204pub Privacy Policy – Your Personal Data, Explained Clearly

This Policy applies to all personal information that 204pub collects and processes in connection with your use of the Platform, including information provided during account registration, identity verification, payment processing, gameplay activity, customer support interactions, and marketing communications.

This Policy forms part of the 204pub Terms and Conditions and should be read alongside them. By creating a 204pub account or using the Platform in any capacity, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal information as described herein.

This Policy does not apply to third-party websites, applications, or services that may be linked to or from the Platform. 204pub is not responsible for the privacy practices of any third party. We encourage you to review the privacy policies of any third-party services you access.

For the purposes of the Data Privacy Act of 2012, 204pub is the personal information controller in respect of personal data processed through the Platform. 204pub operates under PAGCOR regulatory oversight for the Philippine online gaming market.

204pub has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and with RA 10173 and its Implementing Rules and Regulations. The DPO may be contacted via the details provided in Section 14 of this Policy.

204pub collects the following categories of personal information in the course of operating the Platform and providing gaming services to Filipino players:

204pub does not intentionally collect special categories of personal information as defined under RA 10173 (such as racial or ethnic origin, political opinions, religious beliefs, or health data) except where such information is voluntarily disclosed in the context of responsible gaming self-exclusion requests or support interactions, in which case it is processed solely for player welfare purposes.

204pub collects personal information through the following methods:

• Direct provision by you: Information you submit when creating an account, completing KYC verification, making a deposit or withdrawal request, contacting customer support, or responding to a survey or promotion.
• Automated technical collection: Information collected automatically through cookies, web beacons, server logs, and similar technologies when you access or use the Platform. This includes IP addresses, session data, device identifiers, and gameplay activity records.
• Payment processors: Transaction confirmation data received from GCash, PayMaya, and our partner Philippine banking payment processors when deposits and withdrawals are processed. 204pub does not store full bank account numbers or GCash PINs.
• Identity verification services: Data returned by third-party KYC verification providers engaged by 204pub to validate the authenticity of identity documents submitted by Players. These providers operate under data processing agreements that bind them to the same data protection standards required by RA 10173.
• Fraud and AML monitoring systems: Transactional and behavioral data generated by our automated anti-money laundering and fraud detection systems, as required under RA 9160 (Anti-Money Laundering Act) and PAGCOR compliance obligations.

204pub processes your personal data for the following purposes and on the following legal bases under RA 10173:

• Account creation and management — To create, maintain, and administer your 204pub account, verify your identity at registration, and manage your account settings and preferences. Legal basis: Performance of a contract (your Account Agreement with 204pub).
• Processing deposits and withdrawals — To execute financial transactions on your account through GCash, PayMaya, and Philippine banking channels, and to maintain accurate financial records of all transactions. Legal basis: Performance of a contract; compliance with BSP payment regulations.
• KYC identity verification — To verify your identity and age (21+) in compliance with PAGCOR licensing requirements and the Anti-Money Laundering Act of 2001, as amended. Legal basis: Legal obligation under RA 9160 and PAGCOR regulatory requirements.
• Fraud prevention and AML compliance — To detect, investigate, and prevent fraud, money laundering, and other financial crimes, and to report suspicious transactions to the Anti-Money Laundering Council (AMLC) as required by law. Legal basis: Legal obligation; legitimate interest in protecting the integrity of the Platform.
• Responsible gaming — To monitor gaming patterns, enforce deposit limits and self-exclusion arrangements, send responsible gaming communications, and refer at-risk Players to appropriate support resources. Legal basis: Legal obligation under PAGCOR responsible gaming requirements; legitimate interest in player welfare.
• Customer support — To respond to your queries, complaints, and support requests, and to maintain records of communications for quality and training purposes. Legal basis: Performance of a contract; legitimate interest in service quality.
• Platform improvement and analytics — To analyze gameplay data, navigation patterns, and technical performance to improve the Platform's features, content offerings, and user experience for Filipino players. Legal basis: Legitimate interest; data is anonymized or pseudonymized where feasible.
• Marketing communications — To send you promotional offers, bonuses, and relevant gaming content via email, SMS, or push notification, where you have provided your consent or where we have a legitimate interest in communicating with existing Players. Legal basis: Consent (which may be withdrawn at any time) or legitimate interest for existing customers.
• Legal and regulatory compliance — To comply with applicable Philippine laws, PAGCOR conditions of license, court orders, or regulatory directions from the NPC, PAGCOR, BSP, or AMLC. Legal basis: Legal obligation.

204pub does not sell your personal information. We share personal data only in the following limited circumstances:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other approved Philippine payment partners receive the minimum personal data required to execute your deposit and withdrawal transactions. These providers operate under their own applicable BSP-regulated privacy frameworks.
• KYC verification providers: Third-party identity verification services receive copies of identity documents you submit for KYC processing. These providers are engaged under data processing agreements requiring compliance with RA 10173 standards.
• Game software providers: Certified game providers whose products are available on 204pub may receive anonymized or pseudonymized gameplay and session data for technical operation and RNG auditing purposes. No directly identifiable personal data is shared with game providers without necessity.
• Regulatory authorities: PAGCOR, the AMLC, the NPC, the BSP, and other Philippine government agencies may receive personal data where disclosure is required by law, court order, regulatory direction, or compliance obligation. 204pub will comply with all lawful requests from competent Philippine authorities.
• Professional advisers: Legal counsel, auditors, accountants, and compliance consultants engaged by 204pub may access personal data in the course of professional services, subject to professional confidentiality obligations.
• Corporate transactions: In the event of a merger, acquisition, or sale of all or substantially all of 204pub's assets, personal data held may be transferred to the successor entity, subject to the same privacy protections described in this Policy.

