206 pub Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") describes how 206 pub ("we", "us", "the Company", "206 pub") collects, uses, discloses, stores, and protects the personal data of users ("you", "Player", "Data Subject") who access and use the 206 pub online gaming platform at 206pub.one and all associated services.

1.2 206 pub is committed to protecting your privacy and handling your personal data responsibly, transparently, and in full compliance with the Philippines' Data Privacy Act of 2012 (Republic Act 10173), its Implementing Rules and Regulations, the issuances of the National Privacy Commission (NPC), and all other applicable Philippine laws and regulations.

1.3 By registering an account with 206 pub, you acknowledge that you have read, understood, and consent to the practices described in this Policy. If you do not agree to this Policy, you must not use the 206 pub platform. This Policy should be read together with the 206 pub Terms & Conditions.

2. Data Controller Information

2.1 206 pub is the Data Controller responsible for your personal data collected through the 206pub.one platform. As Data Controller, 206 pub determines the purposes and means of processing your personal data and is accountable for ensuring that processing is lawful, fair, and transparent.

2.2 206 pub has designated a Data Protection Officer (DPO) as required under the Data Privacy Act. The DPO is responsible for overseeing compliance with this Policy and applicable data privacy laws. You may contact the DPO at the address provided in Section 13 of this Policy.

3. Personal Data We Collect

3.1 206 pub collects personal data from you in the following categories:

3.2 206 pub does not collect sensitive personal information beyond what is strictly necessary for KYC compliance and responsible gaming obligations. We do not collect biometric data, political opinions, religious beliefs, or health data unless specifically required by a regulatory process and disclosed separately at the point of collection.

3.3 You are not obligated to provide all requested personal data; however, failure to provide data required for KYC verification or account registration may prevent you from accessing certain 206 pub services, including deposits and withdrawals.

4. How We Use Your Personal Data

4.1 206 pub processes your personal data for the following purposes:

• Account Management: To create, maintain, and administer your 206 pub player account, including login authentication and account security;
• Service Delivery: To provide access to 206 pub games, process bets, calculate and credit winnings, and deliver all features of the platform;
• Payment Processing: To process deposits via GCash, PayMaya, BPI, BDO, Metrobank, and 7-Eleven, and to process withdrawal requests;
• Identity Verification (KYC): To verify your identity and age (21+) in compliance with PAGCOR licensing requirements and Philippine AML regulations;
• Anti-Money Laundering (AML) Compliance: To monitor transactions, report suspicious activity to the AMLC (Anti-Money Laundering Council) as required by Republic Act 9160 (Anti-Money Laundering Act) and its amendments;
• Responsible Gaming: To monitor gaming patterns, enforce deposit limits and self-exclusion tools, and identify players who may be experiencing gambling-related harm;
• Customer Support: To respond to support queries, resolve disputes, and maintain records of interactions;
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — only where you have provided consent and not opted out. You may withdraw marketing consent at any time via account settings or by contacting support;
• Platform Security: To detect, prevent, and investigate fraud, cheating, bot activity, and other security incidents;
• Legal & Regulatory Compliance: To comply with applicable Philippine laws, regulatory directions from PAGCOR and the NPC, and court orders.

5. Legal Basis for Processing

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

• Consent: For marketing communications and optional data processing activities where consent is the most appropriate basis. You may withdraw consent at any time;
• Contractual Necessity: Processing necessary to perform the contract between you and 206 pub (the Terms & Conditions), including account management, game delivery, and payment processing;
• Legal Obligation: Processing required to comply with applicable Philippine law, including KYC/AML obligations under PAGCOR regulations, RA 9160, and NPC issuances;
• Legitimate Interests: Processing necessary for 206 pub's legitimate business interests, including platform security, fraud prevention, and responsible gaming monitoring, where these interests are not overridden by your data privacy rights.

6. Data Sharing & Disclosure

6.1 206 pub does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your personal data only in the following circumstances:

• Game Providers: 206 pub shares necessary session data with licensed game providers (e.g., JILI, PG Soft, Pragmatic Play) solely to enable game functionality. Game providers are contractually bound to process data only for this purpose;
• Payment Processors: Financial data necessary to process transactions is shared with payment providers (GCash, PayMaya, BPI, BDO, Metrobank). These providers are governed by their own privacy policies and applicable BSP regulations;
• Regulatory Authorities: 206 pub will disclose personal data to PAGCOR, the AMLC, the NPC, and other Philippine regulatory bodies as required by law, including mandatory suspicious transaction reporting under the AMLA;
• Law Enforcement: 206 pub will disclose personal data in response to valid legal orders, subpoenas, or requests from Philippine law enforcement agencies with proper jurisdiction;
• Service Providers: 206 pub engages third-party service providers for technical infrastructure, customer support systems, and identity verification. These providers process data only on 206 pub's documented instructions under data processing agreements;
• Corporate Transactions: In the event of a merger, acquisition, or asset sale, player data may be transferred to the acquiring entity. Affected players will be notified via their registered contact details prior to any such transfer.

