pub204 Privacy Policy — How We Handle Your Personal Data

This Privacy Policy describes how pub204 collects, uses, stores, protects, and discloses the personal information of individuals who visit, register with, or use the pub204 online gaming platform available at pub204.app (the "Platform").

This Policy applies to:

• All registered players who hold a pub204 account, whether active, dormant, or closed.
• Visitors who access the pub204 website without completing registration.
• Individuals who contact pub204 through any support or inquiry channel.
• Any person whose personal data is submitted to pub204 for KYC identity verification purposes.

This Policy does not apply to the privacy practices of third-party game studios, payment processors, or other external services linked to or integrated with pub204. Those entities operate under their own privacy policies, which pub204 encourages players to review independently.

For the purposes of the Philippine Data Privacy Act of 2012, pub204 acts as the Personal Information Controller (PIC) with respect to the personal data collected from users of the Platform. As PIC, pub204 determines the purposes and means of processing your personal data and is responsible for ensuring that processing is conducted lawfully, fairly, and transparently.

pub204 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data privacy law. Contact details for the pub204 DPO are provided in Section 16 of this Policy.

pub204 collects personal data through several channels: directly from you during registration and account use, automatically through your interaction with the Platform, and from third parties as required for regulatory compliance. The categories of data collected are described below.

3.1 Data You Provide Directly

3.2 Data Collected Automatically

pub204 processes personal data for the following specific, declared purposes only. Data collected for one purpose will not be repurposed for an incompatible use without your explicit consent or a legal obligation requiring us to do so.

• Account Management: Creating, maintaining, and securing your pub204 account; verifying your identity at login; processing password resets and account recovery.
• KYC Compliance: Verifying your identity and age as required by PAGCOR regulations and the Philippine Anti-Money Laundering Act (AMLA). This is a legal obligation and cannot be waived.
• Payment Processing: Facilitating deposits via GCash, PayMaya, and Philippine bank transfers; processing withdrawal requests to your verified payment method; maintaining transaction records for regulatory and audit purposes.
• Gaming Service Delivery: Providing access to games, recording wager outcomes, processing winnings, calculating and crediting bonuses, delivering real-time gaming experiences.
• Regulatory Compliance: Meeting PAGCOR's operator requirements, AMLA transaction monitoring obligations, and reporting requirements to government authorities as mandated by Philippine law.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behavior; enforcing deposit limits, cooling-off periods, and self-exclusion orders; operating pub204's responsible gaming tools.
• Fraud Prevention & Security: Detecting and preventing unauthorized account access, bonus abuse, collusion, money laundering, and other prohibited conduct.
• Customer Support: Responding to player inquiries, processing complaints, and resolving disputes.
• Platform Improvement: Analyzing aggregated, anonymized usage data to improve platform performance, game selection, and user experience.
• Marketing Communications (with consent): Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive marketing communications from pub204.

Under the Philippine Data Privacy Act of 2012, pub204 processes personal data only where a lawful basis exists. The applicable legal bases for pub204's processing activities are as follows:

• Contract Performance: Processing necessary to perform the gaming services contract with you — account management, game delivery, payment processing.
• Legal Obligation: Processing required to comply with PAGCOR licensing requirements, AMLA obligations, National Privacy Commission requirements, and other applicable Philippine laws — including KYC verification and transaction monitoring.
• Legitimate Interests: Processing conducted in furtherance of pub204's legitimate business interests, including fraud detection, platform security, and responsible gaming monitoring, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and optional analytics. Consent is obtained explicitly and can be withdrawn at any time without affecting your ability to use pub204.

pub204 does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. Your data is shared only in the circumstances described below:

6.1 Regulatory Authorities

pub204 shares personal data and transaction records with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies as required by law. Disclosure to these authorities is mandatory and not subject to your consent.

