203pub Privacy Policy — Your Data, Our Responsibility

1. Scope and Application

This Privacy Policy (the "Policy") is issued by 203pub (the "Platform," "we," "us," or "our") and governs the collection, use, storage, transfer, and protection of personal information provided by or collected from individuals (the "User," "Player," or "you") who access or use the 203pub online gaming platform, including through the website at 203pub.cam and all associated subdomains, mobile-optimized pages, and related services.

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA) of the Republic of the Philippines, its Implementing Rules and Regulations (IRR), and relevant issuances of the National Privacy Commission (NPC). By creating a 203pub account or using any part of the platform, you consent to the processing of your personal data as described in this Policy.

This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, both of which form part of the agreement between you and 203pub.

2. Personal Information We Collect

203pub collects only the personal information that is necessary for the legitimate operation of the platform, fulfilment of regulatory obligations, and delivery of a safe, functional gaming experience for Filipino players. The categories of personal information we may collect include:

2.1 Identity and Contact Information

• Full legal name as it appears on a government-issued identification document
• Date of birth (for age verification purposes — all users must be 21 years of age or older)
• Residential address, including barangay, city or municipality, province, and postal code
• Email address used for account registration and correspondence
• Mobile phone number registered in the Philippines
• Government-issued identification document details (e.g., Philippine National ID, passport, driver's license, SSS ID, UMID), including document number and expiry date

2.2 Financial and Transaction Information

• GCash or PayMaya account number associated with your registered mobile number
• Bank account details for BDO, BPI, Metrobank, or other Philippine banks used for deposit or withdrawal transactions
• Credit or debit card details (card number, expiry, and cardholder name) where applicable
• Transaction history, including deposit amounts, withdrawal requests, bet amounts, game outcomes, and account balance movements

2.3 Technical and Usage Data

• IP address and geolocation data at the time of login or transaction
• Device type, operating system, browser type and version
• Pages visited, features accessed, session duration, and navigation patterns within the 203pub platform
• Login timestamps and session activity logs
• Cookies and similar tracking technology data (see Section 9)

2.4 Communications Data

• Records of live chat, email, or any other communications you initiate with 203pub customer support
• Feedback, complaints, dispute records, and any voluntary information you provide in correspondence with 203pub
• Responses to surveys or promotions where participation is voluntary

3. How We Collect Your Information

203pub collects personal information through the following methods:

• Direct collection: Information you voluntarily provide during account registration, identity verification, deposit or withdrawal requests, support inquiries, or participation in promotions.
• Automated collection: Technical data collected automatically when you access the 203pub platform, including through cookies, log files, and analytics tools embedded in the platform interface.
• Third-party sources: Information received from payment processors (including GCash, PayMaya, and banking partners) to verify transactions; information from identity verification service providers used to comply with KYC (Know Your Customer) and AML (Anti-Money Laundering) requirements.
• Regulatory sources: Information received from PAGCOR or other competent Philippine regulatory authorities in connection with compliance obligations.

4. Purposes of Processing Personal Information

203pub processes your personal information for the following purposes:

Purpose	Description
Account Management	Creating, maintaining, verifying, and administering your 203pub player account.
Age & Identity Verification	Confirming you meet the 21+ age requirement and verifying your identity as required by PAGCOR and Philippine law.
Payment Processing	Processing GCash, PayMaya, bank transfer, and card deposits and withdrawals in Philippine Peso.
Regulatory Compliance	Fulfilling KYC, AML, and other obligations under Philippine gaming and financial regulations.
Platform Security	Detecting and preventing fraud, unauthorized access, cheating, collusion, and other prohibited activities.
Customer Support	Responding to inquiries, resolving disputes, and providing assistance to players across the Philippines.
Responsible Gaming	Monitoring gaming activity to identify potentially problematic behavior and applying responsible gaming tools where appropriate.
Platform Improvement	Analyzing usage data to improve platform performance, user experience, and game offerings for Filipino players.
Marketing Communications	Sending promotional offers, game updates, and platform news to players who have opted in to receive such communications.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012 and its IRR, 203pub processes your personal information on the following legal bases:

• Consent: Where you have expressly given your consent to the processing of your personal data, including during account registration and opt-in communications.
• Contractual Necessity: Where processing is necessary to perform the contract between you and 203pub (i.e., providing online gaming services pursuant to our Terms & Conditions).
• Legal Obligation: Where processing is required to comply with applicable Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate Interests: Where processing is necessary for 203pub's legitimate business interests, including fraud prevention, platform security, and business analytics, provided such interests do not override your rights and freedoms.

6. Sharing and Disclosure of Personal Information

203pub does not sell, rent, or trade your personal information to third parties. We may share your personal information only in the following circumstances and only to the extent necessary:

6.1 Service Providers and Partners

We may disclose your information to trusted third-party service providers who assist in operating the 203pub platform, including payment processors (GCash, PayMaya, banks), identity verification providers, cloud hosting services, analytics providers, and customer support tools. All such providers are bound by confidentiality obligations and are prohibited from using your personal data for any purpose other than providing the contracted service to 203pub.

