205pub Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 205pub ("205pub," "we," "us," or "our") collects, uses, stores, shares, and protects the personal data of individuals ("you," "Player," or "User") who access or use the 205pub online casino platform, website, mobile interface, and all related services (collectively, the "Platform").

205pub is committed to protecting your privacy and handling your personal data with transparency, integrity, and respect. This Policy is designed to comply with the Data Privacy Act of the Philippines (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

This Policy applies to all personal data collected through the 205pub Platform, including data collected during account registration, identity verification, payment processing, gameplay, customer support interactions, and marketing communications. It should be read together with the 205pub Terms & Conditions and Responsible Gaming Policy.

2. Data Controller

For the purposes of the Data Privacy Act of the Philippines, 205pub is the personal information controller responsible for the personal data collected through the Platform. As data controller, 205pub determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data protection law.

205pub 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 at [email protected] for any privacy-related enquiries, requests, or complaints.

3. Personal Data We Collect

205pub collects the following categories of personal data, depending on how you interact with the Platform:

3.1 Identity & Registration 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
• Government-issued identification number (passport, SSS, UMID, driver's license, or PhilSys National ID)
• Username and encrypted password

3.2 Contact Data

• Email address
• Mobile phone number
• Residential address (city, province, barangay, ZIP code)

3.3 Financial & Payment Data

• GCash or PayMaya account number and registered name
• Bank account details (bank name, account number, account name) for bank transfer transactions
• Debit card details (card number masked, expiry date, cardholder name)
• Transaction history (deposits, withdrawals, wager amounts, winnings)
• Source of funds declarations where required by Philippine anti-money laundering regulations

3.4 KYC Verification Documents

• Scanned copies or photographs of government-issued photo identification
• Proof of address documents (utility bills, bank statements, barangay certificates)
• Selfie photographs for liveness verification where required

3.5 Gaming & Behavioural Data

• Game history (games played, bet amounts, outcomes, session duration)
• Bonus and promotion usage history
• Responsible gaming settings (deposit limits, session limits, self-exclusion status)
• Customer support interaction records (chat logs, email correspondence, call recordings where applicable)

3.6 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Unique device identifiers
• Login timestamps and session activity logs
• Cookie and tracking technology data (see Section 8)

4. How We Collect Your Data

205pub collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, participate in promotions, or update your account settings.
• Automatically: When you access and use the Platform, we automatically collect technical and device data through cookies, web beacons, log files, and similar tracking technologies.
• From third parties: We may receive personal data from identity verification providers, payment processors (GCash, PayMaya, Philippine banks), fraud detection services, and PAGCOR or other regulatory authorities where required by law.
• From publicly available sources: In limited circumstances, we may supplement your data with information from publicly available sources for fraud prevention or regulatory compliance purposes.

5. How We Use Your Personal Data

205pub uses your personal data for the following purposes:

205pub will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

6. Legal Basis for Processing

205pub processes your personal data on the following legal bases under the Data Privacy Act of the Philippines:

• Contractual necessity: Processing is necessary to perform the contract between you and 205pub — specifically, to operate your account, process transactions, and provide gaming services.
• Legal obligation: Processing is required to comply with applicable Philippine laws, including the Anti-Money Laundering Act (RA 9160), PAGCOR regulatory requirements, and the Data Privacy Act itself.
• Legitimate interests: Processing is necessary for 205pub's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and business analytics, provided these interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and non-essential cookies, 205pub relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

7. Data Sharing & Disclosure

205pub 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, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya (Maya), and Philippine banking partners, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers: Third-party services that assist 205pub in verifying player identity and age in compliance with PAGCOR requirements.
• Game content providers: Licensed game studios and software providers whose games are available on the 205pub Platform, to the extent necessary for game operation and dispute resolution.
• Fraud prevention and security services: Third-party providers that assist 205pub in detecting and preventing fraudulent activity, money laundering, and account abuse.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law, court order, or regulatory directive.
• Professional advisers: Lawyers, auditors, and accountants engaged by 205pub, subject to professional confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of 205pub's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

8. Cookies & Tracking Technologies

205pub uses cookies and similar tracking technologies on the Platform to enhance your experience, maintain session security, and analyse Platform performance. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled without affecting Platform functionality.
• Functional cookies: Remember your preferences and settings (such as language, display preferences, and responsible gaming settings) to personalise your experience.
• Analytics cookies: Collect aggregated, anonymised data about how players use the Platform, which pages are visited most frequently, and where errors occur. This data helps 205pub improve the Platform.
• Marketing cookies: Used with your consent to deliver relevant promotional content and measure the effectiveness of 205pub's marketing campaigns. You may opt out of marketing cookies at any time.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 205pub Platform. For detailed information about the specific cookies used and how to manage them, please refer to the cookie settings panel available on the Platform.

