pub202 Privacy Policy

pub202 ("pub202", "we", "us", "our") is committed to protecting the personal data of every player, visitor, and user ("you", "Data Subject") who interacts with our online gaming platform at pub202.club ("Platform"). This Privacy Policy ("Policy") describes our practices with respect to the collection, use, storage, sharing, and protection of your personal data in connection with your use of the pub202 Platform and all associated services.

This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines ("NPC"). Where applicable, this Policy also reflects the requirements of PAGCOR's data governance standards applicable to licensed Philippine online gaming operators.

By registering an account on pub202, accessing the Platform, or providing any personal data to pub202, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not consent to this Policy, you should not register an account or use pub202's services.

The data controller responsible for the personal data collected through pub202.club is the legal entity operating the pub202 Platform. pub202 has appointed a Data Protection Officer (DPO) as required under the Philippine Data Privacy Act for personal information controllers engaged in processing personal data on a significant scale.

For all privacy-related inquiries, data subject access requests, complaints, or notifications of data breaches by players, the designated point of contact is pub202 Customer Support, reachable via live chat on pub202.club or by written communication to the email address [email protected]. Correspondence directed to the attention of the Data Protection Officer will be routed to the appropriate internal team.

pub202 is registered as a personal information controller with the National Privacy Commission of the Philippines in accordance with the requirements of the DPA and NPC Registration Regulations.

pub202 collects the following categories of personal data in the course of providing its services:

3.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify you are 21 years of age or older);
• Philippine mobile number (used for account authentication, OTP delivery, and 2FA);
• Email address (used for account communications and password recovery);
• Username and encrypted password hash;
• Residential address (collected during KYC verification).

3.2 Identity Verification (KYC) Data

• Scanned copies or photographs of government-issued Philippine identification documents (PhilSys National ID, passport, driver's license, SSS/GSIS ID, PRC ID, voter's ID, or equivalent);
• Selfie photographs or video frames captured for liveness verification purposes;
• Proof of payment method ownership documents where required;
• Source of funds documentation for accounts subject to enhanced due diligence.

3.3 Financial Transaction Data

• Deposit amounts, dates, and payment channels (GCash, Maya, BPI, BDO, etc.);
• Withdrawal requests, amounts, processing status, and destination payment account details;
• GCash/Maya account reference numbers and partial identifiers as provided by payment processors;
• Transaction history and account balance records.

3.4 Gaming Activity Data

• Game sessions, bet amounts, game outcomes, and win/loss records;
• Bonus claims, wagering progress, and promotional participation records;
• Responsible gaming tool settings (deposit limits, session timers, self-exclusion records);
• Customer support interaction records, including chat transcripts and complaint histories.

3.5 Technical & Device Data

• IP address and approximate geolocation (country/region level) at login;
• Device type, operating system, and browser type;
• Session timestamps and login/logout records;
• Cookie identifiers and analytics data as described in Section 9.

pub202 collects personal data through the following channels and methods:

• Direct submission: Information you voluntarily provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting Customer Support, or updating your account profile;
• Automated technical collection: Device and session data collected automatically when you access pub202.club, including IP address, browser fingerprint data, and session logs generated by our server infrastructure;
• Cookies and similar technologies: As described in Section 9 of this Policy, pub202 uses cookies, web beacons, and similar technologies to collect data relating to your use of the Platform;
• Third-party payment processors: Transaction confirmation data received from GCash, Maya, BPI, BDO, and other payment partners when you complete a deposit or withdrawal;
• KYC and identity verification partners: Verification status and risk assessment data received from our third-party identity verification provider following submission of your identification documents;
• Regulatory and compliance sources: Information received from PAGCOR, AMLC, or other Philippine regulatory bodies in connection with compliance obligations, including watchlist data and regulatory notifications.

pub202 processes your personal data only for specified, legitimate purposes. The table below outlines the primary purposes of processing and the corresponding legal basis under R.A. 10173:

Where pub202 processes your personal data on the basis of consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal. Withdrawing consent for processing that is required to provide core services (e.g., KYC processing) may result in the suspension of those services.

pub202 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. pub202 shares personal data only with the following categories of recipients, strictly on a need-to-know basis and subject to confidentiality obligations or legal requirements:

6.1 Payment Service Providers

GCash (Mynt — Globe Fintech Innovations, Inc.), Maya (PayMaya Philippines, Inc.), BPI, BDO, Metrobank, and other Philippine payment partners receive transaction data necessary to process deposits and withdrawals. These entities are independently regulated by the Bangko Sentral ng Pilipinas (BSP) and operate under their own privacy policies.