6.2 Regulatory and Legal Disclosure

203pub may disclose personal information to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, or other competent Philippine government authorities where required or permitted by law, including in response to lawful orders, subpoenas, or regulatory inquiries.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or a substantial portion of 203pub's assets, your personal information may be transferred to the successor entity, subject to equivalent data protection obligations. We will notify affected Users of any such transfer in advance where reasonably practicable.

6.4 Protection of Rights

We may disclose your personal information where we believe in good faith that such disclosure is necessary to protect the rights, property, or safety of 203pub, its players, or the public — including for the investigation of fraud or security incidents.

7. Data Retention

203pub retains your personal information only for as long as necessary to fulfil the purposes for which it was collected, including to comply with applicable legal, regulatory, and contractual obligations. Specific retention periods are as follows:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR requirements and the Anti-Money Laundering Act.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• Customer support communications: Retained for two (2) years following resolution of the relevant inquiry or dispute.
• Technical and usage data: Retained for up to twelve (12) months, unless retention beyond this period is required for security investigations or legal proceedings.
• Marketing consent records: Retained until you withdraw your consent or close your account, whichever occurs first.

Upon expiry of the applicable retention period, your personal data will be securely deleted, anonymized, or otherwise rendered irrecoverable, in accordance with the NPC's data disposal guidelines.

8. Security Measures

203pub implements technical, organizational, and physical security measures designed to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 203pub platform
• Encryption of sensitive data at rest, including financial account details and identity document information
• Role-based access controls ensuring that 203pub personnel can only access personal data necessary for their specific duties
• Regular security assessments and vulnerability testing of the platform and its infrastructure
• Multi-factor authentication requirements for account access
• Monitoring systems for detecting and responding to unauthorized access attempts or suspicious activity
• Staff training on data privacy obligations under the DPA and 203pub's internal data handling procedures

Notwithstanding the foregoing, no security system is impenetrable. While we take data security seriously, we cannot guarantee the absolute security of your personal information. In the event of a data breach that is likely to give rise to a real risk of serious harm to data subjects, 203pub will notify affected Users and the National Privacy Commission in accordance with the DPA's breach notification requirements.

9. Cookies and Similar Tracking Technologies

203pub uses cookies and similar tracking technologies to enhance your experience on the platform, remember your preferences, maintain your login session, and collect analytics data to improve platform performance. The types of cookies we use include:

• Essential cookies: Necessary for the platform to function correctly. These include session cookies that keep you logged in and security tokens that protect against cross-site request forgery. These cannot be disabled without impairing platform functionality.
• Functional cookies: Remember your language preferences, region settings, and other personalization options to improve your experience on 203pub.
• Analytics cookies: Collect aggregated, anonymized data about how players interact with the platform, including which games are most frequently visited and where technical errors occur. This data is used solely to improve 203pub's services.
• Security cookies: Help detect and prevent fraudulent activity and unauthorized account access by tracking login patterns and device fingerprints.

You may control cookie settings through your browser preferences. However, disabling essential cookies may prevent certain features of the 203pub platform from functioning correctly. 203pub does not use cookies for cross-site advertising or to share behavioral data with third-party advertisers.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its IRR, you have the following rights with respect to your personal information held by 203pub:

• Right to be Informed: You have the right to be informed of how your personal information is being collected, used, and processed before or at the time of collection.
• Right to Access: You have the right to request a copy of the personal information we hold about you, and to be provided with information about how that data has been processed.
• Right to Rectification: You have the right to request correction of inaccurate, incomplete, or outdated personal information held in your 203pub account.
• Right to Erasure or Blocking: You have the right to request the deletion or blocking of your personal data where it is no longer necessary for the purposes for which it was collected, subject to applicable legal retention obligations.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data based on legitimate interests or for direct marketing purposes.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission if you believe that 203pub has violated your rights under the Data Privacy Act.

To exercise any of the above rights, please contact 203pub's data privacy team via email at [email protected]. We will acknowledge your request within three (3) business days and endeavor to respond substantively within fifteen (15) business days, as required by the DPA's IRR.

11. Protection of Minors

The 203pub platform is strictly intended for individuals who are at least twenty-one (21) years of age. We do not knowingly collect or process personal information from individuals below this age threshold. As part of our registration process, we require all Users to confirm that they are at least 21 years old and to provide government-issued identification for age verification purposes.

If 203pub discovers that it has inadvertently collected personal information from an individual below 21 years of age, we will promptly delete such information from our records and close any associated account. If you believe that a minor has registered for a 203pub account, please notify us immediately at [email protected].

12. Changes 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 law, or regulatory guidance. Material changes to this Policy will be communicated to registered Users by email or through a prominent notice on the 203pub platform prior to the changes taking effect. The date of the most recent revision is indicated at the top of this page.

Your continued use of the 203pub platform following the effective date of any amended Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with the changes, you must discontinue your use of the platform and may request account closure as described in our Terms & Conditions.

13. Contact Information and Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal information by 203pub, please contact us through the following channels:

• Email: [email protected]
• Live Chat: Available 24 hours a day, 7 days a week through the 203pub platform
• Response Time: Written inquiries acknowledged within three (3) business days; substantive response within fifteen (15) business days

For complaints that cannot be resolved directly with 203pub, you may contact the National Privacy Commission of the Philippines, which serves as the supervisory authority for data protection matters under the Data Privacy Act of 2012.