205 pub Privacy Policy

205 pub ("205 pub," "we," "us," or "our") operates the online gaming platform accessible at https://205pub.win and all associated subdomains, mobile applications, and related digital services (collectively, the "Platform"). We are committed to protecting the privacy and security of the personal data entrusted to us by our Players and site visitors.

This Privacy Policy ("Policy") describes in detail how 205 pub collects, uses, discloses, stores, and protects your personal information in connection with your use of the Platform. It also explains your rights as a data subject under Republic Act No. 10173 (Data Privacy Act of 2012, or "DPA") and its implementing rules and regulations as administered by the National Privacy Commission ("NPC") of the Philippines.

By registering an account with 205 pub, making a deposit, or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you must not use the Platform.

For the purposes of the Philippine Data Privacy Act, the data controller responsible for the personal data collected through the 205 pub Platform is:

205 pub
Operating under PAGCOR's regulatory framework for online gaming in the Philippines
Email: [email protected] (plain text — not a clickable link)
Data Protection Officer: [email protected] (plain text — not a clickable link)

All data subject requests, privacy concerns, and complaints should be directed to the Data Protection Officer contact above. 205 pub is registered with the National Privacy Commission as required under the DPA's implementing rules.

205 pub collects personal data through multiple channels in the ordinary course of platform operations. The categories of data collected include:

205 pub does not intentionally collect sensitive personal information (as defined under Section 3(l) of the DPA) beyond what is strictly required for identity verification and AML compliance. Where sensitive data is collected, it is processed under heightened security controls.

205 pub processes your personal data for the following specific purposes:

• Account Creation and Management: To register your account, verify your identity, maintain your Player profile, and provide access to the 205 pub Platform.
• Transaction Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard; to reconcile financial records; and to prevent payment fraud.
• Regulatory Compliance: To fulfil PAGCOR's licensing conditions, comply with Philippine AML obligations under RA 9160 (as amended), submit required reports to the Anti-Money Laundering Council (AMLC), and respond to lawful requests from government authorities.
• Responsible Gaming: To monitor for indicators of problem gambling, enforce self-exclusion and cooling-off periods, apply deposit and session limits, and comply with PAGCOR's responsible gaming requirements.
• Customer Support: To respond to your queries, complaints, and account issues through live chat, email, and other support channels.
• Platform Improvement: To analyse Platform performance, identify technical issues, personalise your gaming experience, and develop new features based on aggregate usage patterns.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided explicit consent to receive such communications. You may withdraw consent at any time through your account settings.
• Fraud Prevention and Security: To detect and prevent account takeovers, multi-accounting, bonus abuse, and other prohibited conduct as defined in the 205 pub Terms & Conditions.

Under Section 12 and Section 13 of the Philippine Data Privacy Act, 205 pub processes personal data on the following lawful bases:

• Contractual Necessity: Processing required to perform the contract with you (your account registration agreement and these Terms) — covers account management, transaction processing, and customer support.
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, RA 9160 (AMLA), RA 10173 (DPA), and other applicable Philippine laws and regulations.
• Legitimate Interests: Processing necessary for 205 pub's legitimate business interests, including fraud prevention, platform security, and service improvement — provided such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for direct marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

6.1 Service Providers. 205 pub engages third-party service providers to support Platform operations. These include payment processors (GCash/G-Xchange Inc., Maya Bank, BancNet), game content providers (JILI Technology, Pragmatic Play, PG Soft), identity verification providers, cloud infrastructure operators, and customer support software vendors. All service providers are bound by data processing agreements that restrict their use of your data to the specified service purpose only.

6.2 Regulatory Authorities. 205 pub discloses personal data to PAGCOR, the AMLC, the National Privacy Commission, and other Philippine government authorities where required by law or in response to lawful orders, subpoenas, or regulatory audits. 205 pub will notify affected Players of such disclosures to the extent permitted by applicable law.

6.3 No Sale of Data. 205 pub does not sell, rent, licence, or otherwise transfer your personal data to third parties for their independent commercial purposes. Data shared with marketing analytics platforms is anonymised or pseudonymised before transmission.

6.4 Business Transfers. In the event of a merger, acquisition, or sale of all or substantially all of 205 pub's assets, personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. Affected Players will be notified prior to any such transfer.

205 pub uses cookies and similar tracking technologies (local storage, session storage, pixel tags) to operate and improve the Platform. Cookies are small data files stored on your device that enable Platform functionality and analytics.

The categories of cookies used by 205 pub include:

• Strictly Necessary Cookies: Essential for the Platform to function. These enable login session management, security token validation, and shopping cart-equivalent wallet functions. These cookies cannot be disabled without impairing core functionality.
• Performance & Analytics Cookies: Collect anonymised data about how Players use the Platform — pages visited, error messages encountered, load times. Used to improve Platform performance. These require your consent.
• Functional Cookies: Remember your preferences such as language settings, preferred game categories, and display options. These require your consent.
• Responsible Gaming Cookies: Store your session duration data locally to enforce session time limits and display responsible gaming reminders at set intervals.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging into the Platform. Your consent to non-essential cookies can be withdrawn at any time through the cookie preference centre accessible via the Platform's settings menu.