7. Cookies & Tracking Technologies

7.1 206 pub uses cookies and similar tracking technologies on the 206pub.one platform. Cookies are small data files placed on your device that help us deliver a functional and personalised experience.

7.2 We use the following categories of cookies:

• Strictly Necessary Cookies: Required for core platform functionality — login sessions, security tokens, and session state. These cannot be disabled without breaking the platform;
• Performance Cookies: Collect anonymised data on how players interact with the platform to help us identify and fix issues. No personally identifiable information is included in performance cookie data;
• Functional Cookies: Remember your preferences, such as language settings and game lobby display options;
• Analytics Cookies: Help us understand aggregate player behaviour to improve the 206 pub platform. Data is processed in anonymised or pseudonymised form.

7.3 You may configure your browser to refuse or delete cookies. Note that disabling strictly necessary cookies will impair your ability to use the 206 pub platform, including the login and payment functions.

8. Data Retention

8.1 206 pub retains your personal data for as long as necessary to fulfil the purposes described in this Policy, including ongoing contractual, legal, and regulatory obligations.

8.2 Specific retention periods are as follows:

• Account Data: Retained for the duration of your account plus five (5) years after account closure, in compliance with PAGCOR record-keeping requirements;
• Financial & Transaction Records: Retained for a minimum of ten (10) years from the date of the transaction, as required by RA 9160 (AMLA) and its amendments;
• KYC Documents: Retained for the duration of the account relationship plus five (5) years, or longer if required by a regulatory investigation;
• Communications Records: Retained for a minimum of three (3) years;
• Technical Logs: Retained for a maximum of twelve (12) months unless required longer for a specific security investigation.

8.3 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be attributed to any identifiable individual.

9. Data Security

9.1 206 pub implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 206 pub servers;
• Encryption of sensitive data at rest, including financial data and KYC documents;
• Role-based access controls ensuring only authorised 206 pub personnel can access specific categories of personal data;
• Regular security assessments, penetration testing, and vulnerability scanning;
• Mandatory security training for all 206 pub staff who handle personal data.

9.2 Data Breach Notification. In the event of a personal data breach that is likely to result in harm to affected players, 206 pub will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players within reasonable time thereafter, in accordance with NPC Circular 16-03.

10. Your Data Subject Rights

10.1 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: To know how your personal data is being collected, processed, and used — this Policy fulfils that obligation;
• Right of Access: To request a copy of the personal data 206 pub holds about you;
• Right to Rectification: To request correction of inaccurate or incomplete personal data. You may update most account information directly in your 206 pub account settings;
• Right to Erasure (Right to be Forgotten): To request deletion of your personal data. Note that this right is subject to 206 pub's legal obligations to retain certain data — we will inform you of any applicable retention requirements at the time of your request;
• Right to Object: To object to the processing of your personal data on the basis of legitimate interests or for direct marketing purposes;
• Right to Data Portability: To receive your personal data in a structured, commonly used, machine-readable format where processing is carried out by automated means;
• Right to Lodge a Complaint: To lodge a complaint with the National Privacy Commission (NPC) if you believe 206 pub has processed your data unlawfully.

10.2 To exercise any of these rights, please contact the 206 pub Data Protection Officer using the contact details in Section 13. 206 pub will respond to verified requests within fifteen (15) business days.

11. Children's Privacy

11.1 The 206 pub platform is strictly for adults aged twenty-one (21) years and older. We do not knowingly collect personal data from any person under 21 years of age. If we discover that personal data has been collected from an underage individual, we will immediately delete that data and close the associated account.

11.2 If you believe that a minor has registered with 206 pub, please contact our support team immediately at the contact details provided in Section 13.

12. Changes to This Privacy Policy

12.1 206 pub may update this Privacy Policy from time to time to reflect changes in our data practices, regulatory requirements, or platform features. Material changes will be communicated to registered players via their registered mobile number or email address at least fourteen (14) days before the changes take effect.

12.2 The "Last updated" date at the top of this Policy reflects the most recent revision. Continued use of the 206 pub platform after the effective date of any changes constitutes your acceptance of the updated Policy.

12.3 We encourage you to review this Policy periodically so that you are always aware of how 206 pub handles your personal data.

13. Contact & Complaints

If you have questions about this Privacy Policy, wish to exercise your data subject rights, or wish to raise a concern about 206 pub's data practices, please contact the 206 pub Data Protection Officer:

You may also access 206 pub's live chat support 24/7 from within your logged-in account for general privacy queries.

If you are unsatisfied with 206 pub's response to your privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission of the Philippines (NPC) through its official channels.