Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how 206pub ("206pub," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal data of users ("you," "your," or "User") who access or use the 206pub online gaming platform located at 206pub.vip (the "Platform").

206pub takes data privacy seriously. As a platform primarily serving users in the Philippines, we operate in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). Where operations or data processing involve users in other jurisdictions, we apply the higher applicable standard.

We encourage you to read this Policy in full. If any part is unclear, please contact our Data Protection Officer using the details provided in Section 15. This Policy applies to all personal data collected via the Platform, our mobile-optimized site, customer communications, and any other touchpoint between you and 206pub.

2 Personal Data We Collect

206pub collects personal data in several categories depending on how you interact with our Platform. The following table summarizes the primary categories of data collected:

3 How We Collect Your Data

3.1 Directly From You

Most personal data we hold is collected directly from you when you:

• Register a 206pub account and complete the onboarding process
• Submit KYC verification documents through your account settings
• Make a deposit or request a withdrawal via GCash, PayMaya, or bank transfer
• Contact 206pub's customer support team via live chat or email
• Respond to surveys, participate in promotions, or complete responsible gaming assessments
• Update your account profile, preferences, or responsible gaming settings

3.2 Automatically Via the Platform

When you access and use the 206pub Platform, certain data is collected automatically through server logs, cookies, and session tracking technology. This includes your IP address, device identifiers, browser characteristics, pages visited, game rounds played, and time spent on the Platform. This data is collected to ensure Platform security, optimize performance, and detect fraudulent activity.

3.3 From Third Parties

206pub may receive personal data about you from trusted third parties in limited circumstances, including:

• Payment processors (e.g., GCash, PayMaya, bank partners) confirming transaction completion
• Identity verification service providers used to validate KYC documents
• Fraud detection and anti-money laundering screening services
• Game providers, where game interaction data is passed back to 206pub for wallet reconciliation and reporting

4 Legal Basis for Processing

Under the Philippine Data Privacy Act, 206pub relies on the following legal grounds for processing your personal data:

• Contractual Necessity: Processing required to fulfill our obligations under the 206pub Terms & Conditions — including account management, payment processing, and game service delivery.
• Legal Obligation: Processing necessary to comply with applicable laws, including anti-money laundering (AML) requirements, PAGCOR-related regulatory obligations, tax reporting, and responses to lawful authority requests.
• Legitimate Interests: Processing conducted in pursuit of 206pub's legitimate business interests, including fraud prevention, Platform security, responsible gaming monitoring, and service improvement — provided that these interests are not overridden by your rights and freedoms.
• Consent: Where you have provided explicit, informed consent to specific processing activities — primarily for the sending of marketing communications and optional analytics participation. You may withdraw consent at any time.

5 How We Use Your Personal Data

206pub uses the personal data we collect for the following purposes:

• Account Creation and Management: To register your 206pub account, verify your identity and age, maintain your profile, and administer your relationship with 206pub.
• Service Delivery: To provide access to 206pub's full game library, process bets, calculate and credit winnings, and ensure the general operation of the Platform.
• Payment Processing: To process deposits via GCash, PayMaya, BPI, BDO, Metrobank, and other accepted Philippine payment channels; to verify transaction legitimacy; and to process withdrawal requests to your verified payment method.
• Regulatory Compliance: To fulfill obligations under PAGCOR regulations, anti-money laundering laws, and other applicable Philippine legislation — including maintaining records required by law and responding to regulatory inquiries.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, cheating, money laundering, and other prohibited conduct on the Platform.
• Responsible Gaming: To monitor for patterns indicative of problem gambling, to implement self-imposed limits and self-exclusion requests, and to communicate responsible gaming information where appropriate.
• Customer Support: To respond to your inquiries, resolve disputes, process complaints, and provide assistance through 206pub's live chat and email support channels.
• Platform Improvement: To analyze Platform usage patterns, troubleshoot technical issues, improve game recommendations, and optimize the user experience for Filipino players.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates — only where you have opted in to receive such communications.

6 Data Sharing and Disclosure

6.1 Permitted Sharing

206pub does not sell, rent, or trade your personal information. We share personal data with third parties only where strictly necessary for the legitimate operation of the Platform or where required by law:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay/PESONet partners receive transaction data necessary to complete deposits and withdrawals.
• KYC and Verification Providers: Third-party identity verification services receive document and biometric data for the purpose of verifying your identity, age, and residency.
• Game Technology Providers: Licensed game studios and RNG providers receive session data necessary to operate games and reconcile bet results.
• IT Infrastructure and Security Providers: Cloud hosting, cybersecurity, and fraud detection vendors who process data on our behalf under strict data processing agreements.
• Regulatory and Law Enforcement Authorities: Where legally required, we will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or other competent Philippine authorities.

6.2 Data Processing Agreements

All third-party service providers who process personal data on behalf of 206pub are bound by written data processing agreements that require them to process data only for specified purposes, maintain appropriate security measures, and comply with applicable data privacy laws.

7 Cookies and Tracking Technologies

7.1 What We Use

The 206pub Platform uses cookies and similar tracking technologies (including local storage and session identifiers) to operate the Platform, remember your preferences, maintain your login session, and gather analytics data about Platform usage.

7.2 Types of Cookies

• Strictly Necessary Cookies: Required for the Platform to function. These include session cookies that maintain your logged-in state and security cookies that protect against cross-site request forgery. These cannot be disabled without impairing Platform functionality.
• Functional Cookies: Enable personalized features such as remembering your game preferences, language settings, and responsible gaming limit configurations.
• Analytics Cookies: Help 206pub understand how users navigate the Platform — which game categories are most visited, where users encounter difficulty, and how the Platform performs across different devices and networks. Data collected is aggregated and anonymized where possible.
• Security and Fraud Prevention Cookies: Used to detect and investigate suspicious activity, unauthorized access attempts, and potential fraud.

