pub202 Privacy Policy

01. Introduction & Scope

This Privacy Policy ("Policy") is issued by pub202 ("the Company," "we," "us," or "our") and applies to all personal information collected from individuals ("you," "the Player," or "the User") who access or use the pub202 platform ("the Platform") available at pub202.vip, including its mobile-optimized interface and Progressive Web App.

This Policy is designed to comply with the Republic of the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). It also reflects our responsibilities under applicable anti-money laundering laws and PAGCOR's requirements for licensed online gaming platforms.

By registering for a pub202 account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal information as described herein. This Policy should be read in conjunction with our Terms & Conditions.

02. Data Controller Identity

For the purposes of the Data Privacy Act of 2012, pub202 acts as the Personal Information Controller (PIC) in respect of the personal data collected from players using the Platform. pub202 determines the purposes and means of processing personal information submitted by or collected about Platform users.

Questions, requests, or complaints relating to this Policy or the processing of your personal data should be directed to pub202's Data Protection Officer (DPO), whose contact details are set out in Section 16 of this Policy.

03. Information We Collect

pub202 collects the following categories of personal information from players:

3.1 Registration & Identity Information

When you create a pub202 account, we collect:

• Full legal name (as it appears on your government-issued ID);
• Date of birth (used to verify you are 21 years of age or older);
• Gender;
• Residential address;
• Valid Philippine mobile number;
• Email address;
• Chosen username and encrypted password (passwords are never stored in plain text).

3.2 Identity Verification (KYC) Documents

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

• Copies of government-issued photo identification (PhilSys National ID, driver's license, passport, UMID, PRC ID, or equivalent);
• Proof of address documents (utility bills, bank statements, or equivalent);
• Selfie photographs for identity confirmation where required;
• Source of funds documentation for high-value accounts where required under applicable law.

3.3 Financial & Transaction Information

• GCash account details (mobile number linked to GCash) for deposit and withdrawal processing;
• Maya (PayMaya) account information;
• Bank account details (BPI, BDO, Metrobank, or similar) for bank transfer transactions;
• Cryptocurrency wallet addresses (for USDT transactions);
• Complete transaction history including deposits, withdrawals, wins, losses, and bonus activity;
• Partial payment card details (where card payments are used; full card numbers are never stored by pub202).

3.4 Usage & Behavioral Data

• Games played, bets placed, and gaming session durations;
• Login timestamps, session lengths, and logout times;
• Device type, operating system, and browser information;
• IP address and approximate geolocation;
• Platform navigation patterns and feature usage;
• Responsible gaming tool interactions (e.g., deposit limit changes, self-exclusion requests).

3.5 Communications Data

• Contents of messages sent to pub202 support via live chat or email;
• Responses to surveys or feedback forms;
• Records of any complaints or disputes and their resolution.

04. How We Collect Your Data

Collection Method	Data Collected
Account Registration Form	Name, date of birth, address, mobile number, email, username
KYC Submission	Government ID documents, selfie photos, address proof
Payment Processor Integration	GCash/Maya account reference, bank account details, USDT wallet
Platform Usage Tracking	Games played, session data, login history, IP addresses
Cookies & Tracking Technologies	Session cookies, analytics data, device fingerprinting
Support Interactions	Chat transcripts, email records, complaint details
Third-Party Verification Services	Identity verification confirmation from KYC providers

05. Legal Basis for Processing

pub202 processes personal information on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to provide the gaming services you have requested, including account management, payment processing, and game access;
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering obligations (AMLA), PAGCOR compliance requirements, and the NPC's data governance framework;
• Legitimate Interests: Processing is conducted to prevent fraud, protect the security of the Platform and its users, and improve the quality of our services;
• Consent: Where none of the above bases apply, we will seek your explicit consent before processing specific categories of data. You have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

06. How We Use Your Personal Information

pub202 uses collected personal information for the following purposes:

6.1 Account Operations

• Creating and maintaining your pub202 account;
• Authenticating your identity at login;
• Delivering the gaming services you have signed up for;
• Processing your deposits and withdrawals via GCash, Maya, BPI, BDO, and other supported payment methods;
• Managing your Loyalty Program tier status and Loyalty Points balance.

