209 pub Privacy Policy

§1 Introduction

1.1 209 pub ("the Platform," "we," "us," or "our") operates the online gaming platform accessible at 209pub.vip, providing casino games, sports betting, e-sabong, bingo, keno, and related entertainment services to registered players in the Philippines.

1.2 This Privacy Policy ("Policy") governs the collection, processing, storage, disclosure, and protection of personal data submitted to or collected by 209 pub in the course of providing these services. It applies to all registered Players, prospective registrants, and visitors to the Platform.

1.3 209 pub is committed to processing personal data lawfully, fairly, and transparently in accordance with the Republic Act No. 10173 (Data Privacy Act of 2012), its Implementing Rules and Regulations, and the circulars and advisories issued by the National Privacy Commission (NPC) of the Philippines.

1.4 This Policy should be read in conjunction with the Terms and Conditions and the Responsible Gaming Policy of 209 pub, which together form the complete regulatory framework governing use of the Platform.

§2 Data Controller

2.1 For the purposes of applicable data protection law, the Data Controller responsible for your personal data is 209 pub, operating the online gaming platform at 209pub.vip.

2.2 209 pub has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and applicable data protection legislation. The DPO may be contacted at:

2.3 Players may direct all data-related requests, queries, and complaints to the DPO using the contact information above. 209 pub commits to acknowledging receipt of all data-related requests within five (5) business days.

§3 Personal Data We Collect

3.1 209 pub collects personal data in accordance with the principle of data minimization — collecting only information that is adequate, relevant, and limited to what is necessary for the purposes described in this Policy. The categories of personal data we collect are as follows:

§4 How We Collect Your Data

4.1 209 pub collects personal data through the following channels:

Direct Collection

• Account registration form — name, contact details, date of birth;
• KYC verification process — identity documents, selfie verification;
• Deposit and withdrawal transactions — payment account references;
• Customer support interactions — emails, live chat transcripts;
• Responsible gaming tool submissions — limit settings, self-exclusion requests;
• Feedback and survey responses.

Automated Collection

• Session logs — timestamps, login/logout records, game activity;
• Technical data — IP addresses, device fingerprints, browser metadata;
• Cookie and similar tracking technologies (see Section 10);
• Geolocation data — general location derived from IP address for compliance purposes.

Third-Party Sources

• Identity verification service providers — to validate KYC documents;
• Payment processors — transaction confirmation and status updates from GCash, PayMaya, and banking networks;
• Fraud detection services — risk scoring data to protect against fraudulent activity;
• Regulatory databases — sanctions screening and politically exposed persons (PEP) lists as required by anti-money laundering obligations.

§5 Legal Basis for Processing

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

• Contractual Necessity: Processing required to register your Account, provide gaming services, process deposits and withdrawals, and fulfill our obligations under the Terms and Conditions;
• Legal Obligation: Processing necessary to comply with anti-money laundering (AML) laws, Know Your Customer (KYC) requirements, PAGCOR regulatory obligations, tax reporting requirements, and court orders;
• Legitimate Interests: Processing for fraud detection and prevention, platform security, responsible gaming monitoring, and improving our services, where such interests are not overridden by your fundamental rights;
• Consent: For optional marketing communications and non-essential analytics, where you have provided clear, informed, and freely given consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

5.2 Where processing is based on consent, you have the right to withdraw that consent at any time by contacting our Data Protection Officer. Withdrawal of consent will not affect your ability to use the Platform for its core gaming services.

§6 How We Use Your Personal Data

6.1 209 pub uses the personal data we collect for the following purposes:

• Account Management: Creating, maintaining, and administering your 209 pub Account, including verifying your identity and managing your authentication credentials;
• Service Delivery: Providing access to all games, sports betting, and other Platform features; processing deposits and withdrawals; crediting bonuses and tracking wagering progress;
• KYC and Age Verification: Verifying that you meet the minimum age requirement of 21 years and confirming your identity before processing withdrawals;
• Regulatory Compliance: Meeting our obligations under AML/CFT legislation, PAGCOR regulatory requirements, and any other applicable laws;
• Fraud Prevention and Security: Detecting and preventing fraudulent transactions, unauthorized Account access, bonus abuse, collusion, and money laundering;
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behavior; administering deposit limits, loss limits, session limits, and self-exclusion requests;
• Customer Support: Responding to support requests, resolving disputes, and maintaining records of interactions;
• Marketing Communications: Sending promotional offers, bonus announcements, and Platform updates — only where you have consented or where permissible under applicable law;
• Platform Improvement: Analyzing usage patterns and technical data to optimize performance, fix issues, and develop new features;
• Legal Proceedings: Establishing, exercising, or defending legal claims.

§7 Data Sharing & Disclosure

7.1 209 pub does not sell, rent, or trade your personal information to third parties for their own marketing purposes. Personal data is shared only in the following circumstances and only to the extent necessary:

• Service Providers: Third-party vendors who assist in operating the Platform, including KYC verification providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), cloud hosting providers, cybersecurity services, and customer support tools. All service providers are bound by data processing agreements requiring them to protect your data and use it only for the specified purpose;
• Game Providers: Licensed game software providers may receive pseudonymized gameplay data necessary to operate their game engines on the Platform;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the Bureau of Internal Revenue (BIR), the National Privacy Commission (NPC), and other government bodies as required by law;
• Law Enforcement: Police, courts, or other authorities when required by a valid legal order, warrant, or subpoena;
• Fraud Prevention Networks: Industry fraud prevention organizations for the purpose of protecting all participants from fraudulent activity;
• Business Transfers: In the event of a merger, acquisition, or sale of all or substantially all assets of 209 pub, your data may be transferred to the successor entity. You will be notified of any such transfer and the applicable privacy terms.

