pub 203 Privacy Policy

pub 203 ("the Company," "we," "us," or "our") is committed to protecting the privacy and personal data of all players, visitors, and users of the pub 203 platform, accessible at pub203.co ("the Platform"). This Privacy Policy sets out in detail how pub 203 collects, uses, stores, shares, and protects personal information in connection with your use of the Platform.

This Privacy Policy is issued pursuant to Republic Act No. 10173, the Philippine Data Privacy Act of 2012 ("PDPA"), and its implementing rules and regulations, as administered by the National Privacy Commission of the Philippines. It supplements and should be read in conjunction with pub 203's Terms & Conditions.

By registering for a pub 203 account, accessing the Platform, or otherwise providing your personal information to pub 203, 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 consent to the practices described in this Policy, you must not use the pub 203 Platform.

pub 203 is the data controller responsible for personal data collected through the Platform. As data controller, pub 203 determines the purposes and means by which personal data is processed. pub 203 has appointed a Data Protection Officer ("DPO") in accordance with the requirements of the PDPA and the NPC's registration requirements.

All data protection enquiries, subject access requests, correction requests, and deletion requests should be directed to the pub 203 Data Protection Officer at [email protected], with the subject line "Data Privacy Request." pub 203 will acknowledge all such requests within five (5) business days and provide a substantive response within fifteen (15) business days.

pub 203 collects the following categories of personal data in connection with the operation of the Platform:

• Identity Data: Full legal name, date of birth, gender, nationality, and copies of government-issued Philippine identification documents (such as PhilSys ID, passport, driver's license, UMID, SSS ID, or PRC ID) collected during account registration and Know Your Customer (KYC) verification.
• Contact Data: Email address, Philippine mobile number, and residential address (including city, province, and postal code).
• Account Data: Username, encrypted password, account preferences, communication preferences, and self-imposed responsible gaming limits.
• Financial Data: Payment method details (GCash number, PayMaya number, bank account details as required by the payment method), transaction history, deposit and withdrawal records.
• Gaming Data: Game session history, bet amounts, win/loss records, game preferences, bonus claim history, and wagering activity logs.
• Technical Data: IP address, device identifiers, browser type and version, operating system, session timestamps, login history, and geolocation data (where enabled by your device).
• Communications Data: Records of your communications with pub 203 customer support, including live chat transcripts and email correspondence.
• Marketing Data: Your marketing communication preferences and promotion response history.

pub 203 does not intentionally collect sensitive personal information as defined under the PDPA (such as health, political, religious, or biometric data) except where specifically required by applicable law or regulation (for example, health-related information in the context of responsible gaming interventions).

pub 203 collects personal data through the following means:

• Directly from you: When you register for a pub 203 account, complete KYC verification, make a deposit or withdrawal, contact customer support, respond to a survey, or voluntarily provide information through any platform feature.
• Automatically: When you access or use the Platform, pub 203's systems automatically collect Technical Data including IP address, device information, session duration, pages visited, and interaction patterns through cookies and server-side logging.
• From third-party service providers: pub 203 may receive personal data from payment processors (such as GCash and PayMaya operators), identity verification providers, fraud detection services, and game studios in connection with the services they provide to pub 203 or to you via the Platform.
• From regulatory authorities: pub 203 may receive data from PAGCOR or other Philippine regulatory bodies in connection with compliance obligations, including self-exclusion register information and AML-related disclosures.

pub 203 uses your personal data for the following purposes:

• Account administration: Creating, maintaining, and managing your pub 203 account, including login authentication, password recovery, and account preference management.
• Service delivery: Providing access to games, processing deposits and withdrawals, issuing and administering bonuses and promotions, and delivering customer support.
• Identity and age verification: Verifying that you are at least 21 years of age and that your identity matches the payment methods registered on your account, as required by PAGCOR and the PDPA.
• Financial compliance: Meeting Anti-Money Laundering (AML) obligations under the Anti-Money Laundering Act of 2001 (Republic Act 9160) and PAGCOR's AML compliance requirements, including transaction monitoring and suspicious transaction reporting.
• Responsible gaming: Monitoring gaming behaviour for indicators of problem gambling, administering self-exclusion and limit-setting tools, and contacting players where the platform identifies risk indicators.
• Security and fraud prevention: Detecting, investigating, and preventing fraudulent transactions, unauthorized account access, bonus abuse, and other prohibited activities.
• Platform improvement: Analysing aggregated usage data to improve the Platform's features, performance, game selection, and user experience.
• Marketing communications: Sending promotional offers, game recommendations, and platform news to players who have opted in to marketing communications. This activity is always subject to your explicit consent and your right to withdraw that consent at any time.
• Legal compliance: Meeting all legal and regulatory obligations applicable to pub 203's operations in the Philippines, including PAGCOR reporting requirements, tax obligations, and responses to lawful requests from Philippine government authorities.

pub 203 processes personal data on the following legal bases as provided under the PDPA:

• Contractual necessity: Processing required to perform the contract between pub 203 and you (account administration, game access, payment processing, and customer support).
• Legal obligation: Processing required to comply with pub 203's obligations under Philippine law, including the PDPA, AML legislation, PAGCOR regulatory requirements, and taxation laws.
• Legitimate interests: Processing for pub 203's legitimate business interests, including fraud prevention, platform security, and service improvement, provided such interests are not overridden by your privacy rights and interests.
• Consent: Processing for marketing communications, where your explicit consent has been obtained. You retain the right to withdraw consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

pub 203 does not sell your personal data to third parties. pub 203 may share your personal data with the following categories of recipients only to the extent necessary for each party to fulfil their role:

• Payment service providers: GCash (G-Xchange Inc.), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, and cryptocurrency payment processors, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML compliance service providers engaged by pub 203 to verify player identity and conduct risk screening.
• Game content providers: Licensed game studios and platform software providers who require session identifiers and account-level data to deliver game services through the pub 203 Platform.
• Customer support platforms: Live chat and email support service providers engaged to operate pub 203's 24/7 customer support function.
• Regulatory authorities: PAGCOR, the NPC, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Professional advisers: Legal counsel, auditors, and accountants, subject to applicable professional secrecy obligations.

