About This Privacy Policy
This Privacy Policy ("Policy") describes how pub 202 ("the Platform," "we," "us," "our") collects, uses, stores, and protects the personal data of individuals ("Data Subjects," "Players," "you") who access or use the pub 202 platform at pub202.one. This Policy is issued in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations. By registering and using pub 202, you acknowledge that you have read and understood this Policy.
1 Introduction
1.1 pub 202 respects the privacy of every Filipino player who uses our platform. We understand that your personal data belongs to you, and we are committed to handling it with care, transparency, and in accordance with your rights under Philippine law.
1.2 This Policy applies to all personal data collected by pub 202 through the use of the pub202.one website, including account registration, deposits, withdrawals, gameplay, customer support interactions, and any other services provided by the Platform.
1.3 This Policy should be read together with the pub 202 Terms & Conditions. In the event of a conflict between this Policy and the Terms & Conditions on a privacy-related matter, this Policy shall prevail.
2 Data Controller
2.1 For the purposes of the Philippine Data Privacy Act of 2012, pub 202 is the personal information controller responsible for the personal data collected through the Platform.
2.2 pub 202 operates in compliance with applicable PAGCOR regulations and the requirements of the National Privacy Commission of the Philippines. Our Data Protection Officer can be contacted via the live chat support system available on the pub 202 platform.
3 Personal Data We Collect
3.1 pub 202 collects personal data in the following categories:
3.1 Registration and Identity Data
- Full legal name as it appears on a Philippine government-issued ID;
- Date of birth (used to verify that you meet the 21+ age requirement);
- Philippine mobile number (used as your primary account identifier and for OTP verification);
- Email address, where voluntarily provided;
- Username and encrypted password.
3.2 KYC and Verification Data
- Government-issued ID document (SSS card, PhilHealth card, Driver's License, or Passport) — collected for identity and age verification before withdrawals are processed;
- Selfie or liveness verification image where required by our KYC process;
- Proof of payment method ownership where applicable.
3.3 Financial Transaction Data
- Deposit and withdrawal history (amount, date, payment method, status);
- GCash, PayMaya, or bank account reference numbers associated with transactions;
- Wallet balance history.
3.4 Gaming Activity Data
- Game session records (game title, date, duration, bets placed, outcomes);
- Bonus claim and wagering history;
- Responsible gaming settings and tool activations (deposit limits, self-exclusion events).
3.5 Technical and Device Data
- IP address at the time of login and major account actions;
- Device type, operating system, and browser version;
- Session timestamps and duration;
- Cookie data as described in Section 10.
3.6 Communications Data
- Live chat transcripts when you contact pub 202 support;
- Dispute or complaint submissions.
4 How pub 202 Uses Your Personal Data
| Purpose | Data Used |
|---|---|
| Account creation and management | Registration data, mobile number, username |
| Identity and age verification (KYC) | Government ID, selfie, date of birth |
| Processing deposits and withdrawals | Financial transaction data, KYC data |
| Delivering gaming services | Gaming activity data, wallet balance |
| Fraud prevention and AML compliance | Financial data, IP data, identity data |
| Customer support | Communications data, account data |
| Responsible gaming monitoring | Gaming activity, responsible gaming tool data |
| Platform security and fraud detection | IP address, device data, session data |
| Regulatory reporting to PAGCOR | Identity data, financial data as required by law |
| Service improvement and analytics | Aggregated, anonymized gaming and technical data |
4.1 pub 202 does not use your personal data for unsolicited third-party marketing. Any promotional communications from pub 202 relate to our own platform services and may be opted out of at any time via your account settings or by contacting our support team.
5 Legal Basis for Processing
5.1 pub 202 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:
- Contractual necessity — Processing required to fulfill the agreement between you and pub 202 (account registration, game delivery, payment processing);
- Legal obligation — Processing required to comply with PAGCOR regulations, Philippine AML law, and other applicable legal requirements (KYC, transaction monitoring, regulatory reporting);
- Legitimate interests — Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your privacy rights;
- Consent — Where we rely on consent for specific processing activities (such as optional marketing communications), you may withdraw consent at any time without affecting the lawfulness of prior processing.
6 Sharing of Personal Data
6.1 pub 202 does not sell, rent, or trade your personal data to third parties for marketing purposes. Your personal data may be shared with the following categories of recipients only where necessary and under appropriate data protection arrangements:
- Payment processors (GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency processors) — to process deposits and withdrawals on your behalf;
- KYC verification providers — to verify your identity and age in compliance with PAGCOR and Philippine AML requirements;
- Game software providers — receive session identifiers necessary to deliver certified games; these providers do not receive your full personal profile;
- Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement authorities, where disclosure is required by law;
- IT and security service providers — cloud infrastructure, cybersecurity, and fraud detection vendors engaged by pub 202 under contractual data processing agreements.
6.2 All third-party service providers engaged by pub 202 are required to process personal data in accordance with this Policy and applicable Philippine data protection law. pub 202 does not permit service providers to use your data for their own independent purposes.