6.2 KYC and Identity Verification Partners

pub202 uses a third-party identity verification provider to process KYC documents. Identity data transmitted to this provider is subject to a Data Processing Agreement (DPA Agreement) that requires the provider to process data only for pub202's stated KYC purposes, maintain appropriate security standards, and not retain data beyond what is necessary.

6.3 Game Content Providers

Game providers such as JILI Gaming, Pragmatic Play, PG Soft, Evolution Gaming, and others may receive anonymized or pseudonymized session identifiers to enable game play, record game outcomes, and detect cheating or irregular play patterns. Personal identifiers are not routinely transmitted to game providers without your knowledge.

6.4 Regulatory and Law Enforcement Bodies

pub202 is required by Philippine law to disclose personal data and transaction records to PAGCOR, the AMLC, the National Privacy Commission, and other competent Philippine authorities upon lawful request or as required by mandatory reporting obligations. Such disclosures may be made without prior notice to you where legally required.

6.5 Professional Advisers

pub202 may share personal data with legal counsel, auditors, and other professional advisers where necessary for legal proceedings, compliance audits, or regulatory correspondence. Such advisers are bound by confidentiality obligations.

pub202 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to mandatory retention periods imposed by Philippine law. The following general retention periods apply:

• Account and registration data: Retained for the duration of your account plus five (5) years following account closure, to comply with PAGCOR record-keeping requirements and potential audit obligations;
• KYC and identity verification documents: Retained for five (5) years following account closure, in compliance with AMLA requirements for covered persons;
• Financial transaction records: Retained for five (5) years from the date of each transaction, or longer where required by AMLC record-keeping rules applicable to covered transactions;
• Gaming activity logs: Retained for two (2) years following account closure, or longer where records are relevant to an open dispute, regulatory investigation, or legal proceeding;
• Customer support records: Retained for two (2) years from the date of the last interaction;
• Marketing consent records: Retained for three (3) years from the date of consent, or until consent is withdrawn, whichever is earlier;
• Technical and access logs: Retained for twelve (12) months from the date of generation, subject to extension where security investigation requires.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized such that re-identification is not reasonably practicable. Anonymized and aggregated data may be retained indefinitely for statistical and business analytics purposes.

pub202 implements appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

8.1 Technical Safeguards

• Transport Encryption: All data transmitted between your device and pub202 servers is protected by TLS 1.2 or TLS 1.3 encryption (256-bit). The connection is authenticated by a valid SSL certificate — verifiable by the padlock icon in your browser address bar when accessing pub202.club;
• Data-at-Rest Encryption: Personal data and sensitive financial records stored on pub202 servers are encrypted using AES-256 at rest;
• Password Security: Account passwords are stored as salted cryptographic hashes using industry-standard algorithms. pub202 never stores plain-text passwords and cannot retrieve your password — only reset it;
• Two-Factor Authentication: pub202 offers 2FA via OTP to your registered Philippine mobile number. Enabling 2FA is strongly recommended for all accounts;
• Intrusion Detection: pub202's infrastructure includes automated intrusion detection systems that monitor for unusual access patterns, unauthorized login attempts, and anomalous data extraction activities.

8.2 Organizational Safeguards

• Access to personal data is restricted to pub202 personnel on a strict need-to-know basis, enforced through role-based access controls;
• All pub202 employees and contractors who handle personal data are bound by confidentiality agreements and receive data privacy training;
• pub202 conducts periodic internal security assessments and engages third-party security experts for penetration testing;
• A data breach response plan is maintained, including notification procedures to the NPC and affected Data Subjects within the timeframes required by R.A. 10173.

pub202 uses cookies, web beacons, local storage objects, and similar technologies on pub202.club. This section explains how and why we use these technologies and how you can manage them.

9.1 Types of Cookies Used

9.2 Managing Cookies

You can manage or delete cookies through your browser settings. Most browsers allow you to refuse new cookies, accept or reject specific cookies, and delete existing cookies. Instructions for managing cookies are available in your browser's help documentation. Note that disabling essential cookies may prevent you from logging in to or using core pub202 features.

pub202 does not use third-party advertising cookies or cross-site tracking technologies for targeted advertising purposes. Analytics cookies used by pub202 are configured with IP anonymization enabled.

As a Data Subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pub202. To exercise any of these rights, contact pub202 Customer Support in writing via email to [email protected], marking your communication as a Data Subject Access Request (DSAR).

Right to Be Informed

You have the right to be informed about how pub202 collects, uses, retains, and shares your personal data. This Privacy Policy is pub202's fulfilment of this obligation. You may request a copy of this Policy in alternative formats if needed.