All third parties with whom pub 203 shares personal data are required to maintain appropriate data security measures and to process personal data only in accordance with pub 203's instructions and applicable law.

Some of pub 203's service providers — including game studio operators and cloud infrastructure providers — may process personal data in jurisdictions outside the Philippines. Where such transfers occur, pub 203 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to the protections afforded under the PDPA.

Safeguards used by pub 203 for international data transfers include contractual data protection clauses binding the recipient to PDPA-equivalent standards, transfers to recipients in jurisdictions recognised by the NPC as providing adequate data protection, and transfers subject to binding corporate rules where applicable.

pub 203 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 and PAGCOR regulatory requirements, whichever is longer.

Specific retention periods applicable to pub 203 data categories include:

• Account and identity data: Retained for the duration of your active account relationship plus five (5) years following account closure, in accordance with PAGCOR record-keeping obligations and AML compliance requirements.
• Financial transaction records: Retained for a minimum of ten (10) years from the date of the transaction in accordance with AMLC record-keeping requirements under Republic Act 9160.
• Gaming activity logs: Retained for five (5) years following your last gaming activity on the Platform.
• Customer support communications: Retained for two (2) years from the date of the communication unless a longer period is required for ongoing dispute resolution or legal proceedings.
• Marketing consent records: Retained for the duration of your account plus three (3) years following account closure to evidence compliance with consent obligations.

Upon expiry of the applicable retention period, pub 203 will securely delete or anonymise your personal data in accordance with industry-standard data destruction protocols.

Under the Philippine Data Privacy Act of 2012 and its implementing rules, you have the following rights in relation to your personal data held by pub 203:

• Right to be informed: The right to be informed that your personal data is being processed, as provided through this Privacy Policy.
• Right of access: The right to request a copy of the personal data pub 203 holds about you, together with information about how it is processed.
• Right to correction: The right to request correction of any inaccurate, incomplete, or outdated personal data in your pub 203 account.
• 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 pub 203's legal retention obligations.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes at any time, with immediate effect.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that pub 203 has processed your personal data in violation of the PDPA.

To exercise any of these rights, please contact pub 203's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." pub 203 will process all valid requests free of charge within fifteen (15) business days of receipt, subject to identity verification.

pub 203 uses cookies and similar tracking technologies (including web beacons and local storage objects) on the Platform for the following purposes:

• Strictly necessary cookies: Required for the Platform to function correctly, including session management, login authentication, and security features. These cookies cannot be disabled without affecting your ability to use the Platform.
• Functional cookies: Used to remember your preferences, language settings, and personalisation choices across sessions.
• Performance cookies: Used to collect aggregated, anonymised data about how players use the Platform, enabling pub 203 to identify and fix technical issues and improve platform performance.
• Marketing cookies: Used to deliver promotions and game recommendations relevant to your account history and preferences, where you have consented to marketing communications.

You may control your cookie preferences through your browser settings. Most browsers allow you to block or delete cookies. Note that blocking strictly necessary cookies will impair your ability to access the Platform. pub 203 does not currently use third-party advertising network cookies for cross-site tracking.

pub 203 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, alteration, disclosure, destruction, or accidental loss. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the pub 203 Platform;
• Encryption at rest for sensitive stored data, including payment details and identity documents;
• Industry-standard bcrypt password hashing with per-account salts;
• Role-based access controls restricting employee access to personal data on a need-to-know basis;
• Regular internal and third-party security audits and penetration testing;
• Incident response procedures for detecting, investigating, and notifying affected individuals and the NPC of personal data breaches within the timeframes required by the PDPA.

While pub 203 takes all reasonable precautions to secure your personal data, no internet transmission or electronic storage system is completely secure. You are responsible for maintaining the confidentiality of your pub 203 login credentials and for reporting any suspected unauthorized access to your account immediately.

The pub 203 Platform is strictly for adults aged 21 years and above. pub 203 does not knowingly collect personal data from individuals under the age of 21. If pub 203 becomes aware that personal data has been collected from a person under 21, that account will be immediately closed and all associated personal data will be deleted, except where retention is required by law.

If you have reason to believe that a minor has registered on the pub 203 Platform, please contact [email protected] immediately so that pub 203 can take appropriate action.

pub 203 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Material changes to this Privacy Policy will be communicated to registered players via email notification to the address on file or via a prominent notice on the Platform. For non-material changes, your continued use of the Platform following the publication of the updated Policy constitutes your acceptance of the revised terms.

pub 203 recommends that you periodically review this Privacy Policy to stay informed of how we protect your personal data.

For all privacy-related enquiries, subject access requests, corrections, complaints, or to exercise any of your rights under the PDPA, please contact pub 203's Data Protection Officer through the following channels:

• Email (DPO): [email protected] — subject line: "Data Privacy Request"
• Live Chat: Available 24/7 via the pub 203 Platform

pub 203 processes all data privacy requests in accordance with the timelines stipulated in Section 10 of this Policy. If you are not satisfied with pub 203's response to a data privacy request or complaint, you have the right to escalate the matter to the National Privacy Commission of the Philippines through its official channels.

pub 203 takes every privacy inquiry seriously and commits to responding promptly, transparently, and in a language accessible to Filipino players — whether in English or Filipino.