pub201 Privacy Policy

01 Introduction

pub201 ("we," "us," or "our") operates the online gaming platform accessible at pub201.net (the "Platform"), which is designed to serve Filipino players across the Philippines, including those in Manila, Cebu, Davao, Quezon City, Makati, and other areas nationwide. We recognize that the privacy and security of your personal data is fundamental to the trust you place in pub201 as your online gaming provider.

This Privacy Policy ("Policy") describes in detail how pub201 collects, receives, uses, stores, transfers, discloses, and otherwise processes personal data in connection with your use of the Platform. It also sets out your rights as a data subject under Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations.

This Policy should be read alongside the pub201 Terms & Conditions and the pub201 Responsible Gaming policy, both of which form part of the overall agreement between you and pub201.

02 Data Controller

For the purposes of the Data Privacy Act of 2012 and its implementing rules, pub201 is the Personal Information Controller in respect of all personal data collected through the Platform. pub201 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable Philippine data privacy law.

pub201 has designated an internal Data Protection Officer (DPO) who is responsible for overseeing data protection compliance. You may contact the DPO through the pub201 support channel. All data privacy inquiries, access requests, and complaints will be escalated to the DPO for handling within the timeframes set out in Section 11 of this Policy.

03 Data We Collect

pub201 collects personal data in the following categories. The specific data points collected may vary depending on the features of the Platform you use and the payment methods you select.

Category	Data Points	Purpose
Identity Data	Full legal name, date of birth, government-issued ID type and number (e.g., Philippine passport, PhilSys ID, SSS ID, driver's license)	KYC verification, age verification, AML compliance
Contact Data	Email address, Philippine mobile number, residential address	Account communications, OTP delivery, support
Financial Data	GCash number, Maya account reference, bank account details (BPI, BDO, UnionBank), USDT TRC20 wallet address, transaction history	Payment processing, withdrawal verification, AML monitoring
Gaming Activity Data	Game sessions, wager amounts, wins and losses, game types played, session durations, responsible gaming limit settings	Platform delivery, responsible gaming monitoring, regulatory reporting
Technical Data	IP address, device type, browser type and version, operating system, session tokens, login timestamps	Security, fraud detection, account access management
Usage Data	Pages visited, features accessed, navigation patterns, session duration, error logs	Platform improvement, analytical reporting
Communications Data	Support chat transcripts, complaint records, email correspondence with pub201	Customer service delivery, dispute resolution, quality assurance

pub201 does not intentionally collect sensitive personal information as defined under Section 3(l) of the Data Privacy Act — such as racial or ethnic origin, political opinions, religious beliefs, health data, or sexual orientation — unless you voluntarily disclose such information in the course of a support interaction, in which case it will be handled with heightened care and deleted once no longer necessary.

04 How We Collect Your Data

pub201 collects personal data through the following channels and mechanisms:

• Direct submission: Data you provide when completing the account registration form, the KYC verification process, payment transaction forms, responsible gaming limit submissions, and support requests.
• Automated collection: Technical and usage data collected automatically when you access the Platform via cookies, server-side logging, and session management systems. See Section 9 for details on cookies.
• Payment processors: Transaction confirmation data received from GCash, Maya, BPI, BDO, UnionBank, 7-Eleven CLiQQ, Coins.ph, and USDT TRC20 network confirmations when you make deposits or receive withdrawals.
• Identity verification providers: Where pub201 uses a third-party KYC service to validate government-issued IDs, that provider may return a verification result and associated data to pub201 for storage on your account record.
• Fraud and security tools: Risk scoring and device fingerprinting data generated by pub201's internal security systems during account login and payment processing events.

05 Legal Basis for Processing

pub201 processes your personal data under the following legal bases as recognized by the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform the contract between you and pub201 — specifically, to create and maintain your account, process deposits and withdrawals, deliver gaming services, and manage your responsible gaming settings.
• Legal obligation: Processing necessary for pub201 to comply with Philippine legal and regulatory obligations, including anti-money laundering (AML) laws, KYC requirements, and reporting obligations to relevant regulatory authorities.
• Legitimate interests: Processing carried out for pub201's legitimate business interests, including fraud prevention, platform security, internal analytics, and service improvement — provided such interests are not overridden by your data protection rights.
• Consent: Where pub201 processes data for optional purposes, such as sending promotional communications or newsletters, we will request your explicit consent and provide a clear mechanism to withdraw it at any time without affecting your account access.