205 pub retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to the following minimum retention requirements imposed by Philippine law:

• Account and KYC Records: Retained for a minimum of five (5) years following account closure, as required by PAGCOR's anti-money laundering compliance framework.
• Transaction Records: Retained for a minimum of five (5) years following the date of the transaction, as required by RA 9160 and PAGCOR's record-keeping requirements.
• Customer Support Communications: Retained for three (3) years following the resolution of the relevant support interaction.
• Marketing Data: Retained until you withdraw consent or request erasure, subject to any applicable legal hold requirements.
• Technical and Log Data: Retained for twelve (12) months for security monitoring purposes, after which it is anonymised or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 205 pub's data disposal policy.

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

• 256-bit SSL/TLS encryption for all data in transit between your device and 205 pub's servers;
• AES-256 encryption at rest for all databases containing personal data;
• PCI-DSS Level 1 compliant payment processing — raw payment credentials are never stored on 205 pub infrastructure;
• Multi-factor authentication (OTP) for high-risk account operations including login from new devices, password changes, and withdrawal requests;
• Role-based access controls ensuring that 205 pub employees access personal data only on a strict need-to-know basis;
• Regular third-party penetration testing and vulnerability assessments conducted by independent cybersecurity firms;
• Incident response procedures with mandatory NPC notification within 72 hours of discovery of a personal data breach affecting 500 or more data subjects, as required by NPC Circular 16-03.

Despite these measures, no online platform can guarantee absolute security. You are encouraged to use a strong, unique password for your 205 pub account and to enable two-factor authentication. Report any suspected security incidents affecting your account immediately to 205 pub support.

Under Republic Act No. 10173, you have the following rights with respect to your personal data held by 205 pub:

To exercise any of these rights, submit a written request to 205 pub's Data Protection Officer at [email protected] (plain text). 205 pub will acknowledge your request within five (5) business days and provide a substantive response within fifteen (15) business days, extendable by a further fifteen (15) days where the complexity of the request warrants it.

Requests for erasure are subject to 205 pub's legal obligations under PAGCOR regulations and Philippine AML law, which may require retention of certain records notwithstanding an erasure request. Where erasure is not possible due to legal obligations, 205 pub will notify you of the specific legal basis for continued retention.

If you are unsatisfied with 205 pub's response to a data subject request, you have the right to lodge a complaint with the National Privacy Commission via its official channels.

The 205 pub Platform is strictly intended for adults aged 21 years and older, as required by PAGCOR's responsible gaming regulations applicable to casino-style online gaming in the Philippines.

205 pub does not knowingly collect personal data from persons under the age of 21. Age verification controls are implemented at the point of registration, and additional verification may be requested at any time. If 205 pub becomes aware that personal data has been collected from a person under 21 years of age, the account will be immediately closed, the data deleted (subject to any applicable legal retention obligations), and any funds returned to the source payment method.

If you are a parent or guardian and believe your child has registered an account on the 205 pub Platform, please contact support immediately at [email protected] (plain text). 205 pub will investigate and act promptly.

Certain 205 pub service providers — including game content providers, cloud infrastructure operators, and analytics platforms — may be located outside the Philippines. Where personal data is transferred to third parties in other jurisdictions, 205 pub ensures that such transfers are made:

• Only to countries with an adequate level of data protection as determined by the NPC or the European Commission (for GDPR-equivalent reference purposes);
• Subject to binding contractual arrangements (standard contractual clauses or equivalent) that impose the same data protection standards required under Philippine law;
• With your explicit consent, where required by the DPA for transfers to jurisdictions without adequate protection frameworks.

A list of countries to which 205 pub transfers personal data is available upon request from the Data Protection Officer.

205 pub may update this Privacy Policy from time to time to reflect changes in applicable law, regulatory guidance, platform functionality, or our data processing practices. Material changes — those that significantly affect your rights or how your data is processed — will be communicated to registered Players via email to the address on file and/or via a prominent on-platform notice at least seven (7) calendar days before the change takes effect.

Non-material updates (such as clarifications of existing language, formatting changes, or corrections of typographical errors) may be made without prior notice. The "Last updated" date at the top of this Policy will reflect the most recent revision. We encourage you to review this Policy periodically to stay informed about how 205 pub protects your personal data.

Your continued use of the 205 pub Platform after the effective date of any Policy update constitutes your acknowledgement of, and agreement to, the revised Policy.

For all privacy-related enquiries, data subject rights requests, and complaints, please contact 205 pub's designated Data Protection Officer:

• DPO Email: [email protected] (plain text — not clickable)
• General Support: [email protected] (plain text — not clickable)
• Live Chat: Available 24/7 within the 205 pub Platform (Filipino and English)
• Response Time: Acknowledgement within 5 business days; substantive response within 15 business days

205 pub is committed to resolving all privacy concerns promptly, fairly, and in full compliance with Philippine data protection law. If you remain unsatisfied after engaging with our DPO, you may file a complaint with the National Privacy Commission (NPC) of the Philippines through its official website and channels.