pub204 Privacy Policy

pub204 ("we," "us," or "our") is the data controller responsible for the personal information collected through the pub204 Platform at pub204.club. As data controller, pub204 determines the purposes and means of processing your personal data. pub204 is committed to fulfilling its obligations as a personal information controller under Republic Act No. 10173, the Data Privacy Act of 2012 of the Republic of the Philippines, and all applicable data protection regulations.

For all privacy-related inquiries, requests, or complaints, Members may contact pub204 via the 24/7 in-app live chat support or by email at [email protected].

When you create a pub204 account, we collect the following personal information necessary to establish and maintain your membership:

• Full legal name as it appears on your government-issued identification document
• Date of birth (for age verification — pub204 strictly requires members to be 21 years of age or older)
• Philippine mobile number (used as primary account identifier and for two-factor verification)
• Email address (for account communications and password recovery)
• Username selected during registration

Before enabling withdrawal services, pub204 requires completion of Know Your Customer (KYC) identity verification. During this process, we collect:

• Government-issued photo identification (Philippine passport, driver's license, PhilSys national ID, SSS ID, UMID, or equivalent)
• Proof of address documents (utility bills, bank statements, or equivalent dated within 90 days) where required
• Source of funds documentation in cases of enhanced due diligence at higher deposit thresholds
• Selfie or live verification image for biometric document matching where required

pub204 collects records of all financial transactions conducted through your account, including deposit amounts, withdrawal requests, transaction reference numbers, timestamps, and the payment method type used (GCash, PayMaya, BPI, BDO, Metrobank). pub204 does not store full payment account credentials — payment processing is handled by regulated third-party payment processors who maintain their own security standards.

pub204 maintains a complete log of your gaming activity on the Platform, including game titles played, bet amounts, win/loss outcomes, session durations, bonus usage, and wagering history. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory compliance purposes.

When you access the pub204 Platform, our systems automatically collect certain technical data including your IP address, browser type and version, device type and operating system, screen resolution, referring URL, and session timestamps. This data is used for security monitoring, fraud detection, platform optimization, and geographic compliance purposes.

pub204 collects personal data through the following methods:

1. Directly from you — information you provide during registration, KYC submission, support interactions, and promotional participation.
2. Automatically — technical and device data collected when you access and use the Platform through cookies, server logs, and analytics tools.
3. From payment processors — transaction confirmation data received from GCash, PayMaya, BPI, BDO, Metrobank, and other integrated payment services when you initiate deposits or withdrawals.
4. From third-party verification services — identity and age verification data received from KYC service providers used to validate the authenticity of documents submitted during the verification process.

pub204 processes your personal data for the following specific and legitimate purposes:

1. Creating and maintaining your pub204 account and managing the Member relationship
2. Verifying your identity and age as required under applicable gaming regulations and pub204's KYC obligations
3. Processing deposits and withdrawals in Philippine Peso through the supported payment channels
4. Providing all gaming, betting, and ancillary services available on the Platform
5. Detecting, investigating, and preventing fraud, money laundering, and other illegal activity
6. Monitoring compliance with our Terms and Conditions and responsible gaming commitments
7. Providing customer support and resolving account disputes and complaints
8. Sending transactional communications such as deposit confirmations, withdrawal notifications, and security alerts
9. Sending promotional and marketing communications where you have provided consent
10. Complying with legal obligations under Philippine law and applicable gaming regulations
11. Improving Platform performance, game offerings, and user experience based on aggregated usage analytics

pub204 processes your personal data on the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual necessity — processing required to perform the membership agreement between pub204 and you, including account management, payment processing, and service delivery.
• Legal obligation — processing necessary to comply with pub204's obligations under applicable laws, including anti-money laundering regulations, KYC requirements, and gaming regulatory frameworks.
• Legitimate interests — processing for fraud prevention, security monitoring, and platform improvement where those interests are not overridden by your rights and freedoms.
• Consent — processing for marketing communications and optional analytics purposes, where your specific consent has been obtained and can be withdrawn at any time.

pub204 shares personal data with trusted third-party service providers who assist in operating the Platform. These include payment processors (GCash/Maya Holdings, BPI, BDO, Metrobank), KYC verification service providers, game software providers, cloud infrastructure providers, and customer support platform vendors. All service providers are bound by data processing agreements requiring them to process your data only for the purposes specified by pub204 and to maintain appropriate security standards.

pub204 may disclose your personal information to PAGCOR, the National Privacy Commission, law enforcement agencies, financial intelligence units, or other competent regulatory and government authorities where required by law, court order, or regulatory directive. pub204 will notify affected Members of such disclosures where legally permitted to do so.

pub204 does not sell, rent, trade, or otherwise transfer your personal information to unaffiliated third parties for their own marketing purposes. Your personal data is used solely for the purposes described in this Privacy Policy and to operate the pub204 Platform and its associated services.

pub204 uses cookies and similar tracking technologies on the Platform. Cookies are small text files placed on your device by your browser when you visit pub204.club. pub204 uses the following categories of cookies:

• Essential / Strictly Necessary Cookies: Required for the Platform to function — these enable login session management, security token validation, and basic account functionality. These cookies cannot be disabled without preventing access to core Platform features.
• Functional Cookies: Remember your preferences such as language settings and display configurations to provide a personalized experience across visits.
• Analytics Cookies: Used to collect aggregated, anonymized data about how Members navigate and use the Platform, enabling pub204 to improve service quality and user experience. Analytics data is not linked to individual identifiable profiles.
• Security Cookies: Used for fraud detection, bot prevention, and identifying suspicious access patterns to protect your account and the Platform.

