Privacy Policy – 203pub

1. Introduction

This Privacy Policy ("Policy") describes how 203pub ("the Company," "we," "us," or "our") collects, processes, stores, and discloses personal information in connection with your use of the website https://203pub.co and all associated gaming services (collectively, "the Platform").

203pub is committed to protecting the personal information of all registered players and website visitors in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and applicable issuances of the National Privacy Commission (NPC) of the Philippines. We are registered as a personal information controller with the NPC.

This Policy applies to all personal information collected through the Platform, whether submitted directly by you during registration, generated automatically through your use of our services, or received from trusted third-party sources in the course of identity verification and payment processing.

2. Personal Data We Collect

2.1 Registration and Identity Data

• Full legal name as it appears on a government-issued ID
• Date of birth (used to verify 21+ age eligibility)
• Philippine mobile number and email address
• Residential address in the Philippines
• Username and encrypted password hash

2.2 Know Your Customer (KYC) Documents

• Government-issued photo ID (PhilSys national ID, driver's license, passport, UMID, or SSS/GSIS ID)
• Proof of address (utility bill, bank statement, or barangay certification)
• Selfie or liveness verification image for identity matching
• Source of funds documentation for high-value accounts as required by PAGCOR and AMLC regulations

2.3 Financial and Transaction Data

• GCash or PayMaya account number (partial, masked)
• Bank account details for BPI, BDO, or Metrobank withdrawals (partial, masked)
• Deposit and withdrawal transaction history
• Bonus credit and wagering activity records

2.4 Platform Usage Data

• Game history, session duration, and bet records
• Login timestamps and device identifiers
• IP address and approximate geographic location
• Browser type, operating system, and screen resolution
• Customer support chat logs and email correspondence

3. How We Collect Personal Data

203pub collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, contacting support, or filling in any platform form.
• Automatic collection: Technical data collected through cookies, log files, and analytics tools when you browse or use the Platform.
• Third-party providers: Identity verification data from our KYC partners; transaction confirmation data from GCash, PayMaya, and banking partners; fraud screening data from security service providers.
• Regulatory sources: Where required by PAGCOR or AMLC, we may receive or cross-reference data from authorized regulatory databases.

4. How We Use Your Personal Data

203pub processes your personal data for the following purposes:

• Account creation and management: To register, verify, and maintain your 203pub account.
• Age and identity verification: To confirm that you are at least 21 years of age and that your identity matches the information provided, as required by PAGCOR.
• Payment processing: To facilitate GCash, PayMaya, and bank deposits and withdrawals denominated in Philippine Peso (PHP).
• Regulatory compliance: To fulfill our obligations under the Data Privacy Act, PAGCOR licensing conditions, and the Anti-Money Laundering Act, including filing Covered Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) with the AMLC where required.
• Platform security and fraud prevention: To detect and investigate unauthorized access, bonus abuse, multi-accounting, and other prohibited conduct.
• Customer support: To respond to your queries, resolve disputes, and process responsible gaming requests such as self-exclusion.
• Service improvement: To analyze platform usage patterns and improve game offerings, interface design, and system performance.
• Marketing communications: With your explicit consent, to send you promotional offers, bonus notifications, and platform updates via email or SMS. You may withdraw this consent at any time.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our obligations under the account agreement, including account management, game provision, and payment processing.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, AMLC reporting requirements, NPC registration obligations, and other applicable Philippine law.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where our interests do not override your privacy rights.
• Consent: Processing for direct marketing communications, where you have given explicit, informed, and freely given consent.

6. Data Sharing and Disclosure

203pub does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your data only in the following circumstances:

• Service providers: KYC verification partners, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), IT infrastructure providers, and fraud detection services — all bound by data processing agreements and confidentiality obligations.
• Regulatory authorities: PAGCOR, the AMLC, the National Privacy Commission, and law enforcement agencies where disclosure is required by law, court order, or valid regulatory demand.
• Self-exclusion registries: Where required by PAGCOR responsible gaming regulations, minimum account data may be shared with national self-exclusion databases.
• Business transfers: In the event of a merger, acquisition, or sale of substantially all assets, your data may be transferred to the successor entity, subject to equivalent privacy protections.

All third-party service providers engaged by 203pub are contractually required to process your data only for the specified purpose, maintain appropriate security measures, and comply with the Data Privacy Act of 2012.

7. Data Retention

203pub retains personal data for as long as necessary to fulfill the purposes set out in this Policy, subject to the following minimum retention periods required by Philippine law:

• Account and KYC records: Five (5) years from the date of account closure, as required by PAGCOR and AMLC regulations.
• Financial transaction records: Five (5) years from the date of each transaction, in compliance with the AMLA.
• Customer support records: Three (3) years from the date of the last interaction.
• Marketing consent records: Retained until withdrawal of consent plus one (1) year for compliance documentation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification.

8. Security Measures

203pub implements technical and organizational security measures appropriate to the sensitivity of personal data processed on the Platform:

• TLS 1.3 encryption on all data transmitted between your device and 203pub servers.
• AES-256 encryption for stored sensitive data, including KYC documents and financial records.
• Multi-factor authentication available for all player accounts.
• Role-based access controls limiting internal staff access to personal data on a need-to-know basis.
• Regular third-party penetration testing and vulnerability assessments.
• Incident response procedures including NPC notification within 72 hours in the event of a data breach affecting personal data.

While 203pub takes all reasonable precautions, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access.

9. Cookies and Tracking Technologies

203pub uses cookies and similar tracking technologies to operate and improve the Platform. The categories of cookies used are:

• Strictly necessary cookies: Required for platform operation, session management, and security. Cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and game lobby layout.
• Analytics cookies: Collect aggregated, anonymized data about how players use the Platform to help us improve service quality.

You may manage non-essential cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Platform.

10. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by 203pub:

• Right to be informed: To know what personal data we collect, how we use it, and with whom we share it.
• Right to access: To request a copy of the personal data we hold about you.
• Right to rectification: To request correction of inaccurate or incomplete personal data.
• Right to erasure: To request deletion of your personal data, subject to our legal retention obligations.
• Right to object: To object to processing based on legitimate interests or for direct marketing purposes.
• Right to data portability: To receive your personal data in a structured, commonly used format.
• Right to file a complaint: To lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of the above rights, contact our Data Protection Officer at: [email protected] (plain text — not a clickable link). We will respond to verified requests within fifteen (15) business days.

11. Minors and Age Restriction

203pub strictly prohibits the use of the Platform by persons under 21 years of age. We do not knowingly collect personal data from individuals below 21. All accounts are subject to age verification as part of the KYC process. If we discover that personal data has been collected from an individual under 21, we will immediately suspend the account, delete the collected data, and return any deposited funds to the originating payment method.

If you are a parent or guardian and believe that a minor has accessed the Platform or provided personal data to 203pub, please contact our support team immediately.

12. Changes to This Privacy Policy

203pub may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. Material changes will be communicated to registered users via email or in-platform notification at least seven (7) days before the changes take effect. The "Last updated" date at the top of this page reflects the most recent revision. Your continued use of the Platform after the effective date of any revision constitutes your acknowledgment of the updated Policy.

13. Contact and Data Protection Officer

For any privacy-related questions, requests to exercise your data rights, or concerns about how 203pub handles your personal information, please contact our Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 via the platform support widget
• Response time: Within 15 business days for formal DPA rights requests

You also have the right to file a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with our response to your privacy concerns.