7.2 Where personal data is transferred to service providers located outside the Philippines, 209 pub ensures that adequate safeguards are in place through contractual obligations consistent with NPC standards.

§8 Data Security

8.1 209 pub implements technical and organizational security measures appropriate to the risk level of the data we process. These measures include but are not limited to:

• SSL/TLS encryption for all data in transit between the Platform and user devices;
• AES-256 encryption for sensitive data stored at rest;
• One-way cryptographic hashing of passwords (bcrypt or equivalent) — no plain-text passwords are stored;
• Role-based access controls limiting data access to authorized personnel on a need-to-know basis;
• Multi-factor authentication for internal systems accessing personal data;
• Regular security audits, vulnerability assessments, and penetration testing;
• Intrusion detection and monitoring systems operating 24/7;
• Secure data deletion procedures for data no longer required.

8.2 Notwithstanding these measures, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. 209 pub takes all reasonable precautions but cannot guarantee absolute security. Players are advised to use strong, unique passwords and to enable two-factor authentication for their 209 pub Accounts.

8.3 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 affected individuals and the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular No. 16-03 and its amendments.

§9 Data Retention

9.1 209 pub retains personal data for as long as is necessary to fulfill the purposes described in this Privacy Policy, to comply with legal obligations, to resolve disputes, and to enforce our agreements. The following retention periods apply as a general guide:

• Account and Identity Data: Retained for the duration of the active Account relationship, plus a minimum of five (5) years following Account closure, to satisfy AML record-keeping obligations under applicable Philippine law;
• Financial Transaction Records: Retained for a minimum of five (5) years in accordance with AML/CFT requirements and tax record obligations;
• KYC Documents: Retained for five (5) years following completion of the business relationship;
• Gaming Activity Logs: Retained for five (5) years for regulatory compliance and dispute resolution purposes;
• Customer Support Records: Retained for three (3) years following resolution of the relevant issue;
• Marketing Consent Records: Retained for the duration of the marketing relationship plus one (1) year following opt-out;
• Technical and Log Data: Retained for twelve (12) months for security and fraud prevention purposes, unless required longer for an ongoing investigation.

9.2 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in a manner that prevents reconstruction of the original personal information. Anonymized data may be retained indefinitely for statistical and analytical purposes.

§10 Cookies & Tracking Technologies

10.1 The 209 pub Platform uses cookies and similar tracking technologies to ensure the Platform functions correctly, to analyze usage, and to provide a personalized experience. The categories of cookies used are as follows:

• Strictly Necessary Cookies: Required for the Platform to operate. These include session management cookies that maintain your login state. These cannot be disabled without impairing Platform functionality;
• Functional Cookies: Used to remember your preferences, such as language settings and responsible gaming limit selections;
• Analytics Cookies: Used to collect aggregated information about how Players interact with the Platform, enabling 209 pub to improve performance and user experience. Data collected through analytics cookies is processed in aggregate and not linked to individual identities;
• Security Cookies: Used to detect and prevent fraudulent sessions and unauthorized access attempts.

10.2 You can control cookie settings through your browser preferences. Note that disabling certain cookies may affect the functionality of the 209 pub Platform, including the ability to maintain your login session.

10.3 209 pub does not use third-party advertising or retargeting cookies on the Platform. No cookies are placed for the purpose of tracking your activity across other websites.

§11 Your Rights Under RA 10173

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

11.2 To exercise any of the above rights, please submit a written request to our Data Protection Officer at [email protected]. Please include your full name, Account username, and a clear description of the right you wish to exercise. We may request identity verification before processing your request.

11.3 209 pub will respond to all verified data rights requests within thirty (30) calendar days of receipt. Where a request is particularly complex or we receive a large volume of requests, we may extend this period by an additional thirty (30) days, with notice provided within the initial period.

§12 Children & Minors

12.1 If you are a parent or guardian and you believe that your child (under 21) has provided personal information to 209 pub, please contact our Data Protection Officer immediately at [email protected]. We will promptly investigate and, upon confirmation, delete the data and terminate the Account.

12.2 Age verification through KYC is required before any withdrawal is processed, providing an additional layer of protection against underage participation.

§13 Third-Party Links

13.1 The 209 pub Platform may contain references to third-party game providers and payment processors as part of its normal operation. These third parties maintain their own privacy policies, and 209 pub is not responsible for the content, privacy practices, or data handling of any third-party systems or services.

13.2 Players are encouraged to review the privacy policies of any third-party service providers they interact with in connection with their use of the 209 pub Platform. Our inclusion of references to third-party services does not constitute an endorsement of their privacy practices.

§14 Changes to This Privacy Policy

14.1 209 pub reserves the right to update or amend this Privacy Policy at any time. Material changes — those that affect your rights or how your personal data is processed in a significant way — will be communicated to registered Players via email notification and/or a prominent notice on the Platform prior to the effective date of the change.

14.2 The effective date of the current version of this Policy is displayed at the top of this document. Minor updates — such as typographical corrections or clarifications that do not alter substantive rights — may be made without advance notice.

14.3 Continued use of the 209 pub Platform after any amendment to this Privacy Policy constitutes acceptance of the revised Policy. If you do not agree to a material amendment, please close your Account and discontinue use of the Platform before the amendment's effective date.

14.4 Previous versions of this Privacy Policy are available on request from the Data Protection Officer.

§15 Contact & Data Protection Officer

15.1 For any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data by 209 pub, please contact our Data Protection Officer:

15.2 If you are not satisfied with 209 pub's response to a data protection concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for overseeing compliance with RA 10173.

This Privacy Policy is effective as of January 1, 2026. Version 2.0. All previous versions are superseded.