202pub Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how 202pub ("the Company", "we", "us", "our") collects, uses, stores, and protects the personal data of users ("Player", "you", "your") who access or use the 202pub platform at 202pub.app and all associated services (collectively, the "Platform").

202pub is committed to protecting your privacy and handling your personal data with transparency, integrity, and in full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

By registering an account, accessing the Platform, or otherwise providing your personal data to 202pub, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

02 Data Controller

For the purposes of the Data Privacy Act of 2012, 202pub acts as the Personal Information Controller (PIC) in respect of the personal data it collects from players and website visitors. This means 202pub determines the purposes and means of processing your personal data.

Where 202pub engages third-party service providers to process personal data on its behalf — such as payment processors, game providers, and identity verification services — those parties act as Personal Information Processors (PIPs) and are contractually bound to process data only on 202pub's documented instructions and in accordance with applicable data protection law.

202pub has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection legislation. Contact details for the DPO are provided in Section 14 of this Policy.

03 Personal Data We Collect

3.1 Data You Provide Directly

When you register for a 202pub account or interact with the Platform, we collect the following categories of personal data that you provide to us:

• Identity Data: Full legal name, date of birth, gender, nationality.
• Contact Data: Email address, mobile number, residential address (including city, province, and postal code).
• Identity Verification Data: Government-issued photo ID (e.g., Philippine passport, PhilSys ID, SSS ID, driver's licence), selfie or liveness check image, proof of address documents.
• Financial Data: GCash account number, Maya account details, bank account details (for withdrawal processing), transaction history.
• Account Credentials: Username and encrypted password hash.
• Communications Data: Records of your correspondence with our customer support team, including live chat transcripts and email exchanges.

3.2 Data Collected Automatically

When you access the Platform, we automatically collect certain technical and behavioural data, including:

• Device & Technical Data: IP address, device type, operating system, browser type and version, screen resolution, device identifiers.
• Usage Data: Pages visited, games played, betting history, session duration, click-stream data, search queries within the Platform.
• Location Data: Approximate geographic location derived from your IP address, used for regulatory compliance and fraud prevention.
• Cookie Data: Data collected via cookies and similar tracking technologies as described in Section 7.

3.3 Data from Third Parties

We may receive personal data about you from third parties in the following circumstances:

• Identity verification and KYC service providers who confirm the authenticity of your identity documents.
• Payment processors who confirm the status and details of your deposit and withdrawal transactions.
• Fraud prevention and anti-money laundering screening services.
• PAGCOR and other regulatory bodies, where required by law.

04 How We Use Your Personal Data

202pub uses your personal data for the following purposes:

202pub will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

05 Legal Basis for Processing

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

• Contractual Necessity: Processing required to perform our contract with you — i.e., to operate your account, process transactions, and provide gaming services.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including PAGCOR licensing conditions, AML obligations, and NPC requirements.
• Legitimate Interests: Processing necessary for 202pub's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights and freedoms.
• Consent: Where we rely on your consent as the legal basis for processing — such as for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

06 Data Sharing and Disclosure

6.1 Service Providers

202pub shares personal data with carefully selected third-party service providers who assist us in operating the Platform. These include:

• Payment processors and e-wallet providers (GCash, Maya, and Philippine banking partners) for transaction processing.
• Identity verification and KYC service providers for document authentication and age verification.
• Game content providers and software licensors who supply the games available on the Platform.
• Cloud hosting and infrastructure providers who store Platform data on secured servers.
• Customer support platform providers who facilitate live chat and ticketing services.
• Fraud detection and cybersecurity service providers.

All third-party service providers are bound by data processing agreements that require them to maintain appropriate security measures and process personal data only as instructed by 202pub.

6.2 Regulatory and Legal Disclosure

202pub may disclose your personal data to regulatory authorities, law enforcement agencies, or courts where required to do so by applicable Philippine law, including but not limited to:

• PAGCOR, in connection with our gaming licence obligations.
• The Anti-Money Laundering Council (AMLC), as required under the Anti-Money Laundering Act.
• The National Privacy Commission (NPC), in connection with data breach notifications or regulatory enquiries.
• Philippine courts or law enforcement agencies, pursuant to a valid legal order or warrant.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 202pub's assets, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and the privacy practices of the successor entity prior to the transfer taking effect.

07 Cookies & Tracking Technologies

202pub uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyse usage patterns, and support security functions. The types of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, preferred games, and display options to personalise your experience.
• Analytics Cookies: Collect aggregated, anonymised data about how players use the Platform, helping us identify areas for improvement. No personally identifiable information is included in analytics reports.
• Security Cookies: Used for fraud detection, bot prevention, and to protect the integrity of the Platform and player accounts.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. 202pub does not use third-party advertising or behavioural tracking cookies.

08 Data Retention

202pub retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following retention periods:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and AML regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC and Identity Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Customer Support Records: Retained for three (3) years from the date of the last interaction.
• Usage and Analytics Data: Retained in anonymised, aggregated form indefinitely for platform improvement purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with 202pub's data disposal procedures.

09 Data Security

202pub implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 202pub Platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Multi-factor authentication (MFA) options for player accounts.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Role-based access controls ensuring that 202pub staff can only access personal data necessary for their specific job functions.
• Continuous security monitoring and intrusion detection systems.
• Regular staff training on data protection and information security best practices.

While 202pub takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the security of your own account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

10 Your Data Subject Rights

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

• Right to be Informed: The right to be informed of how your personal data is being collected and processed — which is the purpose of this Policy.
• Right of Access: The right to request a copy of the personal data 202pub holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• 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, machine-readable format and to transmit it to another controller.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission if you believe your data protection rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 14. We will respond to all verified requests within thirty (30) days. In complex cases, this period may be extended by a further thirty (30) days, and you will be notified accordingly.

11 Children's Privacy and Age Restriction

The 202pub Platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations governing casino-style gambling in the Philippines. 202pub does not knowingly collect personal data from individuals under the age of 21.

If you are under 21 years of age, you are not permitted to register for or use the 202pub Platform. If 202pub becomes aware that it has inadvertently collected personal data from a person under the age of 21, that account will be immediately suspended and the personal data will be deleted as soon as practicable.

If you are a parent or guardian and believe that your child has registered on the 202pub Platform, please contact us immediately at the details provided in Section 14 so that we can take appropriate action.

12 International Data Transfers

202pub primarily stores and processes personal data on servers located within the Philippines or in jurisdictions that provide an adequate level of data protection as recognised by the National Privacy Commission.

Where personal data is transferred to a third-party service provider located outside the Philippines — for example, a cloud infrastructure provider or game content supplier — 202pub ensures that appropriate safeguards are in place, including:

• Contractual clauses that require the recipient to protect personal data to a standard equivalent to that required under Philippine law.
• Verification that the recipient jurisdiction provides an adequate level of data protection.
• Binding corporate rules where the recipient is part of the same corporate group as 202pub.

By using the 202pub Platform, you acknowledge and consent to the transfer of your personal data to jurisdictions outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

13 Updates to This Privacy Policy

202pub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where changes are material — meaning they significantly affect your rights or how we process your personal data — we will notify you by email to your registered address and/or by a prominent notice on the Platform at least fourteen (14) days before the changes take effect.

Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree to the amended Policy, you must cease using the Platform and may request account closure.

14 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 202pub, please contact our Data Protection Officer:

• Data Protection Officer, 202pub
• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the Platform
• Response Time: We aim to acknowledge all data subject requests within five (5) business days and to respond fully within thirty (30) days.

If you are not satisfied with our response to your data protection concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint is available on the NPC's official website.