Privacy Policy — 209 pub

1. Introduction

1.1 This Privacy Policy applies to all personal data collected by 209 pub in connection with the operation of the 209 pub online gaming platform, accessible at https://209pub.org and any related subdomains or mobile-optimised versions of the site.

1.2 209 pub is committed to handling your personal data responsibly and in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

1.3 This Privacy Policy should be read alongside our Terms & Conditions, which govern your use of the 209 pub platform. Terms not defined in this Privacy Policy carry the meaning given to them in the Terms & Conditions.

1.4 If you have any questions about this Privacy Policy or how 209 pub handles your personal data, please contact our Data Protection Officer using the details provided in Section 13 of this document.

2. Personal Data We Collect

2.1 209 pub collects the following categories of personal data from registered players and platform visitors:

2.2 209 pub does not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect biometric data, religious beliefs, political opinions, or health information unless specifically required by law.

3. How We Collect Your Data

3.1 209 pub collects personal data through the following means:

• Direct interactions: When you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in promotions on the 209 pub platform;
• Automated technologies: When you browse the 209 pub website, we automatically collect technical and usage data through cookies, server logs, and similar tracking technologies;
• Third-party sources: We may receive data from identity verification providers, payment processors (such as GCash and PayMaya), and fraud prevention services to supplement the information you provide directly;
• Regulatory sources: In certain circumstances, we may receive data from PAGCOR or other regulatory bodies as part of our compliance obligations.

4. How We Use Your Personal Data

4.1 209 pub uses your personal data for the following purposes:

• To create and manage your 209 pub player account;
• To verify your identity and age (21+ requirement) in compliance with Philippine gaming regulations;
• To process deposits, withdrawals, and other financial transactions in Philippine Peso (PHP);
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities;
• To provide customer support and resolve disputes;
• To send you account-related notifications, including security alerts and transaction confirmations;
• To send you marketing communications about 209 pub promotions and new games, where you have given your consent;
• To monitor your gaming activity for responsible gaming purposes and to apply any limits or restrictions you have requested;
• To improve the 209 pub platform, analyse usage patterns, and develop new features;
• To comply with our legal obligations under Philippine law, including the Data Privacy Act of 2012, Anti-Money Laundering Act, and PAGCOR regulations.

4.2 209 pub will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by applicable law.

5. Legal Basis for Processing

5.1 209 pub processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfil our obligations under the Terms & Conditions, including account management and payment processing;
• Legal obligation: Processing required to comply with Philippine law, including KYC/AML requirements and PAGCOR regulatory obligations;
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time.

6. Data Sharing & Disclosure

6.1 209 pub does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients only to the extent necessary:

• Payment processors: GCash, PayMaya / Maya, and Philippine banking partners, for the purpose of processing deposits and withdrawals;
• Identity verification providers: Third-party KYC service providers who assist in verifying your identity and age;
• IT and platform service providers: Cloud hosting, cybersecurity, and analytics providers who process data on our behalf under strict data processing agreements;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government bodies, where required by law;
• Law enforcement: Philippine law enforcement agencies, where we are legally required to disclose information in connection with a criminal investigation or court order.

6.2 All third-party service providers who process personal data on behalf of 209 pub are contractually required to maintain appropriate security measures and to process data only in accordance with our instructions and applicable law.

7. Cookies & Tracking Technologies

7.1 The 209 pub website uses cookies and similar tracking technologies to enhance your browsing experience, maintain your session, and analyse platform performance. The following types of cookies are used:

• Strictly necessary cookies: Required for the platform to function, including session management and security features. These cannot be disabled.
• Functional cookies: Remember your preferences, such as language settings and game history, to personalise your experience on 209 pub.
• Analytics cookies: Collect anonymised data about how players use the platform, helping us identify areas for improvement. No personally identifiable information is included in analytics reports.
• Marketing cookies: Used to deliver relevant promotional content about 209 pub. These are only set with your consent.

7.2 You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the 209 pub platform.

8. Data Retention

8.1 209 pub retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, as required by Philippine AML regulations;
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction;
• Support and communication records are retained for three (3) years;
• Marketing preference data is retained until you withdraw consent or request deletion.

8.2 When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, 209 pub will securely delete or anonymise the data.

9. Data Security

9.1 209 pub implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 209 pub platform;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits and penetration testing of the 209 pub platform;
• Multi-factor authentication for administrative access to systems containing personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 209 pub will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

10. Your Privacy Rights

10.1 Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 209 pub:

• Right to be informed: You have the right to know what personal data 209 pub collects about you and how it is used;
• Right of access: You may request a copy of the personal data 209 pub holds about you;
• Right to rectification: You may request correction of inaccurate or incomplete personal data;
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations;
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time;
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

10.2 To exercise any of the above rights, please contact the 209 pub Data Protection Officer using the contact details in Section 13. We will respond to all verified requests within thirty (30) days, as required by the Data Privacy Act of 2012.

11. Children's Privacy

11.1 The 209 pub platform is strictly intended for individuals aged 21 years and above. 209 pub does not knowingly collect personal data from anyone under the age of 21.

11.2 If 209 pub becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the 209 pub platform, please contact our support team immediately.

12. Changes to This Privacy Policy

12.1 209 pub reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. The date of the most recent revision is displayed at the top of this page.

12.2 Where changes are material, 209 pub will notify registered players via email or an in-platform notification prior to the changes taking effect. Your continued use of the 209 pub platform following notification of changes constitutes your acceptance of the revised Privacy Policy.

12.3 We encourage you to review this Privacy Policy periodically to stay informed about how 209 pub protects your personal data.

13. Contact & Data Protection Officer

13.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 209 pub, please contact our Data Protection Officer: