202pub Privacy Policy

1. Introduction and Scope

This Privacy Policy (hereinafter referred to as the "Policy") is issued by 202pub (hereinafter referred to as "202pub," "we," "us," or "the Platform"), the operator of the online gaming platform accessible at https://202pub.cam, including its mobile interfaces, subdomains, and associated digital services. This Policy governs the collection, processing, storage, and disclosure of personal information relating to all individuals who access or use the 202pub platform, including registered members, prospective members, and general visitors (collectively referred to as "Data Subjects" or "you").

202pub is committed to protecting the privacy and personal data of its users in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations issued by the National Privacy Commission (NPC), and all other applicable data protection legislation. This Policy has been prepared with reference to the NPC's Circular on Privacy Notices and has been designed to give you clear, accurate, and complete information about how your personal data is handled.

This Policy should be read together with the 202pub Terms & Conditions and the Responsible Gaming Policy. By creating an account or continuing to use the 202pub platform, you confirm that you have read this Policy and consent to the data practices it describes. If you do not agree with any part of this Policy, you must discontinue use of the platform.

2. Personal Data We Collect

202pub collects personal information from you in several ways: directly when you provide it to us during registration, verification, or support interactions; automatically when you use the platform; and from third parties where this is permitted by law. The categories of personal data we collect include the following:

2.1 Identity and Contact Information

Collected at registration and during KYC verification. This includes your full legal name, date of birth, gender, nationality, residential address (including province and city, e.g., Makati, Quezon City, Cebu City), email address, and mobile phone number. You must provide accurate and current information in all fields.

2.2 Identity Verification Documents

For KYC compliance and age verification, we may collect copies of government-issued identification documents including Philippine passports, SSS IDs, UMID cards, driver's licences, and Philippine National IDs. We may also collect proof of address documents such as utility bills or bank statements issued within the past three months.

2.3 Financial and Transaction Data

We collect details of your financial transactions on the platform, including deposits, withdrawals, wagers placed, game results, bonus activity, and account balances. We also collect payment method identifiers, such as your GCash-linked mobile number, PayMaya account reference, or bank account details for BPI, BDO, or Metrobank transfers. We do not store full bank account credentials — payment processing is handled through secure payment gateways.

2.4 Usage and Technical Data

When you access the 202pub platform, we automatically collect technical data including your IP address, browser type and version, device type and operating system, session duration, pages and games accessed, clickstream data, and referring URL. This data is collected through server logs and cookies (see Section 6).

2.5 Communications Data

If you contact 202pub's customer support team via live chat or email, we retain a record of those communications, including the content of messages and the date and time of each interaction. This data is used to manage your support requests and to improve our service quality.

2.6 Responsible Gaming Data

Where you use 202pub's responsible gaming tools — such as deposit limits, session timers, cooling-off periods, or self-exclusion — we record the settings you apply and the dates on which they were activated or modified. This data is essential for enforcing your responsible gaming preferences and for our compliance with PAGCOR responsible gaming requirements.

3. How We Use Your Personal Data

202pub processes your personal data for the following specific purposes:

• Account Creation and Management: To create and administer your 202pub account, verify your identity and age, manage your account settings, and communicate with you regarding your account status.
• Service Delivery: To provide access to games, live dealer tables, sports betting, and all other features of the 202pub platform, and to process deposits and withdrawal requests.
• KYC and Anti-Money Laundering Compliance: To verify your identity and age in compliance with PAGCOR licensing requirements and the Philippine Anti-Money Laundering Act (AMLA), and to monitor transactions for suspicious activity as required by law.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, multi-accounting, bonus abuse, and any other activity that violates the 202pub Terms & Conditions or applicable law.
• Responsible Gaming: To enforce responsible gaming tools you have activated on your account, to identify players who may be exhibiting signs of problem gambling, and to take appropriate protective action as required under PAGCOR guidelines.
• Customer Support: To respond to your support requests, resolve disputes, and improve the quality of our support services based on interaction data.
• Marketing and Promotions: Where you have provided consent, to send you promotional communications regarding 202pub bonuses, new games, tournaments, and other offers. You may withdraw this consent at any time.
• Platform Improvement: To analyse usage patterns, identify technical issues, and make improvements to the platform's performance, usability, and game selection.
• Legal Compliance: To comply with all applicable Philippine laws, regulations, court orders, and requests from competent authorities including PAGCOR, the NPC, and the Anti-Money Laundering Council (AMLC).

4. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 202pub must have a lawful basis for processing your personal data. The legal bases on which we rely are as follows:

• Contractual Necessity: Processing your identity information, transaction data, and KYC documents is necessary for the performance of the contract between you and 202pub as set out in the Terms & Conditions. Without this processing, we cannot provide you with a 202pub account or gaming services.
• Consent: For marketing communications, non-essential cookies, and any processing that is not strictly necessary for the provision of services, we rely on your freely given, informed, and specific consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Legal Obligation: Certain processing activities, particularly KYC verification, transaction monitoring, and record-keeping, are required by Philippine law, including the AMLA, PAGCOR regulations, and the Data Privacy Act itself.
• Legitimate Interests: 202pub processes certain technical and usage data on the basis of its legitimate interest in preventing fraud, securing the platform, improving user experience, and operating a compliant gaming business. These interests are balanced against your rights and are not overridden by your fundamental privacy interests.

5. Data Sharing and Disclosure

202pub does not sell your personal data to third parties. We do not share your personal information with external parties for their own marketing purposes. We disclose your personal data only in the following limited circumstances:

5.1 Service Providers and Data Processors

We engage carefully selected third-party service providers who process personal data on our behalf as data processors. These include payment processing partners (GCash, PayMaya, BPI, BDO, Metrobank), identity verification service providers, cloud infrastructure providers, customer support platform providers, and game software licensors (such as JILI, Pragmatic Play, and Evolution Gaming). All such processors are bound by data processing agreements that require them to handle your data securely, use it only for the purposes we specify, and comply with the Philippine Data Privacy Act.

5.2 Regulatory and Law Enforcement Authorities

202pub will disclose personal data to PAGCOR, the NPC, the AMLC, Philippine law enforcement agencies, and any other competent authority where required to do so by law, court order, or regulatory direction. Such disclosures are made strictly within the scope required and are logged for audit purposes.

5.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 202pub's business, your personal data may be transferred to the acquiring entity as part of the transaction. We will notify you of any such transfer and the identity of the new data controller as required by applicable law.

6. Cookies and Tracking Technologies

6.1 What Are Cookies

Cookies are small text files placed on your device by a website when you visit it. They are widely used to make websites work efficiently, to remember user preferences, and to provide analytical information to website operators. 202pub uses cookies and similar technologies including web beacons and local storage objects.

6.2 Categories of Cookies We Use

• Strictly Necessary Cookies: Essential for the operation of the 202pub platform. These include session management cookies that keep you logged into your account. They cannot be disabled without breaking core platform functionality.
• Functional Cookies: Used to remember your preferences such as language settings, display options, and responsible gaming tool settings. Disabling these cookies may affect your user experience.
• Analytical Cookies: Used to collect aggregate data about how players use the platform, which games are most popular, and where technical errors occur. This data helps us improve the platform. We use only privacy-respecting analytics tools and do not share individual-level analytical data externally.
• Security Cookies: Used to detect and prevent fraudulent account access, bot activity, and other security threats. These are strictly necessary and cannot be disabled.

6.3 Managing Cookies

You can control non-essential cookies through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or be notified when a new cookie is set. Please note that disabling certain cookies may prevent you from accessing some features of the 202pub platform. Strictly necessary and security cookies cannot be controlled through cookie preferences as they are essential for the platform's operation.

7. Data Retention

202pub retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. Our data retention periods are as follows:

• Account and Identity Data: Retained for the duration of your account's active status and for a minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and anti-money laundering regulations.
• Transaction and Financial Data: Retained for a minimum of five (5) years following the date of each transaction, in compliance with AMLA record-keeping requirements.
• KYC Documents: Retained for the duration of your account and for five (5) years following account closure. Copies are securely destroyed upon expiry of the retention period in accordance with NPC guidelines on data disposal.
• Support Communications: Retained for two (2) years from the date of the last communication, or until the matter to which they relate is fully resolved, whichever is later.
• Technical and Usage Logs: Retained for twelve (12) months in standard operational logs, with aggregated analytical data retained indefinitely in anonymised form.
• Self-Exclusion Records: Retained for the duration of the self-exclusion period and for five (5) years thereafter, to prevent re-registration by self-excluded players.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be linked to an identifiable individual. Where data must be retained for legal reasons beyond the standard retention period, it is held in a restricted access environment and marked for deletion as soon as the legal hold expires.

