Privacy Policy

Introduction & Scope

This Privacy Policy ("Policy") describes how 203pub ("203pub," "we," "us," or "our") collects, uses, stores, shares, and protects the personal data of individuals ("you," "your," or "Player") who access or use the 203pub online gaming platform available at 203pub.app, including all associated web pages, mobile applications, and related services (collectively, the "Platform").

This Policy applies to all personal data processed by 203pub in connection with your use of the Platform, regardless of whether you are a registered player, a visitor browsing the Platform, or a person who contacts us through any of our support channels. By accessing the Platform or registering an account, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read together with our Terms & Conditions, which govern your use of the 203pub Platform. Capitalized terms not defined in this Policy have the meanings given to them in our Terms & Conditions. If there is any conflict between this Policy and our Terms & Conditions with respect to privacy matters, this Policy shall prevail.

Data Controller Details

For the purposes of the Philippine Data Privacy Act of 2012 and this Privacy Policy, 203pub is the personal information controller responsible for your personal data collected through the Platform. As the personal information controller, 203pub determines the purposes and means of processing your personal data and is accountable for ensuring that such processing is carried out in accordance with applicable law.

203pub has designated a Data Protection Officer (DPO) who is responsible for overseeing our data protection practices and serving as the primary point of contact for data privacy matters. You may contact our DPO directly for any privacy-related inquiries, requests, or complaints:

• Data Protection Officer: 203pub Data Privacy Team
• Email: [email protected] (plain text — not a clickable link)
• Platform: 203pub.app
• Jurisdiction: Republic of the Philippines

Personal Data We Collect

203pub collects personal data from you in several ways: directly when you provide it to us during registration or account management, automatically when you use the Platform, and from third parties such as payment processors and identity verification services. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth (to verify you are 21 years of age or older)
• Gender
• Nationality and country of residence
• Residential address (including barangay, city/municipality, province, and postal code)
• Email address
• Mobile phone number
• Username and encrypted password

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, UMID, driver's license, PhilSys National ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or facial image for liveness verification
• Source of funds documentation where required by anti-money laundering regulations

3.3 Financial & Transaction Data

• Payment method details (e.g., GCash account number, PayMaya/Maya account, BPI, BDO, or Metrobank account details — stored in tokenized form only)
• Deposit and withdrawal history
• Transaction amounts in Philippine Peso (₱)
• Bonus and promotional credit history

3.4 Gaming Activity Data

• Games played, bet amounts, win/loss records, and session durations
• Responsible gaming tool settings (deposit limits, loss limits, self-exclusion status)
• Bonus wagering progress

3.5 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Pages visited, features used, and time spent on the Platform
• Login timestamps and session activity logs
• Cookie identifiers and similar tracking data (see Section 7)

3.6 Communications Data

• Records of your communications with our customer support team via live chat or email
• Feedback, survey responses, and complaint records
• Marketing communication preferences

How We Use Your Personal Data

203pub uses the personal data we collect for the following specific purposes. We do not use your data for any purpose that is incompatible with the purposes listed below without first obtaining your consent or establishing another lawful basis for processing.

Where we send you marketing communications about 203pub promotions, new games, or special offers relevant to Filipino players — such as Pasko season bonuses, PBA Finals promotions, or local Fiesta specials — we will only do so with your prior consent. You may withdraw your consent to receive marketing communications at any time by updating your notification preferences in your account settings or by contacting our support team.

Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 203pub must have a lawful basis for processing your personal data. Depending on the specific processing activity, we rely on one or more of the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — i.e., to provide the 203pub gaming platform and associated services as described in our Terms & Conditions. This covers account registration, payment processing, game provision, and customer support.
• Legal Obligation: Processing is necessary to comply with our legal obligations under Philippine law, including the Data Privacy Act, Anti-Money Laundering Act (AMLA), and applicable PAGCOR regulations. This covers KYC verification, AML reporting, and regulatory record-keeping.
• Legitimate Interests: Processing is necessary for our legitimate interests in operating a secure, fair, and commercially viable gaming platform, provided those interests are not overridden by your privacy rights. This covers fraud prevention, platform security, and analytics.
• Consent: Where we rely on your consent as the legal basis for processing — primarily for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

Data Sharing & Disclosure

203pub does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

6.1 Service Providers & Processors

We engage trusted third-party service providers who process personal data on our behalf and under our instructions. These include:

• Payment processors and e-wallet providers (GCash, PayMaya/Maya, BPI, BDO, Metrobank) for transaction processing
• Identity verification and KYC service providers
• Cloud hosting and data storage providers
• Customer support platform providers
• Platform analytics and security service providers

All third-party processors are bound by data processing agreements that require them to process your data only as instructed by 203pub and to implement appropriate security measures.

6.2 Regulatory & Law Enforcement Authorities

We may disclose your personal data to Philippine regulatory and law enforcement authorities where required by law or where we have a good-faith belief that disclosure is necessary to:

• Comply with a legal obligation, court order, or regulatory directive
• Report suspicious transactions to the Anti-Money Laundering Council (AMLC) of the Philippines
• Cooperate with PAGCOR or other gaming regulatory bodies
• Protect the rights, property, or safety of 203pub, our players, or the public

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 203pub's business, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer and ensure that the acquiring entity is bound by privacy obligations no less protective than those in this Policy.

Cookies & Tracking Technologies

203pub uses cookies and similar tracking technologies (such as web beacons and local storage) on the Platform. This section explains what cookies we use, why we use them, and how you can manage your preferences.

