202 pub Privacy Policy

202 pub is committed to protecting the privacy and personal data of every player who uses our platform. We recognize that Filipino players trust us with sensitive personal and financial information, and we take that responsibility seriously. This Policy is designed to be transparent — we want you to understand exactly what data 202 pub collects, why we collect it, how long we keep it, and with whom we may share it.

The handling of personal data at 202 pub is guided by the eight privacy principles under the DPA: transparency, legitimate purpose, proportionality, integrity, confidentiality, availability, and accountability. We have appointed a Data Protection Officer ("DPO") and maintain internal data governance procedures to ensure ongoing compliance.

For purposes of the Data Privacy Act of 2012, 202 pub acts as the Personal Information Controller ("PIC") with respect to the personal data you provide when using the 202 pub platform. This means 202 pub determines the purposes and means of processing your personal data.

Our designated Data Protection Officer ("DPO") oversees compliance with this Policy and applicable data privacy laws. You may contact the DPO with any privacy-related inquiry, request, or complaint using the contact details provided in Section 15 of this Policy.

202 pub collects personal data that is necessary and proportionate to the services we provide. The categories of personal data we process are described in the table below:

202 pub collects personal data through the following methods:

• Direct Collection: Information you provide when registering a 202 pub account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or responding to surveys.
• Automated Collection: Technical and behavioral data collected automatically when you access the 202 pub platform, including through cookies, session tracking, log files, and analytics tools.
• Third-Party Sources: Identity verification data may be cross-referenced with Philippine government databases or authorized third-party KYC service providers to confirm the authenticity of documents you submit. Payment processors may share transaction confirmation data with 202 pub.
• Publicly Available Sources: In connection with AML compliance obligations, 202 pub may consult publicly available sources, including government-issued sanctions lists and PAGCOR exclusion registries.

202 pub processes your personal data only when we have a valid legal basis to do so under the DPA. The legal bases we rely on, and the corresponding purposes, are as follows:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms and Conditions — including account management, payment processing, game provision, and customer support.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including KYC and AML obligations under the Anti-Money Laundering Act, age verification requirements under PAGCOR regulations, and tax reporting obligations.
• Legitimate Interest: Processing conducted for purposes of fraud prevention, platform security, responsible gaming monitoring, and internal analytics — where these interests are not overridden by your rights and interests as a data subject.
• Consent: Where 202 pub relies on your consent as the legal basis for processing (for example, for marketing communications), we will obtain your explicit, informed, and freely given consent prior to such processing. You may withdraw consent at any time without affecting the lawfulness of prior processing.

202 pub does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to data processing agreements where required by law:

• Payment Service Providers: GCash (Mynt – Globe Fintech Innovations, Inc.), Maya (PayMaya Philippines, Inc.), GrabPay, InstaPay network participants, and Philippine banks (BPI, BDO, Metrobank) — for the purpose of processing deposits and withdrawals.
• Game Content Providers: Licensed game providers such as Pragmatic Play, PG Soft, Jili, and others may receive session and game play data necessary for game function and compliance audits. These providers are contractually bound to confidentiality and data protection obligations.
• KYC and Identity Verification Providers: Third-party providers authorized by 202 pub to assist with identity verification and document authentication as part of our KYC process.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Bureau of Investigation (NBI), the Philippine National Police (PNP), the National Privacy Commission (NPC), and other competent authorities — where required by law, court order, or regulatory directive.
• Professional Advisers: Legal counsel, auditors, and compliance consultants engaged by 202 pub, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of 202 pub's assets, personal data held by 202 pub may be transferred to the successor entity, subject to equivalent data protection obligations. Affected data subjects will be notified as required by law.

Some of the third parties with whom 202 pub shares data (including game providers and technology vendors) may be located or operate in countries outside the Philippines. Where personal data is transferred internationally, 202 pub ensures that:

• The recipient country has been recognized as providing an adequate level of data protection; or
• Appropriate safeguards are in place, such as contractual clauses approved by the National Privacy Commission or equivalent binding arrangements; and
• The transfer is made only to the extent necessary for the specific purpose and under strict confidentiality obligations.