06 How We Use Your Data

pub201 uses your personal data for the following documented purposes. We will not use your data for any purpose not listed here without first providing notice and, where required, obtaining your consent.

• Creating, verifying, and maintaining your pub201 account.
• Processing deposits and withdrawals via your selected payment methods.
• Verifying your age (21+) and identity as required for legal compliance and responsible gaming.
• Detecting and preventing fraud, money laundering, underage gambling, and other prohibited conduct.
• Delivering and improving the pub201 gaming Platform, including slot games, live casino, bingo, sabong, and sports betting features.
• Responding to your customer support queries, complaints, and dispute resolution requests.
• Sending transactional communications — including deposit confirmations, withdrawal processing updates, security alerts, and account notifications — via your registered email or mobile number.
• Monitoring gaming activity for responsible gaming purposes, including detecting patterns consistent with problem gambling and applying player protection measures.
• Complying with requests from Philippine law enforcement agencies, courts, or regulatory bodies where legally required.
• With your consent: sending promotional offers, bonus notifications, and gaming news relevant to pub201.

07 Data Sharing and Disclosure

pub201 does not sell, rent, or commercially transfer your personal data to any third party. pub201 may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment service providers: GCash, Maya, BPI, BDO, UnionBank, 7-Eleven CLiQQ, Coins.ph, and USDT TRC20 infrastructure providers receive the minimum financial and identity data required to process your transactions. These providers operate under their own privacy policies and are independently regulated.
• KYC and identity verification providers: Third-party verification services that assist pub201 in validating government-issued IDs and confirming player eligibility. All such providers are bound by data processing agreements that restrict their use of your data to KYC purposes only.
• Cloud infrastructure providers: pub201 uses reputable cloud hosting providers to store and process Platform data in secure, access-controlled data centers. Infrastructure providers do not have access to your personal data beyond what is technically necessary for hosting.
• Regulatory and law enforcement bodies: pub201 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), Philippine law enforcement agencies, or courts of competent jurisdiction where disclosure is required by law, court order, or regulatory direction.
• Professional advisers: Legal counsel, auditors, and compliance consultants engaged by pub201 who are bound by professional confidentiality obligations.

08 Data Retention

pub201 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account relationship with pub201, plus a minimum of 5 years after account closure, as required under Philippine AML law (Republic Act No. 9160, as amended).
• Financial transaction records: Retained for a minimum of 5 years from the date of the transaction, in compliance with AMLC record-keeping requirements.
• Gaming activity logs: Retained for 3 years from the date of the relevant gaming session for regulatory audit and dispute resolution purposes.
• Support communications: Retained for 2 years from the date of the last interaction in the relevant support case.
• Technical and usage logs: Retained for 12 months for security monitoring and platform improvement, then anonymized or deleted.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in a manner that prevents re-identification. Where deletion is not immediately possible due to backup system constraints, pub201 will isolate the data from active processing until deletion can be completed.

09 Cookies and Tracking Technologies

pub201 uses cookies and similar technologies on the Platform. A cookie is a small text file stored on your device that allows the Platform to recognize your browser session and maintain certain preferences and security states.

pub201 uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These cookies maintain your login session, security tokens, and responsible gaming limit states. They cannot be disabled without preventing core Platform functionality from operating.
• Analytical cookies: Used by pub201 to understand aggregate player behavior on the Platform — such as which games are most popular, where navigation drop-offs occur, and how the lobby layout performs. This data is used in anonymized or pseudonymized form and is not shared with advertising networks.

pub201 does not use advertising cookies, social media tracking pixels, retargeting cookies, or any cross-site behavioral tracking technologies. You may adjust your browser settings to refuse or delete cookies at any time, though disabling strictly necessary cookies will impair your ability to use the Platform.

