Privacy Policy – 202 pub Casino

1. Who We Are (Data Controller)

202 pub Casino, operating through the website 202pub.biz, is the Data Controller responsible for the personal data of registered users and visitors to the platform. We are a PAGCOR-regulated online gaming platform based in the Philippines, providing casino, sports betting, bingo, and related entertainment services to Filipino players.

As a Data Controller under the Philippine Data Privacy Act of 2012 (RA 10173), 202 pub determines the purposes and means of processing the personal data described in this Privacy Policy. For all privacy-related inquiries, our Data Protection Officer (DPO) can be reached via the contact details provided in Section 14 of this Policy.

2. Personal Data We Collect

202 pub collects the following categories of personal data from registered players and platform visitors:

Identity and Contact Data:

• Full legal name as it appears on your government-issued Philippine ID
• Date of birth (to verify the 21+ age requirement)
• Philippine mobile number (used for account access and OTP verification)
• Email address
• Residential address in the Philippines
• Government-issued ID numbers (e.g., PhilSys number, UMID, passport, or driver's license number)

Financial Data:

• GCash or Maya mobile wallet number linked to your account
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where applicable
• Transaction history including deposits, withdrawals, and bonus credits
• Source of funds declarations where required by PAGCOR Anti-Money Laundering (AML) regulations

Gaming and Behavioral Data:

• Game session history including games played, bets placed, and outcomes
• Login timestamps and session durations
• Bonus redemption and wagering history
• Responsible gaming tool usage (deposit limits set, self-exclusion requests)
• Player preferences and game category affinities

Technical Data:

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Cookie identifiers and session tokens
• Referral source (how you arrived at 202pub.biz)

Communications Data:

• Records of live chat, email, or other support interactions with the 202 pub team
• Responses to optional surveys or feedback forms
• Marketing preferences and opt-in/opt-out records

3. How We Collect Your Data

202 pub collects personal data through the following means:

• Direct collection: Data you provide when you register an account, complete identity verification, make a deposit or withdrawal request, contact support, or respond to a survey.
• Automated collection: Data collected automatically when you use the 202pub.biz platform, including through cookies, server logs, and analytics tools.
• Third-party sources: Data received from identity verification service providers, payment processors (e.g., GCash, Maya payment infrastructure), and fraud detection partners — used solely to fulfil our regulatory and service obligations.

4. How We Use Your Personal Data

202 pub processes your personal data for the following purposes:

• To create and maintain your 202 pub player account and authenticate your identity at each login
• To process deposits and withdrawals via GCash, Maya, and Philippine bank transfer channels
• To comply with PAGCOR KYC (Know Your Customer) requirements and verify that you meet the 21+ age requirement
• To comply with Anti-Money Laundering (AML) obligations under Philippine law, including the AMLA and its amendments
• To detect, investigate, and prevent fraud, cheating, collusion, or any other prohibited conduct on the platform
• To administer bonuses, promotions, and loyalty rewards in accordance with their applicable terms
• To provide customer support and resolve complaints or disputes
• To send you service communications (e.g., transaction confirmations, password reset emails, security alerts)
• To send you promotional communications, if you have opted in to receive them and have not subsequently opted out
• To improve the 202 pub platform through analytics, A/B testing, and player behavior research (using anonymized or aggregated data where possible)
• To administer responsible gaming tools such as deposit limits and self-exclusion requests

5. Legal Basis for Processing

Under the Philippine Data Privacy Act, 202 pub processes personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil our contractual obligations to you as a registered player, including account management, payment processing, and game access.
• Legal obligation: Processing required to comply with PAGCOR regulations, AML laws (AMLA RA 9160 as amended), and other applicable Philippine legal requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where our legitimate interests are not overridden by your rights and interests.
• Consent: Processing for marketing communications, where you have provided explicit opt-in consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

202 pub does not sell or rent your personal data. We may share your data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash (operated by GXI), Maya (operated by PayMaya Philippines), BPI, BDO, Metrobank, and other Philippine payment partners — to process financial transactions you initiate.
• Identity verification providers: Third-party KYC and document verification services used to confirm your identity and age as required by PAGCOR.
• Game providers: Licensed third-party game studios (e.g., PG Soft, Pragmatic Play, Jili) receive anonymized session data necessary to operate their games within the 202 pub platform.
• Fraud and security partners: Services that help 202 pub detect and prevent fraudulent activity, cheating, and unauthorized account access.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies when required by law or regulatory directive.
• Legal and professional advisers: Lawyers, accountants, and auditors engaged by 202 pub, subject to professional confidentiality obligations.

All third-party data processors engaged by 202 pub are subject to contractual data processing agreements that require them to handle your data in compliance with applicable Philippine privacy law and to use it only for the specified purpose of the engagement.