You may request additional information about the safeguards applied to international transfers by contacting our Data Protection Officer at the details in Section 15.

202 pub retains personal data only for as long as is necessary for 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 account relationship with 202 pub, plus a minimum of five (5) years following account closure, as required by AML regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years in compliance with the Anti-Money Laundering Act and PAGCOR record-keeping requirements.
• Gaming History: Retained for a minimum of three (3) years for dispute resolution and responsible gaming monitoring purposes.
• Customer Support Records: Retained for two (2) years following resolution of the relevant support interaction.
• Technical and Log Data: Retained for up to twelve (12) months for security and fraud investigation purposes.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized in accordance with 202 pub's data disposal procedures. Anonymous or aggregated data that cannot identify any individual may be retained indefinitely for analytical and business improvement purposes.

The 202 pub platform uses cookies and similar tracking technologies to operate and improve the platform experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function, including session management, login authentication, and security. These cannot be disabled without disrupting core functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and recent game history to provide a personalized experience.
• Analytics Cookies: Used to understand how players navigate and use the 202 pub platform — such as which games are most popular and where users encounter difficulty. This data is aggregated and used to improve the platform experience.
• Security Cookies: Help detect and prevent fraudulent activity, including bot detection and suspicious login pattern identification.

You may manage non-essential cookie preferences through your browser settings or through the cookie preference center available on the 202 pub platform. Note that disabling certain cookies may affect the functionality of the platform.

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

To exercise any of the rights above, contact the 202 pub Data Protection Officer using the details in Section 15. We will respond to verified requests within thirty (30) days of receipt. Requests may require identity verification before they can be processed.

202 pub implements technical and organizational security measures proportionate to the sensitivity of the personal data we process. These measures include:

• Encryption: All data in transit between your device and 202 pub servers is encrypted using TLS/SSL (256-bit). Sensitive data at rest is stored in encrypted form.
• Access Controls: Personal data is accessible only to 202 pub personnel and authorized third parties on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication.
• Infrastructure Security: 202 pub operates its platform on infrastructure with industry-standard physical and network security controls, including firewalls, intrusion detection systems, and regular penetration testing.
• Fraud Detection: Automated systems monitor for anomalous account activity, login patterns, and transaction irregularities to detect and prevent unauthorized access and fraudulent use.
• Data Breach Response: In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 202 pub will notify affected data subjects and the National Privacy Commission in accordance with the DPA's breach notification requirements.

The 202 pub platform is strictly intended for adults aged 21 years and above, as required by Philippine law and PAGCOR regulations governing online gaming. 202 pub does not knowingly collect or process personal data from individuals under the age of 21.

All account registrations require age verification as part of the KYC process. If 202 pub becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be immediately closed, all funds will be handled in accordance with our Terms and Conditions, and the personal data will be deleted as promptly as legally permissible.

If you are a parent or guardian and believe that a person under 21 in your care has registered on 202 pub without authorization, please contact us immediately at the details in Section 15.

The 202 pub platform may display content from or references to third-party service providers (including payment processors and game providers) whose privacy practices are governed by their own privacy policies. 202 pub is not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services you interact with in connection with your use of 202 pub.

202 pub does not embed third-party advertising networks or social media tracking pixels that would allow third parties to build independent profiles of your gaming activity on this platform.

202 pub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or NPC guidance. Material changes to this Policy will be notified to registered players via email or on-platform notification prior to taking effect.

The current version of this Policy will always be available at 202pub.lat/privacy-policy and will be dated with the most recent effective date. Your continued use of the 202 pub platform after any amendment becomes effective constitutes your acceptance of the updated Policy.

For all privacy-related inquiries, data subject rights requests, or complaints regarding the handling of your personal data by 202 pub, please contact our Data Protection Officer:

If you are not satisfied with our response to a privacy complaint, you have the right to escalate your complaint to the National Privacy Commission of the Philippines via their official channels at privacy.gov.ph.