pub203 Privacy Policy

1.1 pub203 is committed to protecting the privacy and security of your personal data. We understand that when you share your information with us, you are placing trust in pub203, and we take that responsibility seriously.

1.2 This Policy applies to all personal data collected through the pub203 website, mobile platform, customer support channels, and any other service operated by pub203. It applies to all registered players, prospective players, and visitors to the pub203 Platform.

1.3 By accessing the pub203 Platform or creating an account, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the pub203 Platform.

1.4 This Policy should be read together with the pub203 Terms and Conditions, which govern your use of the Platform.

2.1 For the purposes of the Philippine Data Privacy Act of 2012, pub203 is the personal information controller in respect of the personal data collected through the pub203 Platform.

2.2 pub203 has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO using the contact details provided in Section 15 of this Policy.

2.3 Where pub203 engages third-party service providers to process personal data on its behalf, those providers act as personal information processors and are bound by data processing agreements that require them to handle your data in accordance with this Policy and applicable law.

3.1 pub203 collects the following categories of personal data:

3.2 Sensitive Personal Information. In certain circumstances, pub203 may collect sensitive personal information as defined under the Data Privacy Act, including government-issued identification numbers and financial account details. Such data is collected only where strictly necessary and is subject to enhanced security measures.

3.3 pub203 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from an underage individual, we will take immediate steps to delete that data and close the associated account.

4.1 pub203 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated technologies: Data collected automatically when you access the pub203 Platform, including cookies, web beacons, log files, and similar tracking technologies (see Section 8);
• Third-party sources: Data received from identity verification providers, payment processors, fraud prevention services, and publicly available sources, where permitted by law;
• Regulatory sources: Data received from PAGCOR, the AMLC, or other competent Philippine authorities in connection with our legal and regulatory obligations.

5.1 pub203 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you — including account management, game provision, and payment processing;
• Legal obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR licensing requirements, and tax obligations;
• Legitimate interests: Processing necessary for pub203's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, such as for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6.1 pub203 uses your personal data for the following purposes:

• To create, verify, and manage your pub203 player account;
• To process deposits and withdrawals via GCash, PayMaya, bank transfer, and debit card;
• To verify your identity and age (21+) in compliance with Philippine gaming regulations;
• To provide, maintain, and improve the pub203 gaming Platform and its features;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activity;
• To monitor gaming activity for responsible gaming purposes and to enforce self-exclusion requests;
• To communicate with you about your account, transactions, promotions, and Platform updates;
• To respond to your customer support enquiries and resolve disputes;
• To comply with our legal and regulatory obligations under Philippine law;
• To conduct analytics and research to improve the pub203 Platform and user experience;
• To send you marketing communications about pub203 promotions and offers, where you have consented to receive such communications.

7.1 pub203 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary and in accordance with this Policy:

• Payment processors: GCash, PayMaya/Maya, and Philippine banking partners, for the purpose of processing your deposits and withdrawals;
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and comply with regulatory requirements;
• Game software providers: Licensed game studios and software providers whose games are available on the pub203 Platform, to the extent necessary for game provision and dispute resolution;
• IT and security service providers: Cloud hosting, cybersecurity, and fraud prevention providers who process data on pub203's behalf under strict data processing agreements;
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where required by law or court order;
• Professional advisers: Lawyers, auditors, and accountants, where necessary for the conduct of pub203's business and subject to professional confidentiality obligations.

7.2 All third-party processors engaged by pub203 are required to implement appropriate technical and organisational security measures and to process personal data only in accordance with pub203's documented instructions.

8.1 pub203 uses cookies and similar tracking technologies to enhance your experience on the Platform, to analyse usage patterns, and to support security and fraud prevention functions.

8.2 The following types of cookies are used on the pub203 Platform:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management and security. These cannot be disabled.
• Functional cookies: Remember your preferences and settings to personalise your experience on the pub203 Platform.
• Analytics cookies: Collect anonymised data about how players use the Platform to help us improve performance and usability.
• Security cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorised access attempts.

8.3 You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the pub203 Platform. Strictly necessary and security cookies cannot be disabled without impairing Platform operation.

8.4 pub203 does not use third-party advertising cookies or permit third-party advertisers to place cookies on the pub203 Platform.

9.1 pub203 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 pub203 Platform;
• Encryption of sensitive data at rest, including financial and identity data;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Multi-factor authentication for administrative access to systems containing personal data;
• Incident response procedures for the detection, containment, and reporting of personal data breaches.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, pub203 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay.

9.3 While pub203 takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying pub203 immediately of any suspected unauthorised access to your account.

10.1 pub203 retains your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable Philippine law.

10.2 The following retention periods apply as a general guide:

• Account and identity data: Retained for a minimum of five (5) years following account closure, as required by Philippine AML regulations;
• Transaction and financial data: Retained for a minimum of five (5) years following the date of the transaction;
• Gaming history: Retained for a minimum of three (3) years for dispute resolution and regulatory compliance purposes;
• Customer support records: Retained for three (3) years following the resolution of the relevant enquiry;
• Marketing consent records: Retained for the duration of your account and for three (3) years following account closure or withdrawal of consent.

10.3 Where personal data is no longer required for any lawful purpose, pub203 will securely delete or anonymise it in accordance with our data disposal procedures.

11.1 Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by pub203:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy;
• Right of access: The right to request a copy of the personal data pub203 holds about you;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data;
• 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 pub203's legal retention obligations;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to restrict processing: The right to request that pub203 restricts the processing of your personal data in certain circumstances;
• Right to damages: The right to claim compensation for any damages sustained as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data.

11.2 To exercise any of the above rights, please contact pub203's Data Protection Officer using the contact details in Section 15. pub203 will respond to all valid requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, and you will be notified accordingly.

11.3 pub203 will not charge a fee for exercising your data rights unless your request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.

12.1 The pub203 Platform is strictly intended for individuals aged 21 years and above. pub203 does not knowingly collect, use, or store personal data from individuals under the age of 21.

12.2 If pub203 becomes aware that personal data has been collected from an individual under the age of 21, we will take immediate steps to delete that data, close the associated account, and return any funds deposited, subject to verification.

12.3 If you believe that pub203 may have inadvertently collected personal data from an underage individual, please contact our Data Protection Officer immediately using the details in Section 15.

13.1 In the course of providing its services, pub203 may transfer your personal data to service providers or partners located outside the Philippines. Where such transfers occur, pub203 ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law;
• Transfers only to countries or organisations that have been assessed as providing an adequate level of data protection;
• Obtaining your explicit consent where required by applicable law.

13.2 pub203 will not transfer your personal data to any jurisdiction that does not provide adequate protections for personal data without first implementing appropriate safeguards and, where required, notifying the National Privacy Commission.

14.1 pub203 may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or Platform features. The date of the most recent revision is indicated at the top of this page.

14.2 Where changes are material, pub203 will notify registered players by email or via a prominent notice on the pub203 Platform prior to the changes taking effect. Your continued use of the Platform following notification of changes constitutes your acceptance of the revised Policy.

14.3 We encourage you to review this Privacy Policy periodically to stay informed about how pub203 protects your personal data.

15.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by pub203, please contact our Data Protection Officer:

15.2 If you are not satisfied with pub203's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines:

15.3 pub203 takes all privacy complaints seriously and will investigate and respond to all valid complaints in a timely and transparent manner.