By using the pub204 Platform, you consent to the use of essential and security cookies. You may manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of some Platform features.

pub204 retains personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention periods generally apply:

• Active account data: Retained throughout the period your pub204 account remains open and for a minimum of 5 years following account closure.
• KYC and identity verification documents: Retained for a minimum of 5 years from the date of verification or account closure, whichever is later, in compliance with anti-money laundering record-keeping obligations.
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction, consistent with applicable financial regulations.
• Technical and device logs: Retained for up to 12 months from collection for security and fraud monitoring purposes, after which they are anonymized or deleted.
• Marketing consent records: Retained until consent is withdrawn, plus 3 years for compliance documentation purposes.

Upon expiry of applicable retention periods, pub204 will securely delete or anonymize personal data in accordance with our internal data lifecycle management procedures.

pub204 implements technical and organizational security measures appropriate to the risk level associated with the personal data we process. These measures include:

• SSL/TLS encryption on all data transmitted between your device and pub204 servers
• Encryption at rest for sensitive personal data including KYC documents and payment-related records
• Role-based access controls limiting internal access to personal data to authorized personnel with a legitimate operational need
• Regular security assessments, penetration testing, and vulnerability monitoring of Platform infrastructure
• Multi-factor authentication requirements for administrative access to systems containing personal data
• Incident response procedures for detecting, reporting, and responding to personal data breaches within the timeframes required under applicable law

Notwithstanding these measures, no method of electronic transmission or storage is 100% secure. pub204 encourages Members to protect their own account credentials and to report any suspected unauthorized access immediately via the 24/7 live chat support channel.

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pub204:

1. Right to be Informed: The right to know whether pub204 processes your personal data and to receive clear information about how it is used — as provided by this Privacy Policy.
2. Right of Access: The right to request a copy of the personal data pub204 holds about you, along with information about how it is being processed.
3. Right to Rectification: The right to request correction of inaccurate or incomplete personal data held in your pub204 account.
4. Right to Erasure / Right to be Forgotten: 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 pub204's legal retention obligations.
5. Right to Object: The right to object to certain processing activities, including direct marketing, where processing is not based on contractual necessity or legal obligation.
6. Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format, or to request its direct transfer to another controller where technically feasible.
7. Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, contact pub204 via 24/7 in-app live chat or email at [email protected]. Requests will be acknowledged within 5 business days and acted upon within 30 calendar days, subject to identity verification and applicable legal constraints.

The pub204 Platform is strictly intended for adults aged 21 years and above in the Philippines. pub204 does not knowingly collect personal data from individuals below this age threshold. Age is verified through the KYC process prior to withdrawal activation, and pub204 conducts periodic audits to detect and close any accounts where the registered Member may not meet the age requirement.

If pub204 discovers or is notified that personal data has been collected from an individual below 21 years of age, that data will be deleted from our systems without delay and the associated account will be permanently closed. If you believe a minor has registered on pub204 using false information, please contact our support team immediately.

With your consent, pub204 may send you promotional communications regarding new games, bonuses, special offers, and Platform updates via SMS to your registered Philippine mobile number or email. Marketing communications are only sent to Members who have opted in during registration or subsequently through account settings.

You may withdraw your marketing consent at any time by updating your communication preferences in your pub204 account settings, or by contacting support via live chat. Withdrawal of marketing consent does not affect the lawfulness of processing conducted before withdrawal, nor does it affect transactional communications necessary to administer your account (such as deposit confirmations and security alerts, which are sent regardless of marketing preference).

pub204 may update this Privacy Policy from time to time to reflect changes in our practices, legal obligations, or regulatory requirements. Material changes to this Policy will be communicated to registered Members via the in-app notification system or by email, with a minimum of 7 days' notice before the changes take effect. The "Last Updated" date at the top of this Policy will be revised to reflect the date of any substantive amendment. Continued use of the pub204 Platform after the effective date of a revised Policy constitutes your acceptance of the updated terms. We encourage Members to review this Privacy Policy periodically.

For any privacy-related questions, concerns, access requests, or complaints regarding how pub204 handles your personal data, please contact us through the following channels:

• 24/7 Live Chat — available in-app from your pub204 account (fastest response for account-specific queries)
• Email: [email protected]

pub204 processes privacy requests in English and Tagalog. Please include your registered mobile number and a description of your request when contacting us for data subject rights matters. Responses to formal written privacy requests are provided within 30 calendar days of receipt.