7 Data Retention
7.1 pub 202 retains personal data for the period necessary to fulfil the purposes described in this Policy, subject to the following minimum retention requirements:
- Account and KYC records — Retained for a minimum of five (5) years following account closure, in compliance with Philippine AML and gaming regulatory requirements;
- Financial transaction records — Retained for a minimum of five (5) years from the date of each transaction;
- Gaming activity records — Retained for a minimum of three (3) years from the date of each gaming session;
- Customer support communications — Retained for two (2) years from the date of the interaction, unless the communication forms part of an open dispute or regulatory matter;
- Self-exclusion records — Retained indefinitely to ensure that self-excluded players are not re-admitted to the Platform in breach of their exclusion request.
7.2 Following the expiry of applicable retention periods, personal data will be securely deleted or anonymized in a manner that prevents re-identification.
8 Data Security
Technical Security Measures
pub 202 implements 256-bit SSL encryption for all data in transit, AES-256 encryption for sensitive data at rest, role-based access controls limiting internal data access to authorized personnel, and continuous security monitoring of platform infrastructure.
8.1 pub 202 maintains technical and organizational security measures designed to protect your personal data against unauthorized access, loss, destruction, or disclosure. These measures are reviewed and updated on a regular basis in line with industry standards.
8.2 Access to personal data within pub 202 is restricted on a need-to-know basis. Staff who access personal data in the course of their duties are subject to confidentiality obligations.
8.3 In the event of a personal data breach that poses a risk to your rights and freedoms, pub 202 will notify the National Privacy Commission of the Philippines within 72 hours of becoming aware of the breach, and will notify affected Data Subjects as required by the DPA and its implementing regulations.
8.4 While pub 202 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your pub 202 account credentials and for reporting any suspected unauthorized access to our support team immediately.
9 Your Data Subject Rights
9.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pub 202:
Right to Be Informed
You have the right to be informed about the collection and processing of your personal data. This Privacy Policy is our primary means of fulfilling that obligation.
Right of Access
You have the right to request a copy of the personal data pub 202 holds about you. Requests will be fulfilled within 15 business days of identity verification.
Right to Rectification
You have the right to have inaccurate or incomplete personal data corrected. Contact pub 202 support with the correct information and any supporting documentation.
Right to Erasure
You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected. Note that erasure may be limited by legal retention obligations (Section 7).
Right to Object
You have the right to object to the processing of your personal data where pub 202 relies on legitimate interests as the legal basis. pub 202 will assess whether compelling legitimate grounds exist to continue processing.
Right to Data Portability
You have the right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible and where processing is based on consent or contract.
Right to Lodge a Complaint
If you believe pub 202 has processed your personal data in breach of the Philippine DPA, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.
9.2 To exercise any of the above rights, contact the pub 202 support team via the live chat system available on the Platform. We will verify your identity before processing any data subject request to protect against unauthorized access to personal data.
10 Cookies and Tracking Technologies
10.1 pub 202 uses cookies and similar tracking technologies to operate the Platform, maintain your session, detect fraud, and improve the user experience. The following categories of cookies are used:
- Strictly Necessary Cookies — Required for the Platform to function (session management, authentication, security). These cannot be disabled without breaking core Platform functionality.
- Functional Cookies — Remember your preferences and settings (language, lobby layout, responsible gaming settings).
- Analytics Cookies — Collect aggregated, anonymized data about how Players use the Platform to support product improvement. Individual Players are not identified.
- Security Cookies — Used in fraud detection and bot prevention systems to protect the Platform and its Players.
10.2 pub 202 does not use third-party advertising cookies or behavioral tracking cookies for the purposes of serving ads on external websites.
10.3 You may configure your browser to reject or delete cookies; however, doing so may affect the functionality of the pub 202 platform, including the ability to remain logged in during your session.
11 Minors and Age Restriction
Strict 21+ Age Policy
pub 202 services are strictly available to individuals aged 21 years and older per PAGCOR regulations. pub 202 does not knowingly collect personal data from individuals under 21. Where an account is identified as belonging to a person under 21, the account will be closed and all personal data deleted, with deposited funds returned.
11.1 pub 202 implements KYC age verification to prevent registration by individuals under 21. If you have reason to believe that a person under 21 has registered on pub 202, please contact our support team immediately so that we can investigate and take appropriate action.
12 Updates to This Privacy Policy
12.1 pub 202 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. All updates will be published on this page with a revised effective date.
12.2 For material changes that significantly affect how your personal data is processed, pub 202 will provide advance notice via the Platform's notification system or via any email address registered on your account, where applicable.
12.3 Continued use of the pub 202 platform following the publication of an updated Privacy Policy constitutes your acceptance of the revised Policy. We encourage you to review this page periodically.
13 Contact and Data Subject Requests
13.1 For any privacy-related queries, data subject access requests, rectification requests, deletion requests, or complaints regarding pub 202's data handling practices, please contact us through the 24/7 live chat support system available on the pub 202 platform.
13.2 Our support team, including our Data Protection Officer, is available in both Filipino and English. Data subject requests will be acknowledged within 3 business days and resolved within 15 business days of identity verification, in accordance with the Philippine Data Privacy Act of 2012.
13.3 For formal regulatory complaints, you may also contact the National Privacy Commission of the Philippines directly.