7.3 Managing Cookies

You can manage cookie preferences through your browser settings. Please note that disabling certain cookies may affect Platform functionality — in particular, disabling session cookies will prevent you from remaining logged in to your 206pub account. Detailed cookie preferences can also be managed through your 206pub account settings.

8 Data Retention

206pub retains personal data for the period necessary to fulfil the purposes for which it was collected, subject to any longer retention period required by applicable law. The following general retention principles apply:

At the end of the applicable retention period, personal data is securely deleted or anonymized in a manner that makes re-identification impossible. Where data cannot be immediately deleted due to technical constraints, it is isolated and protected from further active processing until deletion is completed.

9 Data Security

206pub implements a multi-layered security architecture to protect personal data against unauthorized access, disclosure, alteration, or destruction. Our security measures include, but are not limited to:

• Transport Encryption: All data transmitted between your device and 206pub's servers is encrypted using TLS 1.3 with 256-bit AES encryption.
• Data-at-Rest Encryption: Sensitive personal and financial data stored in 206pub's databases is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data within 206pub's systems is governed by role-based access controls. Staff access is limited to data required for their specific job function and is subject to regular access review.
• Password Security: User passwords are stored exclusively as salted cryptographic hashes. Plain-text passwords are never stored or transmitted by 206pub.
• Two-Factor Authentication: 206pub offers and recommends two-factor authentication (2FA) for all user accounts to prevent unauthorized access even where credentials are compromised.
• Penetration Testing and Audits: 206pub's systems are subject to regular third-party security audits and penetration testing to identify and remediate vulnerabilities.
• Incident Response: 206pub maintains a documented data breach response plan. In the event of a personal data breach, 206pub will notify affected users and the National Privacy Commission as required under Philippine law.

10 Your Rights Under Philippine Privacy Law

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

To exercise any of these rights, contact the 206pub Data Protection Officer using the details in Section 15. We will respond to all verified requests within thirty (30) days. In cases of complexity, this period may be extended by a further sixty (60) days, with notice provided to you within the initial thirty-day window.

11 Children's Privacy

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

If you are a parent or guardian and become aware that a person under 21 has provided personal data to 206pub or accessed the Platform, please contact us immediately at the details in Section 15. 206pub will take prompt steps to deactivate the account and delete all associated personal data upon verification of the age violation.

12 Cross-Border Data Transfers

206pub's primary operations and data storage are based in the Philippines. In certain circumstances, personal data may be transferred to, or accessed from, locations outside the Philippines — for example, where a third-party technology provider or game studio operates servers in another country.

Where such transfers occur, 206pub ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that provided by Philippine law. These safeguards may include contractual protections in the form of standard data transfer clauses, certification of equivalent data protection standards in the receiving country, or other mechanisms recognized under the Philippine Data Privacy Act.

206pub will not transfer your personal data to a foreign country or international organization that does not provide an adequate level of data protection without your explicit consent, except where required by applicable law.

13 Marketing and Promotional Communications

13.1 Opt-In Basis

206pub will only send you marketing communications — including promotional emails, SMS notifications, and push notifications regarding bonuses, new games, and special offers — where you have provided explicit consent to receive such communications. Consent is collected during account registration and can be updated at any time in your 206pub account communication preferences.

13.2 Opting Out

You may opt out of marketing communications at any time by:

• Updating your communication preferences in the 206pub account settings dashboard
• Clicking the unsubscribe link included in any marketing email from 206pub
• Contacting 206pub's customer support team and requesting removal from marketing lists

Opting out of marketing communications will not affect the delivery of transactional communications — such as deposit confirmations, withdrawal notifications, account security alerts, and responsible gaming messages — which are sent as a necessary part of operating your 206pub account.

13.3 Responsible Gaming Exclusion

Users who have activated self-exclusion or a cooling-off period on their 206pub account will be automatically removed from all marketing communications lists for the duration of their exclusion period. 206pub will not send any promotional material to self-excluded users.

14 Changes to This Privacy Policy

206pub reviews and updates this Privacy Policy periodically to reflect changes in our data processing practices, applicable law, regulatory guidance, or Platform features. When material changes are made, we will:

• Update the "Last Updated" date at the top of this Policy
• Where the change is significant, notify registered users via the email address associated with their 206pub account and/or through a notice displayed upon login
• Maintain previous versions of this Policy available upon request for a period of at least 12 months

Continued use of the 206pub Platform after any update to this Policy constitutes your acceptance of the revised Policy. If you do not agree with any change, you should discontinue use of the Platform and close your account. Your account data will be handled in accordance with the version of the Policy in effect at the time of account closure for the applicable retention periods.

15 Contact and Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy, your personal data held by 206pub, or the exercise of your rights under the Philippine Data Privacy Act, please contact 206pub's Data Protection Officer (DPO) through the following channels:

• Live Chat: Available 24/7 through the 206pub Platform — mention "Privacy / Data Request" to be routed appropriately.
• Email: [email protected] — subject line: "Privacy Policy Inquiry" or "Data Subject Request".
• Account Help Center: Accessible after logging in to your 206pub account dashboard under the Privacy & Data section.

We will acknowledge all data subject requests within five (5) business days and provide a substantive response within the timeframes required under the Philippine Data Privacy Act. For complaints that cannot be resolved directly with 206pub, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.