204pub uses cookies and similar web tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Essential cookies: Required for basic Platform functionality, including maintaining your login session, enforcing security controls, and processing transactions. These cannot be disabled without preventing use of the Platform.
• Analytics cookies: Used to collect aggregated, anonymized data about how Players navigate and interact with the Platform, to identify technical issues and optimize the user experience. Data collected through analytics cookies does not identify you individually.
• Preference cookies: Used to remember your settings and preferences, such as language and game display options, across sessions.
• Marketing cookies: Used to track whether you have clicked on a promotional campaign link that directed you to 204pub, for attribution and bonus eligibility purposes. 204pub does not use third-party advertising or retargeting cookies.

You may control cookie settings through your browser's privacy controls. Disabling essential cookies will impair your ability to use the Platform. 204pub does not currently respond to browser Do Not Track signals, though we will review this policy as Philippine NPC guidance on this issue develops.

204pub retains personal data for the minimum period necessary to fulfil the purposes for which it was collected, subject to the following retention periods:

• Account and KYC data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and AML record-keeping obligations under RA 9160.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by BSP and AMLC regulations applicable to licensed gaming operators.
• Gaming activity data: Retained for three (3) years from account closure or from the date of last activity, whichever is later, for dispute resolution and regulatory audit purposes.
• Customer support communications: Retained for two (2) years from the date of last interaction, for quality assurance and dispute resolution purposes.
• Marketing data: Retained until you withdraw your consent to receive marketing communications, following which it is promptly suppressed from active marketing lists. Where legitimate interest is the processing basis, retained as long as the legitimate interest subsists.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC-recognized secure disposal standards. Data subject to an ongoing legal hold, regulatory investigation, or dispute will be retained until that matter is concluded.

204pub implements the following technical and organizational security measures to protect personal data against unauthorized access, disclosure, alteration, and destruction:

• All data transmitted between your device and the 204pub Platform is encrypted using TLS 1.2 or higher protocols.
• Account passwords are stored using industry-standard one-way cryptographic hashing algorithms. 204pub does not store plaintext passwords.
• Access to personal data systems is restricted on a role-based, need-to-know basis. Access logs are maintained and reviewed regularly.
• All 204pub staff with access to personal data undergo data privacy training and are bound by confidentiality obligations.
• Regular security vulnerability assessments and penetration testing are conducted on Platform infrastructure as part of 204pub's PAGCOR compliance program.
• Physical and logical access controls are applied to servers and data storage systems hosting personal data.

Under Republic Act 10173, you have the following rights with respect to your personal data processed by 204pub. These rights may be exercised by contacting our Data Protection Officer as described in Section 14:

To exercise any of the above rights, please contact the 204pub Data Protection Officer using the contact details in Section 14. We will respond to verified data subject requests within fifteen (15) business days of receipt, as required under RA 10173. We may need to verify your identity before processing a request to protect against unauthorized access to your data.

The 204pub Platform is strictly intended for adults aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. 204pub does not knowingly collect personal information from individuals under the age of 21.

During the account registration and KYC verification processes, 204pub verifies the age of all Players. Any account found to have been created by an individual below 21 years of age will be immediately and permanently closed, and any balance held will be forfeited in accordance with PAGCOR regulations on underage gaming.

As a Philippine-focused platform, 204pub processes the majority of player personal data within the Philippines. However, certain service providers engaged by 204pub — including game software providers, technical infrastructure providers, and cloud hosting services — may be located in other countries and may therefore process personal data outside the Philippines in the course of delivering their services.

Where personal data is transferred outside the Philippines, 204pub ensures that such transfers are carried out in compliance with RA 10173, including by:

• Entering into data transfer agreements with receiving parties that impose data protection standards equivalent to those required under Philippine law.
• Ensuring that cross-border transfers occur only to countries or organizations that provide adequate data protection, as recognized under applicable NPC guidelines or by virtue of contractual safeguards.
• Limiting cross-border transfers to the minimum personal data necessary for the service provider to perform its contracted function.

Details of the cross-border transfer safeguards applicable to specific processing activities are available from the 204pub Data Protection Officer upon request.

204pub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, new regulatory requirements, or amendments to Philippine data privacy law. The updated date at the top of this Policy will be revised accordingly upon each amendment.

Material changes to this Policy — meaning changes that significantly affect how we use your personal data or your rights as a data subject — will be communicated to you via the email address registered to your 204pub account at least 14 days before the amended Policy takes effect. Continued use of the Platform after the effective date of any changes constitutes acceptance of the revised Policy.

We encourage you to review this Policy periodically. All previous versions of this Policy are archived and available from the 204pub Data Protection Officer upon request.

For all inquiries, data subject rights requests, privacy complaints, or matters relating to this Privacy Policy, please contact the 204pub Data Protection Officer using the following details:

If you are not satisfied with 204pub's response to a privacy-related complaint, you have the right to escalate your concern to the National Privacy Commission (NPC) of the Philippines, which is the government body responsible for administering and enforcing RA 10173.