Managing Cookies

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the pub 202 platform. Strictly necessary cookies cannot be disabled as they are essential for platform operation.

10 Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pub 202:

• Right to be informed: The right to be informed about how your personal data is collected, used, and processed — which this Privacy Policy fulfils.
• Right of access: The right to request a copy of the personal data pub 202 holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You can update most account information directly through your pub 202 account settings.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe pub 202 has not handled your personal data in accordance with the Data Privacy Act of 2012.

To exercise any of these rights, please contact pub 202 support through your account dashboard. pub 202 will respond to your request within 30 days. We may need to verify your identity before processing your request.

11 Children's Privacy

The pub 202 platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. pub 202 does not knowingly collect personal data from individuals under the age of 21.

If pub 202 becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the personal data collected, and take appropriate action in accordance with our regulatory obligations. If you believe that a person under 21 has registered on the pub 202 platform, please contact our support team immediately.

Parents and guardians are encouraged to monitor the online activities of minors in their care and to use parental control tools to prevent access to online gaming platforms.

12 Responsible Gaming and Data

pub 202 uses your gaming activity data to support responsible gaming. Specifically, we may use your data to:

• Monitor your gaming patterns for indicators of problem gambling behaviour
• Enforce deposit limits, session time limits, and other responsible gaming tools you have activated
• Enforce self-exclusion periods you have requested
• Comply with PAGCOR's responsible gaming requirements

If you have self-excluded from pub 202, we retain your self-exclusion data for the duration of the exclusion period and for a reasonable period thereafter to prevent re-registration. This processing is necessary to fulfil our legal and regulatory obligations and cannot be restricted on the basis of your right to erasure during the exclusion period.

13 Changes to This Privacy Policy

pub 202 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, pub 202 will notify registered users via email or through a prominent notice on the platform prior to the changes taking effect.

The "Last Updated" date at the top of this page indicates when the Privacy Policy was most recently revised. We encourage you to review this Privacy Policy periodically to stay informed about how pub 202 protects your personal data.

Your continued use of the pub 202 platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not agree with the revised Privacy Policy, you must stop using the platform and may close your account in accordance with the Terms & Conditions.

14 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or pub 202's handling of your personal data, please contact our Data Protection Officer through your account dashboard's live chat feature, available 24/7.

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through its official government channels.