205 pub Privacy Policy

Introduction

205 pub is committed to protecting the personal information of all individuals who interact with our platform. We recognise that privacy is a fundamental right of every Filipino player, and we take our obligations as a personal information controller seriously under the Data Privacy Act of 2012 (Republic Act No. 10173) and all other applicable Philippine data protection legislation.

This Policy applies to all personal information collected by 205 pub through the Platform, including during account registration, gameplay, deposits and withdrawals, promotional participation, customer support interactions, and any other use of services offered at 205pub.one. It applies regardless of whether you access the Platform from Metro Manila, Cebu, Davao, or any other location within the Philippines.

Please read this Policy in its entirety alongside the 205 pub Terms & Conditions, which are incorporated by reference. Capitalised terms not defined here carry the meanings given to them in the Terms & Conditions.

Data Controller

For the purposes of the Data Privacy Act of 2012, 205 pub acts as the personal information controller in respect of all personal data collected through the Platform. As controller, 205 pub determines the purposes and means by which personal data is processed and bears primary responsibility for ensuring that processing activities comply with applicable Philippine privacy law.

Personal Data We Collect

205 pub collects only the personal information that is necessary and proportionate to the purposes for which it is processed. The categories of personal data we collect include, but are not limited to, those described in the table below:

205 pub does not collect sensitive personal information such as biometric data, health records, religious beliefs, or political opinions unless explicitly required by law for a specific regulatory purpose, in which case Players will be notified separately.

How We Collect Your Data

205 pub collects personal data through the following means:

• Direct submission — information you provide when registering your account, completing KYC, making a deposit or withdrawal request, contacting support, or responding to a promotional survey.
• Automated collection — technical data collected automatically when you access the Platform, including IP address, device identifiers, browser type, and session activity logs generated by our platform infrastructure.
• Payment processors — limited financial data shared by GCash, Maya, BPI, BDO, or other payment service providers in connection with deposit and withdrawal transactions.
• Identity verification services — data returned by third-party KYC service providers following document verification checks.
• Cookies and tracking technologies — session and analytics data collected via cookies as described in Section 10.

Why We Process Your Personal Data

205 pub processes personal data for the following purposes:

• Account management — creating, maintaining, and securing your 205 pub Account throughout its lifecycle.
• Age and identity verification — confirming that all Players are 21 years of age or older, in compliance with PAGCOR regulations and the DPA.
• Transaction processing — executing deposits, withdrawals, and bonus credits to and from your Account wallet.
• Regulatory compliance — meeting obligations under Philippine anti-money laundering laws (Republic Act No. 9160, as amended), PAGCOR requirements, and related legislation.
• Fraud prevention and security — detecting, investigating, and preventing fraudulent activity, account takeovers, and other unauthorised conduct.
• Responsible gaming — monitoring gameplay patterns to identify potential problem gambling and administering self-imposed limits and exclusions.
• Customer support — responding to queries, resolving complaints, and delivering quality service to Players across the Philippines.
• Marketing communications — sending promotional offers, bonus notifications, and platform updates to Players who have provided explicit consent, with an opt-out available at any time.
• Platform improvement — using aggregated, anonymised analytics data to improve site performance, game selection, and user experience.

Legal Basis for Processing

Under the Data Privacy Act of 2012, 205 pub processes personal data on the following legal grounds:

• Consent — for marketing communications, optional analytics, and any processing activities beyond those strictly necessary for contractual performance. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Contractual necessity — for processing required to fulfil the Terms & Conditions governing your Account, including identity verification, payment processing, and gameplay record-keeping.
• Legal obligation — for processing required to comply with applicable Philippine law, including anti-money laundering reporting obligations under Republic Act No. 9160 and PAGCOR compliance requirements.
• Legitimate interests — for fraud prevention, security monitoring, and responsible gaming safeguards, where our interests do not override your privacy rights.

Sharing Your Personal Data

205 pub does not sell, rent, or trade your personal data to unaffiliated third parties for commercial marketing purposes. We share personal data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• Payment service providers (GCash, Maya, BPI, BDO, Coins.ph, and others) — to process deposit and withdrawal transactions on your behalf.
• KYC and identity verification providers — to verify your identity and age as required by PAGCOR guidelines and Philippine law.
• Game software providers — limited technical and session data may be processed by game studios (e.g., Pragmatic Play, Jili, PG Soft) for the purpose of operating their games within the Platform.
• Fraud prevention and security services — to detect and prevent fraudulent account activity, money laundering, or other unlawful conduct.
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and any other Philippine government body with lawful authority to request disclosure.
• Legal and professional advisors — lawyers, accountants, or auditors engaged by 205 pub, subject to strict confidentiality obligations.