6.2 Regulatory Compliance

• Verifying that you meet the 21+ age requirement mandated by PAGCOR;
• Conducting Know Your Customer (KYC) and Anti-Money Laundering (AML) checks as required by Philippine law;
• Responding to requests from PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine authorities;
• Maintaining records as required under the Anti-Money Laundering Act and related regulations.

6.3 Security & Fraud Prevention

• Detecting and preventing unauthorized account access, identity fraud, and financial crime;
• Monitoring for unusual account activity or betting patterns that may indicate fraudulent behavior;
• Enforcing the one-account-per-player rule;
• Detecting and blocking attempts to circumvent self-exclusion restrictions.

6.4 Responsible Gaming

• Monitoring gaming behavior to identify potential problem gambling indicators;
• Administering deposit limits, session time alerts, loss limits, and self-exclusion tools;
• Contacting players where our monitoring systems suggest a responsible gaming concern.

6.5 Customer Support

• Responding to support inquiries via live chat and email;
• Resolving disputes regarding game outcomes, transactions, or account matters;
• Maintaining records of support interactions for quality assurance and dispute resolution purposes.

6.6 Platform Improvement

• Analyzing aggregated, de-identified usage data to improve Platform features and performance;
• Testing and debugging the Platform across different device types and network conditions;
• Understanding which games and features are most popular among players in the Philippines.

07. Data Sharing & Disclosure

pub202 may share your personal information in the following limited circumstances:

• Payment Processors: GCash (GXI Corp), Maya (Voyager Innovations), BPI, BDO, Metrobank, and other payment service providers receive the minimum information necessary to process your transactions. Each processor operates under its own privacy policy and applicable Philippine financial regulations.
• KYC & Identity Verification Providers: Third-party identity verification services engaged by pub202 to process government ID documents and conduct biometric checks receive the identity documents you submit during the KYC process. These providers are contractually bound to process such data exclusively for verification purposes.
• Game Content Providers: Software providers whose games are hosted on the pub202 Platform (including JILI, Pragmatic Play, PG Soft, and similar) receive a player identifier and relevant gaming data to facilitate game session delivery. They do not receive your name, contact details, or payment information.
• Regulatory & Law Enforcement Authorities: pub202 is legally obligated to disclose personal information to PAGCOR, the AMLC, the NPC, courts, or other competent Philippine authorities upon receipt of a lawful request, court order, or as otherwise required by Philippine law. pub202 will not notify you of such disclosures where it is legally prohibited from doing so.
• Professional Advisors: Lawyers, auditors, accountants, and similar professional advisors engaged by pub202 may access personal information to the extent necessary to provide their professional services, subject to applicable confidentiality obligations.
• Corporate Restructuring: In the event of a merger, acquisition, or sale of all or substantially all of pub202's assets, personal information held by pub202 may be transferred to the acquiring entity as part of the transaction, subject to the same data protection standards described in this Policy.

08. Cookies & Tracking Technologies

The pub202 Platform uses cookies and similar tracking technologies to enhance your experience and support Platform operations. A "cookie" is a small text file placed on your device by the Platform.

pub202 uses the following types of cookies:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in during an active session. These cannot be disabled without breaking Platform functionality.
• Performance & Analytics Cookies: Collect aggregated, de-identified data about how players interact with the Platform — which pages are most visited, how long sessions last, and which device types are used. This data is used solely to improve Platform performance.
• Security Cookies: Used to detect and prevent fraud, unauthorized access attempts, and other security threats. These contribute to the login location monitoring and anomalous activity detection systems.
• Preference Cookies: Store your Platform preferences such as language settings, display preferences, and notification settings so they persist between sessions.

You may disable non-essential cookies through your browser settings. Note that disabling certain cookies may impair some Platform features. pub202 does not currently use advertising cookies or cookies that track your activity across third-party websites.

09. Data Retention

pub202 retains personal information for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account information and KYC documents: Retained for a minimum of five (5) years following account closure, as required by Philippine anti-money laundering regulations;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction;
• Gaming session logs: Retained for a minimum of three (3) years;
• Support interaction records: Retained for a minimum of two (2) years from the date of the interaction;
• Self-exclusion records: Retained indefinitely to prevent the circumvention of exclusion restrictions.