10 Data Security

pub201 implements a layered, defense-in-depth approach to protecting your personal data. Security measures in place include:

• Encryption in transit: All data exchanged between your device and pub201's servers is encrypted using TLS 1.3, the current industry standard for transport layer security.
• Encryption at rest: Sensitive personal data stored in pub201's databases is encrypted at rest using AES-256 encryption.
• Password hashing: Account passwords are never stored in plaintext. pub201 uses bcrypt with per-account cryptographic salts, ensuring that passwords cannot be recovered even in the unlikely event of a database breach.
• Access controls: Access to personal data within pub201's internal systems is restricted to personnel with a documented operational need, enforced through role-based access controls and multi-factor authentication for administrative systems.
• Intrusion detection: pub201 operates continuous security monitoring, anomaly detection, and automated alerting systems to identify and respond to potential security incidents.
• Penetration testing: pub201 engages independent security professionals to conduct periodic penetration testing of the Platform and its supporting infrastructure.

11 Your Data Subject Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by pub201. To exercise any of these rights, contact pub201 support via the live chat feature on the Platform. pub201 will acknowledge your request within 5 business days and provide a substantive response within 30 calendar days of receipt, unless the complexity of the request requires additional time, in which case pub201 will notify you of the expected completion date.

• Right to be informed: The right to know what personal data pub201 holds about you, how it is being used, and with whom it has been shared.
• Right to access: The right to request a copy of the personal data pub201 holds about you in a structured, readable format.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data held by pub201.
• Right to erasure: The right to request deletion of your personal data, subject to pub201's legal retention obligations under AML and gaming regulations.
• Right to object: The right to object to the processing of your personal data for direct marketing, profiling, or any purpose based on pub201's legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, machine-readable format and to request that pub201 transmit it to another data controller where technically feasible.
• Right to lodge a complaint: If you believe pub201 has handled your personal data unlawfully, you have the right to file a complaint directly with the National Privacy Commission (NPC) of the Philippines.
• Right to damages: The right to claim compensation for damages sustained as a result of inaccurate, incomplete, outdated, false, or unlawfully obtained personal data under the Data Privacy Act.

12 Children's and Minors' Privacy

The pub201 Platform is intended solely for individuals who are 21 years of age or older. pub201 does not knowingly collect personal data from persons under the age of 21. The minimum legal age for participation in online casino-style gambling in the Philippines is 21 years old.

If pub201 discovers or has reason to believe that personal data belonging to a person under 21 years of age has been collected — whether through a misrepresentation during registration or any other means — pub201 will immediately suspend the relevant account, delete all associated personal data as promptly as possible, and refund any deposited funds to the originating payment source. Any winnings accumulated by an underage account are void and will not be paid out.

If you are a parent or guardian and believe your child has created a pub201 account, please contact pub201 support immediately via live chat so that the account can be closed and all data removed without delay.

13 Changes to This Privacy Policy

pub201 may update this Privacy Policy from time to time to reflect changes in our data processing practices, changes in applicable Philippine law, or updates to our Platform and services. The effective date at the top of this document will be updated whenever a new version is published.

For material changes — meaning changes that significantly affect your rights or how pub201 uses your personal data — pub201 will provide advance notice via your registered email address or a prominent in-Platform notification at least 14 days before the changes take effect. Your continued use of the pub201 Platform after the effective date of the revised Policy constitutes acceptance of the updated terms.

We recommend that you review this Privacy Policy periodically. The current version is always accessible via the link in the pub201 footer.

14 Contact and Data Privacy Inquiries

For any questions, concerns, or requests relating to this Privacy Policy or pub201's handling of your personal data, please contact the pub201 Data Protection team via the live chat feature on the Platform or in writing at the email address below. All communications are handled in English and responded to during Philippine Standard Time (PST, UTC+8) business hours.

Data Privacy contact: [email protected]

If you are not satisfied with pub201's response to your data privacy inquiry or complaint, you have the right to escalate your concern directly to the National Privacy Commission of the Philippines.