9. Data Security

205pub implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: All data transmitted between your device and the 205pub Platform is encrypted using 256-bit SSL/TLS technology. Sensitive data stored in our systems is encrypted at rest using industry-standard encryption algorithms.
• Access controls: Access to personal data is restricted to authorised 205pub personnel and third-party processors who require it to perform their functions. All access is logged and monitored.
• Firewalls and intrusion detection: 205pub's infrastructure is protected by enterprise-grade firewalls and real-time intrusion detection systems.
• Regular security audits: 205pub conducts regular security assessments, penetration testing, and vulnerability scans to identify and remediate potential security weaknesses.
• Staff training: All 205pub personnel who handle personal data receive regular data protection and security training.
• Incident response: 205pub maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, 205pub will notify the National Privacy Commission and affected players in accordance with the Data Privacy Act's breach notification requirements.

10. Data Retention

205pub retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulatory obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act of the Philippines.
• KYC verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Gaming and behavioural data: Retained for the duration of your active account and for up to two (2) years following account closure for dispute resolution and responsible gaming monitoring purposes.
• Customer support records: Retained for up to three (3) years from the date of the interaction.
• Marketing consent records: Retained for as long as you remain subscribed to marketing communications, plus one (1) year following unsubscription.

Upon expiry of the applicable retention period, 205pub will securely delete or anonymise your personal data in accordance with its data disposal procedures, unless further retention is required by law.

11. Your Data Subject Rights

Under the Data Privacy Act of the Philippines (RA 10173), you have the following rights with respect to your personal data held by 205pub:

To exercise any of your data subject rights, please submit a written request to the 205pub Data Protection Officer at [email protected]. 205pub will respond to all verified data subject rights requests within fifteen (15) business days of receipt. We may require you to verify your identity before processing your request.

If you are not satisfied with 205pub's response to your data subject rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) through its official channels.

12. Children's Privacy

The 205pub Platform is strictly intended for individuals who are at least twenty-one (21) years of age. 205pub does not knowingly collect personal data from persons under the age of 21. If you are under 21, you are not permitted to register an account or use the 205pub Platform.

If 205pub becomes aware that it has inadvertently collected personal data from a person under the age of 21, it will take immediate steps to delete that data and close the associated account. Any winnings accrued by an underage player will be forfeited in accordance with the 205pub Terms & Conditions.

13. Cross-Border Data Transfers

In certain circumstances, 205pub may transfer your personal data to recipients located outside the Philippines — for example, to international game content providers, cloud infrastructure providers, or fraud prevention services. Any such cross-border transfer of personal data will only be made where:

• The recipient country provides an adequate level of data protection as determined by the National Privacy Commission of the Philippines; or
• Appropriate safeguards are in place, such as contractual clauses approved by the NPC or binding corporate rules; or
• The transfer is necessary for the performance of the contract between you and 205pub (e.g., processing a payment through an international payment network); or
• You have given your explicit consent to the transfer after being informed of the possible risks.

205pub will not transfer your personal data to any country or organisation that does not provide adequate data protection safeguards equivalent to those required under Philippine law.

14. Updates to This Privacy Policy

205pub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, NPC guidelines, or PAGCOR regulatory requirements. When material changes are made to this Policy, 205pub will notify registered players by email or through a prominent notice on the Platform at least seven (7) 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 205pub Platform after the effective date of any amendment constitutes your acknowledgement of the updated Policy. We encourage you to review this Policy periodically to stay informed about how 205pub protects your personal data.

15. Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or 205pub's data processing practices, please contact our Data Protection Officer:

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Response Time: We aim to acknowledge all privacy enquiries within five (5) business days and resolve them within fifteen (15) business days.

If you are not satisfied with 205pub's handling of your privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent government body responsible for administering and implementing the Data Privacy Act of the Philippines.