6.2 Payment Processors

To process your deposits and withdrawals, pub204 shares limited personal data — including account identifiers and transaction amounts — with GCash, PayMaya, and Philippine banking partners. These processors act as Personal Information Processors (PIPs) under pub204's instruction and are contractually prohibited from using your data for any purpose other than payment processing.

6.3 KYC Verification Service Providers

pub204 uses PAGCOR-approved identity verification service providers to process KYC document submissions and biometric selfie matching. These providers access identity data solely for verification purposes under strict contractual data protection obligations.

6.4 Game Software Providers

Third-party game studios whose content is hosted on pub204 receive limited technical session data (such as player session tokens) necessary to deliver their games. These providers do not receive your identity documents, payment information, or contact details.

6.5 Law Enforcement

pub204 will disclose personal data to law enforcement or judicial authorities in the Philippines where required by a lawful order, warrant, or applicable law. pub204 will notify affected players of such disclosure where legally permitted to do so.

pub204 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, subject to minimum retention periods mandated by Philippine law.

Following the expiry of the applicable retention period, pub204 will securely delete or anonymize your personal data in a manner that prevents reconstruction. Where anonymization is used, the resulting anonymized data may be retained indefinitely for statistical and analytical purposes as it no longer constitutes personal data.

pub204 implements appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption in Transit: All data transmitted between your device and pub204's servers is encrypted using TLS 1.2 or higher (256-bit SSL). This applies to all Platform pages, login sessions, payment flows, and API communications.
• Encryption at Rest: Sensitive personal data — including identity documents and financial information — is encrypted at rest using AES-256 encryption on pub204's servers.
• Password Hashing: Account passwords are never stored in plaintext. pub204 uses industry-standard cryptographic hashing with salting for all stored credentials.
• Access Controls: Personal data is accessible only to pub204 staff who require it to perform their specific job function. Access is role-based and subject to logging and audit.
• Two-Factor Authentication: 2FA is available to all pub204 players and is strongly recommended. pub204 staff accounts with access to personal data require mandatory 2FA.
• Regular Security Audits: pub204 conducts periodic internal security reviews and engages third-party security assessments of its platform and data handling infrastructure.

pub204 uses cookies and similar tracking technologies to operate the Platform, maintain your session, and analyze usage patterns for platform improvement purposes. Cookies are small text files stored on your device by your browser.

9.1 Types of Cookies Used

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in, security tokens that prevent cross-site request forgery, and load balancing cookies. These cannot be disabled without breaking Platform functionality.
• Performance / Analytics Cookies: Collect aggregated, anonymized data about how players navigate and use the Platform — which pages are visited most, where errors occur, and how long sessions last. This data is used solely to improve pub204's platform. These cookies require your consent.
• Preference Cookies: Store your language, display, and notification preferences to personalize your pub204 experience across sessions.
• Anti-Fraud Cookies: Collect device fingerprint data used to detect suspicious login patterns, multiple account registrations, and other prohibited conduct. These are classified as strictly necessary for security purposes.

9.2 Managing Cookies

You may manage non-essential cookie preferences through your browser settings or through pub204's cookie preference panel accessible from the Platform footer. Disabling strictly necessary cookies will impair or prevent use of the Platform. pub204 does not use third-party advertising or behavioral tracking cookies.

If pub204 becomes aware that personal data has been collected from an individual under the age of 21, the affected account will be immediately suspended, all personal data associated with the account will be deleted or returned to the extent technically feasible, and any deposited funds will be returned to the original payment source.

Parents and guardians who believe a minor may have accessed pub204 are encouraged to contact pub204 support immediately. pub204 will prioritize investigation and resolution of any reported underage account situation.

To exercise any of the data privacy rights described in the summary cards above — access, rectification, erasure, objection, or portability — please submit a written request to pub204's Data Protection Officer through the support channel listed in Section 16. Your request must include:

1. Your full name and registered pub204 email address, so we can verify your identity before processing the request.
2. A clear description of the right you wish to exercise and the specific data it concerns.
3. Where applicable, a copy of your Philippine government ID to confirm your identity (consistent with our KYC standards).

pub204 will acknowledge your request within five (5) business days and will provide a substantive response or data package within thirty (30) business days. Where a request is complex or involves a large volume of data, pub204 may extend this period by a further 30 days with written notice to you.