Following the expiry of the applicable retention period, personal information is securely deleted or anonymized in accordance with pub202's data destruction procedures.

10. Data Security

pub202 implements a multi-layered security framework to protect the personal information of its players. The following technical and organizational measures are in place:

• Encryption in Transit: All data transmitted between your device and the pub202 Platform is encrypted using TLS 1.3 (256-bit SSL). This includes your login credentials, payment details, and all Platform interactions;
• Encryption at Rest: Sensitive personal data, including identity documents and payment references, is encrypted when stored in pub202's systems;
• Access Controls: Access to personal data within pub202's systems is restricted on a need-to-know basis. Staff with access to personal data are subject to confidentiality obligations and regular security training;
• Password Security: Passwords are never stored in plain text. pub202 uses industry-standard cryptographic hashing with salting for all stored passwords;
• Two-Factor Authentication: Available and recommended for all player accounts;
• Intrusion Detection: pub202's systems are monitored for unauthorized access attempts, unusual traffic patterns, and anomalous data access behaviors;
• Incident Response: pub202 maintains a data breach response procedure. In the event of a breach likely to result in a risk to your rights and freedoms, pub202 will notify affected players and the NPC in accordance with the Data Privacy Act's breach notification requirements.

11. Your Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal information held by pub202. These rights are subject to applicable legal exceptions and the proportionate application of our regulatory obligations.

• Right to be Informed: The right to be informed of how your personal data is collected and processed — which is fulfilled by this Privacy Policy;
• Right to Access: The right to request a copy of the personal information pub202 holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal information;
• Right to Erasure (Right to be Forgotten): The right to request deletion of your personal information where it is no longer necessary for the purposes for which it was collected, subject to our legal data retention obligations;
• Right to Object: The right to object to the processing of your personal data where processing is based on legitimate interests, unless pub202 has compelling grounds to continue processing;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe pub202 has not handled your personal data lawfully.

To exercise any of the above rights, please contact pub202's Data Protection Officer using the contact details in Section 16. pub202 will respond to substantiated requests within thirty (30) days of receipt. We may need to verify your identity before processing a data request.

12. Minors & Age Restriction

The pub202 Platform is strictly for individuals aged 21 years and above in accordance with PAGCOR's requirements for licensed online gaming in the Philippines. pub202 does not knowingly collect personal information from individuals under the age of 21.

If pub202 becomes aware that personal information has been collected from a person under 21 without verified parental or guardian consent, that information will be deleted promptly and the associated account will be closed. If you believe a minor has created a pub202 account, please contact us immediately at [email protected].

13. International Data Transfers

pub202's primary data infrastructure is operated within the Philippines. In limited circumstances — specifically in connection with third-party game providers, KYC verification platforms, or technical service providers — some personal data may be processed or stored outside the Philippines.

Where personal data is transferred outside the Philippines, pub202 takes appropriate steps to ensure that the receiving party provides an adequate level of data protection consistent with the Data Privacy Act of 2012. These steps include contractual data protection clauses, compliance assessments of the recipient's security practices, and limiting the scope of data transferred to the minimum necessary.

14. Third-Party Services & Links

The pub202 Platform integrates with third-party services — including payment processors (GCash, Maya, BPI, BDO), game software providers (JILI, Pragmatic Play, PG Soft), and identity verification providers — each of which operates under its own privacy policy. pub202 is not responsible for the privacy practices of these third-party services in respect of data processed under their own policies.

The Platform may contain links to informational pages or support resources. pub202 is not responsible for the privacy practices of any third-party website that you access through such links. This Policy applies exclusively to data processed by pub202 in connection with the Platform.

15. Amendments to This Policy

pub202 reserves the right to update or modify this Privacy Policy at any time. Where changes are material, we will endeavor to notify registered players by SMS to their registered mobile number or via an in-Platform notification. The updated Policy will be published on this page with a revised effective date.

Your continued use of the Platform following publication of a revised Policy constitutes acceptance of the changes. If you do not agree with material changes to this Policy, you should cease use of the Platform and request account closure through pub202 support.

16. How to Contact Us

For privacy-related inquiries, data subject access requests, or complaints, please contact pub202's Data Protection Officer. Contact details are provided below as plain text — these are not clickable links.