201 pub Casino – Privacy Policy

1. Overview & Scope

This Policy applies to all personal information collected by 201 pub through the 201pub.org website, mobile-optimized platform, live chat support, email correspondence, and any other channel through which you interact with 201 pub. It applies to all registered players, prospective players, and visitors to the Platform.

By accessing the 201 pub Platform or creating a player account, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform.

201 pub acts as the Personal Information Controller in respect of the personal data it collects directly from you. Where 201 pub engages third-party service providers to process data on its behalf, those providers act as Personal Information Processors and are bound by data processing agreements consistent with the Data Privacy Act of 2012.

2. Personal Data We Collect

201 pub collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include:

2.1 Identity & Contact Information

• Full legal name, date of birth, and nationality;
• Government-issued identification number (e.g., Philippine National ID, passport, driver's licence);
• Residential address (including city — Manila, Cebu, Davao, Quezon City, Makati, or elsewhere in the Philippines);
• Email address and mobile phone number.

2.2 Account & Financial Information

• Username, encrypted password, and account preferences;
• GCash number, PayMaya account details, or Philippine bank account information used for deposits and withdrawals;
• Transaction history, deposit amounts, withdrawal requests, and account balance records;
• Bonus and promotional activity records.

2.3 Gaming Activity Data

• Game session logs, bet history, win/loss records, and game preferences;
• Responsible gaming settings, including deposit limits and self-exclusion status;
• Session duration and frequency of play data.

2.4 Technical & Device Data

• IP address, device type, operating system, and browser type;
• Geolocation data (country/region level) for regulatory compliance;
• Cookie identifiers and session tokens (see Section 9);
• Platform access logs and error reports.

2.5 Communications Data

• Records of live chat conversations with 201 pub customer support;
• Email correspondence and support ticket history;
• Survey responses and feedback submitted voluntarily.

3. How We Collect Your Data

201 pub collects personal data through the following means:

3.1 Directly From You

The majority of personal data we hold is provided directly by you when you: register a 201 pub account; complete KYC identity verification; make a deposit or request a withdrawal; contact our customer support team; or participate in promotions and surveys.

3.2 Automatically Through the Platform

When you access the 201 pub Platform, certain technical data is collected automatically through cookies, web beacons, and server logs. This includes your IP address, device identifiers, browser type, and session activity. This data is collected to ensure the Platform functions correctly, to detect fraud, and to improve the user experience.

3.3 From Third Parties

In certain circumstances, 201 pub may receive personal data about you from third parties, including:

• Payment processors (e.g., GCash, PayMaya, Philippine banks) — to verify and process financial transactions;
• Identity verification providers — to assist with KYC and anti-money laundering compliance;
• Fraud prevention services — to identify and prevent fraudulent account activity;
• Regulatory authorities — including PAGCOR, where required by law.

4. Purpose of Processing

201 pub processes your personal data for the following specific, legitimate purposes:

• Account Management: To create, maintain, and administer your 201 pub player account, including authentication and security;
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver customer support;
• Identity Verification (KYC): To verify your identity and age (21+) in compliance with PAGCOR regulations and Philippine anti-money laundering laws;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, money laundering, and other illegal activity;
• Regulatory Compliance: To meet our obligations under Philippine law, including reporting requirements to PAGCOR and the Anti-Money Laundering Council (AMLC);
• Responsible Gaming: To monitor gaming activity and enforce responsible gaming tools such as deposit limits and self-exclusion;
• Marketing & Promotions: To send you relevant promotional offers and updates about 201 pub, where you have provided consent or where permitted by law;
• Platform Improvement: To analyse usage patterns and improve the functionality, performance, and content of the 201 pub Platform;
• Legal Claims: To establish, exercise, or defend legal claims arising from your use of the Platform.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173), 201 pub processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and 201 pub — specifically, to operate your player account and deliver gaming services;
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act itself;
• Legitimate Interests: Processing is necessary for the legitimate interests of 201 pub, including fraud prevention, platform security, and business analytics, provided those interests are not overridden by your rights and freedoms;
• Consent: For certain processing activities — particularly direct marketing communications — we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

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

6.1 Service Providers

We engage trusted third-party service providers to assist in operating the 201 pub Platform, including payment processors (GCash, PayMaya, Philippine banks), KYC and identity verification providers, IT infrastructure and hosting providers, and customer support platforms. These providers are contractually bound to process your data only on our instructions and in accordance with the Data Privacy Act of 2012.

6.2 Regulatory & Law Enforcement Authorities

201 pub may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine government authorities where required by law, court order, or regulatory directive.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of the 201 pub business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Privacy Policy that result from it.

6.4 With Your Consent

We may share your personal data with other third parties where you have given your explicit prior consent to such sharing.

7. Data Retention

201 pub retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and KYC records: Retained for a minimum of five (5) years from the date of account closure, in compliance with PAGCOR and AMLC requirements;
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction;
• Gaming activity logs: Retained for a minimum of two (2) years from the date of each session;
• Customer support communications: Retained for two (2) years from the date of the last interaction;
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year thereafter for compliance documentation purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with 201 pub's data disposal procedures.

8. Data Security

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

• SSL/TLS Encryption: All data transmitted between your device and the 201 pub Platform is encrypted using industry-standard SSL/TLS protocols;
• Password Hashing: Account passwords are stored using strong one-way cryptographic hashing algorithms — we never store your password in plain text;
• Access Controls: Access to personal data within 201 pub is restricted on a strict need-to-know basis, with role-based access controls and audit logging;
• Two-Factor Authentication: Players are encouraged to enable OTP-based two-factor authentication for additional account security;
• Regular Security Audits: The 201 pub Platform undergoes regular security assessments and vulnerability testing.

9. Cookies & Tracking Technologies

The 201 pub Platform uses cookies and similar tracking technologies to enhance your experience, maintain session state, and gather analytics data. A cookie is a small text file placed on your device by the Platform when you visit.

9.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without affecting Platform functionality;
• Functional Cookies: Remember your preferences such as language settings, game preferences, and responsible gaming configurations;
• Analytics Cookies: Collect anonymised data about how players use the 201 pub Platform, helping us identify areas for improvement;
• Security Cookies: Used to detect and prevent fraudulent activity, including bot detection and session integrity verification.

9.2 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 201 pub Platform, including your ability to log in and access games. For detailed guidance on managing cookies in your browser, refer to your browser's help documentation.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by 201 pub:

• Right to Be Informed: The right to be informed about how your personal data is collected and processed — which this Privacy Policy fulfils;
• Right of Access: The right to request a copy of the personal data 201 pub holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data, subject to our legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another controller where technically feasible;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

11. Minors & Age Restriction

If 201 pub becomes aware that personal data has been collected from a person under 21 years of age without verifiable parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the 201 pub Platform, please contact our support team immediately.

Parents and guardians are encouraged to use parental control software and to monitor their children's internet activity to prevent access to gambling platforms. 201 pub supports responsible gaming and the protection of minors as a core operational principle.

12. Changes to This Privacy Policy

201 pub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, or PAGCOR regulatory requirements. When material changes are made, we will notify registered players via email or a prominent notice on the Platform, and the "Last Updated" date at the top of this page will be revised accordingly.

Your continued use of the 201 pub Platform after the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your personal data.

13. Contact & Data Privacy Officer

201 pub has designated a Data Privacy Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Policy, please contact us through the following channels:

Please note that the email address above is displayed as plain text for informational purposes only and is not a clickable link. For the fastest response to privacy-related queries, we recommend using the live chat feature available after logging in to your 201 pub account.

If you are not satisfied with our response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines through its official channels.