11.1 Limitations on Rights

Certain privacy rights may be limited where exercising them would conflict with pub204's legal obligations. For example, pub204 cannot delete KYC and transaction data that it is required to retain under PAGCOR and AMLA regulations, even following account closure. In such cases, pub204 will explain the limitation clearly and advise on any partial relief available.

11.2 Withdrawal of Marketing Consent

You may withdraw consent to receive marketing communications from pub204 at any time by updating your communication preferences in your account settings. Withdrawal of marketing consent will not affect your ability to use the Platform or the lawfulness of any processing carried out before withdrawal.

In the event that pub204 identifies a personal data breach — meaning a security incident resulting in unauthorized access to, disclosure, alteration, or destruction of personal data — pub204 will follow the protocol described below in accordance with NPC Circular 16-03 and related issuances.

• Containment: pub204 will immediately take steps to contain the breach and prevent further unauthorized access. This may involve temporary suspension of affected systems or account features.
• Assessment: pub204 will assess the nature, scope, and probable consequences of the breach within 72 hours of discovery.
• NPC Notification: If the breach involves sensitive personal information and is likely to give rise to a real risk of serious harm, pub204 will notify the National Privacy Commission within 72 hours of discovery, as required by NPC Circular 16-03.
• Player Notification: Where a breach is likely to adversely affect the rights and freedoms of individual players, pub204 will notify affected players directly through their registered email address without undue delay. The notification will describe the nature of the breach, the data involved, the likely consequences, and the steps being taken.

pub204 operates primarily within the Philippines, and the majority of personal data processing occurs on servers located within Philippine territory or in jurisdictions that maintain data protection standards recognized by the National Privacy Commission.

Where personal data is transferred to a service provider located outside the Philippines — for example, where a game studio's servers are hosted in another jurisdiction — pub204 ensures such transfers are governed by data processing agreements that impose data protection obligations equivalent to those required under Philippine law. pub204 will not transfer personal data to a jurisdiction without adequate data protection safeguards.

The pub204 Platform integrates with third-party game providers, payment processors, and identity verification services to deliver its core functionality. These third-party services process personal data under their own privacy policies and are subject to contractual data protection obligations established by pub204.

pub204 does not control and is not responsible for the privacy practices of third-party game studios or their underlying software platforms beyond the contractual protections in place. Players are encouraged to review the privacy documentation of individual game providers where this information is made available.

pub204 does not display third-party advertising on its Platform and does not use advertising networks that would expose player data to ad-tech companies. No data is shared with social media platforms for retargeting or behavioral advertising purposes.

pub204 may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal requirements, or Platform functionality. Where changes are material — meaning they significantly affect how we process your personal data or the rights available to you — pub204 will provide at least fourteen (14) days' advance notice by email to your registered address and by prominent notice on the Platform.

For minor or non-substantive changes — such as typographical corrections, clarifications that do not alter the substance of any provision, or updates to contact information — pub204 may update this Policy without advance notice.

The "Last Revised" date at the top of this document will be updated upon any amendment. Continued use of pub204 following the effective date of any revised Privacy Policy constitutes your acknowledgment of the updated terms. Where changes require fresh consent under the Data Privacy Act, pub204 will obtain such consent explicitly before proceeding with the affected processing.

For all data privacy inquiries, requests to exercise your rights, or concerns about pub204's data handling practices, please contact the pub204 Data Protection Officer through the following channels:

pub204 aims to respond to all data privacy inquiries within five (5) business days and to provide full resolution or data packages within thirty (30) business days. For urgent security concerns related to your account, the live chat channel in your pub204 account dashboard provides the fastest response.