8. Data Security

202pub implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, and destruction. Our security framework includes the following:

• Encryption in Transit: All data transmitted between your browser or device and the 202pub platform is encrypted using Transport Layer Security (TLS) with a minimum cipher strength of TLS 1.2. HTTPS is enforced across all pages and API endpoints.
• Encryption at Rest: Sensitive personal data, including KYC documents and payment method references, is stored in encrypted form. Encryption keys are managed through secure key management systems with restricted access.
• Access Controls: Access to personal data within 202pub's systems is restricted on a need-to-know basis. Staff are granted the minimum level of access required for their role. All access to personal data systems is logged and regularly audited.
• Password Security: Account passwords are stored in hashed form using industry-standard one-way hashing algorithms. 202pub does not store passwords in plain text or reversible encrypted form. We recommend that players use strong, unique passwords and enable any available two-factor authentication features.
• Security Monitoring: 202pub's systems are monitored continuously for intrusion attempts, anomalous access patterns, and other security events. Security incidents are investigated promptly and resolved in accordance with our incident response procedures.
• Data Breach Notification: In the event of a personal data breach that poses a risk to your rights and freedoms, 202pub will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach and will inform affected players without undue delay.

9. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 202pub. These rights may be exercised by contacting our Data Protection Officer (see Section 13).

202pub will respond to all valid data subject requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further sixty (60) days with notice to you. We may require you to verify your identity before processing certain requests to ensure the security of your data.

10. Children's Privacy and Underage Access

The 202pub platform is strictly for adults aged 21 years and above, in compliance with PAGCOR's age requirements for online gaming in the Philippines. 202pub does not knowingly collect personal data from persons under the age of 21. All registration processes include mandatory age declaration, and 202pub enforces age verification through KYC procedures before processing any withdrawal.

If 202pub becomes aware that it has collected personal data from an individual under the age of 21, that account will be immediately suspended, any funds in the account will be handled in accordance with 202pub's underage player procedures, and the personal data will be deleted as soon as it is no longer required for investigation or legal compliance purposes.

If you are a parent or guardian and believe a minor in your care has registered an account on 202pub, please contact our support team immediately via live chat. We take underage gambling seriously and will act promptly on any such notification.

11. Cross-Border Data Transfers

Some of 202pub's service providers and technology partners are located outside the Philippines. Where personal data is transferred to recipients in other countries, 202pub ensures that appropriate safeguards are in place to protect your data, including:

• Data processing agreements incorporating the NPC's standard contractual clauses or equivalent data protection guarantees.
• Transfer only to countries or organisations that provide an adequate level of data protection as recognised by the National Privacy Commission.
• Implementing additional technical and organisational safeguards appropriate to the risk level of the transfer.

You may request information about the specific safeguards in place for cross-border transfers of your personal data by contacting our Data Protection Officer (see Section 13).

12. Changes to This Privacy Policy

202pub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory guidance. The most current version of this Policy will always be published at https://202pub.cam/privacy-policy. The "Last Updated" date at the top of this page will reflect the date of the most recent revision.

For material changes that significantly affect the way we collect or use your personal data, 202pub will provide advance notice via email to your registered email address or via an in-platform notification, where required by the Data Privacy Act or NPC guidelines. Your continued use of the platform following the posting of changes constitutes your acceptance of the revised Policy.

If you do not agree with any change to this Privacy Policy, you should stop using the platform and may request closure of your account by contacting our customer support team. Upon account closure, your personal data will be handled in accordance with the retention schedule described in Section 7 of this Policy.

13. Contact Information and Data Protection Officer

202pub has appointed a Data Protection Officer (DPO) as required under the Philippine Data Privacy Act of 2012. The DPO is responsible for overseeing 202pub's compliance with the Data Privacy Act, advising on data protection matters, and serving as the primary point of contact for data subject rights requests and privacy complaints.

To exercise any of the data subject rights described in Section 9 of this Policy, to submit a privacy-related complaint, or to enquire about any aspect of 202pub's data practices, please contact us through the following channels:

• Live Chat Support: Available 24/7 through the 202pub platform. For data privacy requests, please indicate "Data Privacy Request" at the start of your message and a specialist will handle your enquiry.
• Email (plain text — non-clickable): [email protected] — Please use the subject line "Data Privacy Request — [Your Full Name]" for all formal data subject requests.

202pub will acknowledge all data subject requests within five (5) business days of receipt. Full responses will be provided within the timeframes specified in Section 9.