7.1 What Are Cookies?

Cookies are small text files placed on your device by a website when you visit it. They allow the website to recognize your device on subsequent visits and remember certain information about your preferences and activity. Cookies do not contain executable code and cannot access other data on your device.

7.2 Types of Cookies We Use

203pub does not use third-party advertising cookies or cross-site tracking cookies. You can manage or delete cookies through your browser settings at any time. Please note that disabling functional cookies may affect your experience on the Platform, as certain preferences and settings may not be saved between sessions.

Data Retention

203pub retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. Our general data retention periods are as follows:

• Account & Registration Data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required by Philippine AML regulations and PAGCOR compliance requirements.
• KYC & Identity Verification Documents: Retained for a minimum of five (5) years after the end of the business relationship, in accordance with the Anti-Money Laundering Act of the Philippines.
• Financial & Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine financial regulations.
• Gaming Activity Logs: Retained for three (3) years from the date of each gaming session, for dispute resolution and regulatory audit purposes.
• Customer Support Communications: Retained for two (2) years from the date of the last communication, for quality assurance and dispute resolution purposes.
• Technical & Usage Data: Retained for up to twelve (12) months in identifiable form, after which it is aggregated and anonymized for analytics purposes.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years after withdrawal of consent, as evidence of your consent history.

When personal data is no longer required for any lawful purpose, 203pub will securely delete or anonymize it in accordance with our data disposal procedures. Anonymized data that can no longer be linked to any individual may be retained indefinitely for statistical and analytical purposes.

Data Security

203pub takes the security of your personal data seriously. We implement a comprehensive set of technical, organizational, and physical security measures designed to protect your data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• Encryption in Transit: All data transmitted between your device and the 203pub Platform is encrypted using 256-bit SSL/TLS encryption.
• Encryption at Rest: Sensitive personal data stored in our databases is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized 203pub personnel and service providers on a strict need-to-know basis. All access is logged and audited.
• Two-Factor Authentication: We strongly encourage all players to enable two-factor authentication (2FA) on their 203pub accounts for an additional layer of security.
• Payment Tokenization: Payment method details (such as GCash and bank account numbers) are stored in tokenized form only. 203pub never stores full payment credentials in plain text.
• Regular Security Audits: Our platform undergoes regular third-party security audits and penetration testing to identify and remediate vulnerabilities.
• Incident Response: We maintain a documented data breach response plan and will notify affected players and the National Privacy Commission within 72 hours of discovering a breach that poses a risk to your rights and freedoms.

Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 203pub. We are committed to honoring these rights promptly and transparently.

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and shared. This Privacy Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You can update most of your account information directly through your account settings.
• Right to Erasure: You have 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 our legal obligations to retain certain records.
• Right to Object: You have the right to object to the processing of your personal data where we rely on legitimate interests as the legal basis, or where we process your data for direct marketing purposes.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that we transmit that data to another controller where technically feasible.
• Right to Withdraw Consent: Where we process your data based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] (plain text — not a clickable link). We will respond to all valid data rights requests within thirty (30) days. In complex cases, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reasons for it.

Children & Minors

The 203pub Platform is strictly intended for adults aged 21 years and older, in accordance with Philippine laws governing online gambling and casino-style gaming. We do not knowingly collect, process, or store personal data from individuals under the age of 21.

As part of our registration process, all applicants are required to provide their date of birth and submit valid government-issued identification to verify that they meet the minimum age requirement of 21 years. Any account found to belong to a person under 21 years of age will be immediately suspended, all funds will be handled in accordance with applicable regulations, and the personal data of the minor will be securely deleted as soon as practicable.

International Data Transfers

203pub primarily stores and processes your personal data within the Republic of the Philippines. However, some of our third-party service providers — such as cloud hosting providers and analytics platforms — may process data in other jurisdictions. Where such international transfers occur, 203pub ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Philippine Data Privacy Act of 2012.

These safeguards may include:

• Contractual clauses in our agreements with third-party processors that require them to protect your data to Philippine data privacy standards
• Transfers only to jurisdictions that the National Privacy Commission has recognized as providing an adequate level of data protection
• Implementation of additional technical and organizational security measures where required

By using the 203pub Platform, you acknowledge and consent to the transfer of your personal data to third-party processors in other jurisdictions, subject to the safeguards described above. If you have questions about specific international transfers, please contact our Data Protection Officer.

Updates to This Privacy Policy

203pub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, regulatory requirements, or the features and services offered on the Platform. All updates will be posted on this page with a revised "Last Updated" date at the top of the Policy.

Where we make material changes to this Privacy Policy — changes that significantly affect your rights or how we process your personal data — we will notify you by:

• Displaying a prominent notice on the 203pub Platform for a period of at least thirty (30) days prior to the changes taking effect
• Sending a notification to the email address registered to your account
• Requiring your acknowledgment of the updated Policy upon your next login, where required by law

Your continued use of the 203pub Platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes to this Policy, you should discontinue your use of the Platform and may request account closure by contacting our support team.

Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way 203pub processes your personal data, we encourage you to contact us directly. Our Data Protection Officer and privacy team are committed to addressing all inquiries promptly and transparently.

You may reach our Data Protection Officer at:

• Email: [email protected] (plain text — not a clickable link)
• General Support: [email protected] (plain text — not a clickable link)
• Response Time: Within 30 days of receipt of your request

If you are not satisfied with our response to your privacy concern, or if you believe that 203pub has violated your data privacy rights under the Philippine Data Privacy Act of 2012, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent government body responsible for administering and enforcing the Data Privacy Act.