206 pub Privacy Policy

1. Introduction

206 pub ("we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who interact with our online gaming platform. This Privacy Policy describes how we collect, use, store, share, and protect your personal information when you access or use the 206 pub website and its associated services (collectively, the "Platform").

This policy is issued in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as well as the guidelines issued by the National Privacy Commission (NPC). Where applicable, we also observe the data protection standards required by PAGCOR for licensed online gaming operators.

We encourage you to read this Privacy Policy carefully and in full. If you have questions about any part of it, please contact our Data Protection Officer using the details provided in Section 14.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, the data controller responsible for your personal information is 206 pub, operating the Platform at https://206-pub.app.

We have appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy and our data processing activities. If you wish to exercise any of your rights under the Data Privacy Act, or if you have any concerns about how we handle your personal data, please contact our DPO at the email address listed in Section 14.

3. Personal Data We Collect

Depending on how you interact with the 206 pub Platform, we may collect the following categories of personal data:

We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required for responsible gaming compliance (e.g., self-exclusion records) or as mandated by applicable law.

4. How We Collect Your Data

206 pub collects personal data through the following means:

• Direct Interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated Technologies: Data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies. See Section 8 for more details on our cookie practices.
• Third-Party Sources: Data received from payment processors (GCash, PayMaya, BPI, BDO, Metrobank) for the purpose of verifying and processing financial transactions, and from identity verification service providers for KYC compliance.
• Regulatory Sources: Data received from PAGCOR or other regulatory bodies in connection with our licensing obligations, including self-exclusion registers.

5. How We Use Your Personal Data

206 pub uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your registered account on the Platform, including processing your login credentials and account preferences.
• Identity and Age Verification: To verify that you meet the minimum age requirement of 21 years and to confirm your identity in accordance with KYC and anti-money laundering (AML) obligations.
• Transaction Processing: To process deposits, withdrawals, and bonus credits accurately and securely through your chosen payment method.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Regulatory Compliance: To fulfill our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012, including maintaining required transaction records.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats.
• Responsible Gaming: To monitor gaming patterns, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of problem gambling.
• Platform Improvement: To analyze usage patterns and technical performance data to improve the functionality, reliability, and user experience of the Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have provided consent to receive such communications. You may opt out at any time.

6. Legal Basis for Processing

Under the Data Privacy Act of 2012, 206 pub processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our contract with you, including account registration, transaction processing, and customer support.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including PAGCOR licensing requirements, AMLA obligations, and NPC directives.
• Legitimate Interests: Processing carried out for our legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Data Sharing and Disclosure

206 pub does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya, BPI, BDO, and Metrobank, for the purpose of processing your deposits and withdrawals. These providers are bound by their own privacy policies and applicable financial regulations.
• Identity Verification Providers: Third-party KYC service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government bodies, where disclosure is required by law or regulatory directive.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under strict data processing agreements.
• Legal and Professional Advisors: Lawyers, auditors, and compliance consultants engaged to advise 206 pub on legal and regulatory matters, subject to professional confidentiality obligations.
• Law Enforcement: Where required by a valid court order, subpoena, or other lawful request from Philippine law enforcement authorities.

8. Cookies and Tracking Technologies

206 pub uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain session security, and gather analytics data. The following types of cookies may be used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies and security tokens. They cannot be disabled without affecting core Platform functionality.
• Performance and Analytics Cookies: Used to collect anonymized data about how visitors use the Platform, including pages visited, time spent, and error messages encountered. This data helps us improve Platform performance.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Marketing Cookies: Used to track your interactions with promotional content on the Platform and to measure the effectiveness of our marketing campaigns. These are only activated with your consent.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. A cookie consent notice will be displayed on your first visit to the Platform, allowing you to make informed choices about non-essential cookies.

9. Data Retention

206 pub retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with 206 pub, and for a period of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required under the Anti-Money Laundering Act and PAGCOR regulations.
• KYC and Identity Documents: Retained for five (5) years following the end of the business relationship, or longer if required by a regulatory directive or ongoing investigation.
• Support Communications: Retained for two (2) years from the date of the last interaction, for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of compliance.
• Technical and Usage Data: Retained in anonymized or aggregated form for up to two (2) years for platform analytics purposes.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymized in accordance with our data disposal procedures.

10. Data Security

206 pub implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using TLS 1.2 or higher. Sensitive data at rest, including financial information and identity documents, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular data protection training.
• Two-Factor Authentication: Player accounts support two-factor authentication (2FA) to provide an additional layer of security against unauthorized access.
• Penetration Testing: Our Platform undergoes regular security assessments and penetration testing by independent cybersecurity professionals to identify and remediate vulnerabilities.
• Incident Response: We maintain a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the NPC within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay.

While we take all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

11. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 206 pub:

• Right to Be Informed: The right to be informed about how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• 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 our legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• 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 data controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that your data privacy rights have been violated.

To exercise any of the above rights, please submit a written request to our Data Protection Officer at the contact details provided in Section 14. We will respond to your request within fifteen (15) business days. We may need to verify your identity before processing your request.

12. Children's Privacy

The 206 pub Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gambling regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under the age of 21, we will immediately suspend the associated account, delete the personal data in question, and report the matter to the appropriate regulatory authority. If you believe that a minor has registered on our Platform, please contact us immediately at the details provided in Section 14.

We employ age verification procedures during the registration process to prevent underage access. However, if you are a parent or guardian and have concerns about a minor's use of our Platform, we encourage you to contact our support team without delay.

13. Updates to This Privacy Policy

206 pub 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 requirements. The date of the most recent revision is displayed at the top of this page.

When we make material changes to this Privacy Policy, we will notify registered users via email or through a prominent notice on the Platform at least seven (7) days before the changes take effect. We encourage you to review this Privacy Policy periodically to stay informed about how we are protecting your personal data.

Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with the revised policy, you must cease using the Platform and may request account closure by contacting our support team.

14. Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 206 pub, please contact our Data Protection Officer through the following channels:

If you are not satisfied with our response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.