Right of Access

You have the right to request a copy of the personal data pub202 holds about you, including the categories of data held, the purposes for which it is processed, and the recipients with whom it has been shared. pub202 will provide this information within thirty (30) calendar days of a verified DSAR.

Right to Correction

If any personal data pub202 holds about you is inaccurate, incomplete, or outdated, you have the right to request correction. For minor corrections (e.g., email address, mobile number), you may update these directly in your account settings. For corrections to KYC-verified data (e.g., legal name, date of birth), you must submit supporting documentation.

Right to Erasure or Blocking

You have the right to request the deletion or blocking of your personal data where: the data is no longer necessary for the purposes for which it was collected; you withdraw consent and there is no other legal basis for processing; or the data has been unlawfully processed. Note that pub202 may be required to retain certain data for the mandatory periods described in Section 7, in which case blocking (restriction of processing) rather than deletion may be the appropriate remedy.

Right to Object

You have the right to object to processing of your personal data for marketing communications, profiling, or other purposes where processing is based on legitimate interest. Objecting to processing required for contract performance or legal obligations may affect pub202's ability to provide services to you.

Right to Data Portability

Where technically feasible, you may request that pub202 provide your personal data in a structured, commonly used, and machine-readable format. pub202 will provide available data in CSV or equivalent format within thirty (30) days of a verified portability request.

Right to Lodge a Complaint

If you believe pub202 has processed your personal data in violation of R.A. 10173, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Complaints to the NPC may be submitted through the NPC's official channels. pub202 encourages you to first contact us directly to attempt resolution before escalating to the NPC.

pub202 is an online gaming platform exclusively for persons who are twenty-one (21) years of age or older, in compliance with PAGCOR regulations governing online gambling in the Philippines. pub202 does not knowingly collect personal data from any person under the age of 21, and specifically does not knowingly process personal data belonging to minors (persons under 18 years of age).

During the registration process, pub202 collects date of birth information and verifies it against government-issued identification during KYC. Any account found to have been registered by or used by a person under 21 years of age will be closed immediately, all associated personal data will be deleted except where retention is required for regulatory reporting purposes, and the matter may be reported to relevant Philippine authorities.

If you are a parent or guardian and believe that a minor in your care has registered an account on pub202, please contact Customer Support immediately via live chat or email. pub202 will investigate and take appropriate action, including account closure and data deletion, within 48 hours of a verified notification.

In the course of providing its services, pub202 may transfer your personal data to recipients located outside the Philippines — for example, to cloud infrastructure providers, game content servers, or KYC processing partners whose servers are located in other jurisdictions.

Where such transfers occur, pub202 ensures that appropriate safeguards are in place to protect your personal data in accordance with R.A. 10173, including:

• Requiring recipient organizations to maintain data protection standards equivalent to those required under Philippine law, through contractual Data Processing Agreements or equivalent binding mechanisms;
• Transferring only the minimum data necessary for the specific purpose of the transfer;
• Ensuring that international cloud and infrastructure providers used by pub202 are certified under internationally recognized security standards (e.g., ISO 27001, SOC 2 Type II).

The primary jurisdictions to which pub202 may transfer data include cloud infrastructure regions in Asia-Pacific and Southeast Asia. pub202 does not transfer your personal data to countries that the NPC has determined do not provide adequate data protection equivalent to Philippine standards without implementing supplementary safeguards.

pub202 reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in our data processing practices, new legal or regulatory requirements, or improvements to our platform. The "Effective Date" at the top of this page indicates when the current version took effect.

Where changes to this Policy are material — meaning they significantly affect your rights, the categories of data collected, the purposes of processing, or the parties with whom data is shared — pub202 will provide notice by:

• Displaying a prominent notice on pub202.club;
• Sending a notification to your registered mobile number or email address at least fourteen (14) days before the updated Policy takes effect.

Your continued use of the pub202 Platform after the effective date of an updated Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree to a material change, you may request account closure before the updated Policy takes effect.

For any questions, concerns, data subject access requests, or complaints relating to this Privacy Policy or pub202's handling of your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 through the pub202.club Platform — the chat icon appears in the lower right corner of all pages. Agents in English are available from 8:00 AM to 12:00 midnight PHT daily.
• Email (Privacy and Data Requests): [email protected] — please mark your communication with the subject line "Data Privacy Request" or "DSAR" to ensure it is routed to the correct team.

pub202 will acknowledge receipt of all written privacy requests within three (3) business days and will provide a substantive response within thirty (30) calendar days of verifying your identity, as required by R.A. 10173.

If you are not satisfied with pub202's response to your privacy complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. The NPC's contact information and complaint procedures are available on the NPC's official government website.