7. Cookies and Tracking Technologies

The 202pub.biz website uses cookies and similar tracking technologies to operate effectively and improve your experience. The cookies we use fall into the following categories:

• Strictly necessary cookies: Required for core platform functions such as maintaining your login session and processing secure transactions. These cannot be disabled without significantly degrading your ability to use 202 pub.
• Performance cookies: Used to collect anonymized data about how players navigate and use the platform — helping us identify pages that perform poorly and improve them.
• Functional cookies: Remember preferences such as your selected game category, language settings, and responsible gaming preferences to personalize your experience.
• Analytics cookies: Used with analytics services to understand aggregate player behavior patterns and assess the effectiveness of features and promotions. Data collected is anonymized or pseudonymized where possible.

You can control cookie preferences through your browser settings. Note that disabling non-essential cookies will not affect your ability to log in, play games, or make transactions at 202 pub.

8. Data Retention

202 pub retains personal data for the periods necessary to fulfil the purposes for which it was collected, subject to the following minimum retention requirements:

• Account and identity data: retained for the duration of your account plus a minimum of 5 years after account closure, as required by PAGCOR and AMLA compliance obligations.
• Transaction records: retained for a minimum of 5 years from the date of each transaction, in accordance with Philippine AML record-keeping requirements.
• Game session data: retained for 2 years from the date of the session, unless required for longer by an ongoing dispute or regulatory inquiry.
• Support and communications records: retained for 3 years from the date of the communication.
• Marketing consent records: retained for the duration of your account plus 1 year after account closure.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.

9. Data Security

202 pub implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure:

• TLS 1.3 encryption for all data transmitted between your device and our servers
• AES-256 encryption for sensitive data stored in our databases
• Multi-factor authentication (OTP via SMS) for all player account logins
• Role-based access controls ensuring only authorized personnel can access personal data
• Regular penetration testing and vulnerability assessments by independent security firms
• Intrusion detection systems and 24/7 security monitoring
• Staff data privacy training and binding confidentiality obligations

In the event of a personal data breach that is likely to result in a risk to your rights, 202 pub will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay where the breach is likely to result in a high risk to their rights and interests.

10. Your Data Protection Rights

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

• Right to be informed: The right to be told what personal data 202 pub collects, how it is used, and who it is shared with — as provided by this Privacy Policy.
• Right of access: The right to request a copy of the personal data 202 pub holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You can update most account information directly in your 202 pub account settings.
• 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 overriding legal retention obligations.
• Right to object: The right to object to processing based on legitimate interests, including direct marketing. Objection to marketing takes effect immediately upon receipt of your request.
• Right to data portability: The right to receive your personal data in a structured, machine-readable format and to have it transmitted to another data controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe 202 pub has processed your data unlawfully.

To exercise any of these rights, please contact the 202 pub Data Protection Officer at [email protected]. We will respond to all verified requests within 30 days of receipt. We may request identity verification before processing any data rights request.

11. Children's Privacy

202 pub Casino is strictly restricted to adults who are 21 years of age or older, in accordance with PAGCOR's age restriction policy for all real-money gaming in the Philippines. We do not knowingly collect personal data from any person under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, return any deposits made (after investigation), and securely delete all personal data associated with the underage account. If you believe an underage person has created an account at 202 pub, please contact us immediately at [email protected].

12. International Data Transfers

Your personal data is primarily stored and processed on servers located within the Asia-Pacific region. In limited circumstances, personal data may be transferred to third-party service providers located outside the Philippines — for example, cloud infrastructure providers or international game studios.

Where such transfers occur, 202 pub ensures that appropriate safeguards are in place, including contractual clauses that provide data protection standards equivalent to or greater than those required under Philippine law. We do not transfer personal data to jurisdictions that do not provide adequate data protection unless contractual safeguards are in place.

13. Changes to This Privacy Policy

202 pub reviews this Privacy Policy periodically and will update it as necessary to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. Material changes to this Policy will be communicated to registered players via the email address or mobile number associated with their account at least 14 days before the changes take effect.

The "Last Updated" date at the top of this page indicates when the Policy was most recently revised. Your continued use of the 202 pub platform after the effective date of any amendment constitutes your acknowledgment of the updated Policy.

14. Contact Us & Complaints

For all privacy-related inquiries, data rights requests, or complaints, please contact the 202 pub Data Protection Officer through the following channel:

Email: [email protected]

Live Chat: Available 24/7 directly on the 202pub.biz platform

If you are not satisfied with our response to your privacy complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph). The NPC is the independent regulatory authority responsible for enforcing the Data Privacy Act of 2012 in the Philippines.