All third-party processors engaged by 205 pub are contractually required to process personal data only for the specified purpose, to apply appropriate technical and organisational security measures, and to comply with Philippine data protection law.

International Data Transfers

Some of our service providers and game technology partners may be located outside the Philippines. Where personal data is transferred to countries that have not been assessed as providing an equivalent level of data protection to the Philippines, 205 pub implements appropriate safeguards including contractual clauses that impose obligations on overseas recipients consistent with the requirements of the Data Privacy Act of 2012 and NPC issuances.

Data Retention

205 pub retains personal data for as long as is necessary to fulfil the purposes for which it was collected, to comply with legal and regulatory obligations, and to resolve disputes or enforce agreements. The following general retention periods apply:

• Account and identity data — retained for a minimum of five (5) years following Account closure, as required by Philippine anti-money laundering regulations.
• Transaction records — retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLC and PAGCOR record-keeping requirements.
• KYC documents — retained for the duration of the Account relationship plus five (5) years thereafter.
• Support communications — retained for three (3) years to support dispute resolution and service quality review.
• Marketing preferences — retained until withdrawn by the Player or the Account is closed, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised. Data that has been anonymised in a manner that prevents re-identification may be retained indefinitely for statistical and platform improvement purposes.

Cookies & Tracking Technologies

The 205 pub Platform uses cookies and similar tracking technologies to operate core platform functions, maintain your session state, and gather aggregated usage statistics. Cookies are small text files placed on your device when you visit the Platform. The categories of cookies we use are described below:

• Strictly Necessary Cookies — essential for the Platform to function. These cannot be disabled as they support login sessions, security tokens, and wallet state. No consent is required for these cookies.
• Performance Cookies — collect anonymised data about how Players use the Platform (pages visited, errors encountered, load times) to help us improve user experience. Deployed with your consent.
• Functional Cookies — remember your preferences such as language settings and game filter configurations across sessions. Deployed with your consent.
• Analytics Cookies — used for internal audience analysis on an aggregated, anonymised basis. 205 pub does not deploy third-party advertising cookies or allow advertising networks to track Players across the Platform.

You may manage your cookie preferences through your browser settings at any time. Disabling certain categories of cookies may affect Platform functionality. 205 pub does not use cookies to build advertising profiles or to track Players across unaffiliated websites.

Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 205 pub. These rights may be exercised by submitting a request to [email protected]. 205 pub will respond to verified requests within fifteen (15) business days.

Players who are not satisfied with 205 pub's response to a privacy request have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which serves as the supervisory authority for data protection matters under the DPA.

Minors & Age Policy

If a parent or guardian believes that their minor child has provided personal data to 205 pub, they should contact us immediately at [email protected] so that appropriate steps can be taken. 205 pub takes underage gambling prevention extremely seriously and cooperates fully with PAGCOR's requirements in this area.

Data Security

205 pub implements technical and organisational security measures appropriate to the nature and sensitivity of the personal data we process. These measures include but are not limited to:

• 256-bit SSL/TLS encryption applied to all data transmitted between your device and the 205 pub servers.
• Encrypted storage for sensitive data including payment references and identity document images at rest on our servers.
• Access controls limiting personnel access to personal data to those with a legitimate operational need, subject to confidentiality obligations.
• Intrusion detection systems and continuous security monitoring of platform infrastructure to detect and respond to unauthorised access attempts.
• Two-factor authentication (2FA) available for all Player Accounts to reduce the risk of unauthorised access.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 205 pub will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected Players within the period prescribed by the NPC. Players are encouraged to enable 2FA on their Accounts to reduce exposure to account takeover risks.

Third-Party Links

The 205 pub Platform may contain references to third-party services — such as payment providers like GCash or Maya — that operate under their own privacy policies. 205 pub is not responsible for the privacy practices, content, or data handling of any third-party service. Players are encouraged to review the privacy policies of any external service they interact with in connection with their use of the Platform. 205 pub does not control and is not liable for the data practices of third parties.

Updates to This Privacy Policy

205 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 guidance. Material changes to this Policy will be communicated to registered Players by email to their registered address and by prominent notice on the Platform no less than fourteen (14) days before the changes take effect, unless a shorter period is required by law.

The "Effective Date" displayed at the top of this Policy indicates the date on which the current version came into force. Your continued use of the Platform after the effective date of any updated Policy constitutes your acknowledgment of the changes. If you do not accept the revised Policy, you should cease using the Platform and close your Account by contacting support.

Contact Us & Data Protection Enquiries

For any questions, requests, or concerns relating to this Privacy Policy or to 205 pub's data processing activities, please contact our data protection team through the following channels. We respond to all privacy-related enquiries within fifteen (15) business days.