206pub Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") describes how 206pub ("206pub," "we," "us," or "our"), the operator of the online gaming platform accessible at 206pub.club ("the Platform"), collects, uses, stores, discloses, and protects personal data about individuals who visit or register on the Platform ("Players" or "you").

This Policy applies to all personal data processed in connection with your use of 206pub's services, including account registration, identity verification, deposits, gameplay, withdrawals, bonus participation, and customer support interactions.

This Policy is published in compliance with the Philippine Data Privacy Act of 2012 (Republic Act 10173), its Implementing Rules and Regulations, and the regulations issued by the National Privacy Commission (NPC) of the Philippines. It should be read alongside the 206pub Terms & Conditions and Responsible Gaming Policy.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, 206pub is the personal information controller in respect of personal data collected through the Platform. 206pub is responsible for determining the purposes and means of processing your personal data.

206pub operates within the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR). As a PAGCOR-regulated gaming operator, 206pub is subject to data handling obligations imposed by PAGCOR in addition to those under the Data Privacy Act.

For all privacy-related inquiries, requests, and complaints, players may contact 206pub through the live chat support function available on the Platform at all times, or by written correspondence addressed to the 206pub Data Privacy Officer.

3. Personal Data We Collect

3.1 Registration Data

When you create a 206pub account, we collect the following information:

• Full legal name as it appears on your government-issued Philippine identification;
• Date of birth (to verify you are 21 years of age or older);
• Philippine mobile telephone number;
• Account username and password (stored in encrypted form — 206pub cannot retrieve your plaintext password);
• Self-declared residential address.

3.2 Identity Verification (KYC) Data

Before processing withdrawals, 206pub is required by PAGCOR's regulatory framework to verify your identity. KYC data collected includes:

• Scanned or photographed copy of a valid Philippine government-issued ID (e.g., PhilSys National ID, Passport, Driver's License, SSS ID, UMID, PRC ID, Voter's ID);
• A selfie photograph for facial verification against the submitted ID;
• Proof of payment method ownership (where required for withdrawal verification).

3.3 Transaction and Financial Data

206pub records all financial transactions associated with your account, including deposits, withdrawals, bonus credits, and wager history. Payment instrument details (such as your GCash registered number or bank account number) are stored in tokenized form — 206pub does not store your full payment credentials.

3.4 Usage and Technical Data

When you access and use the 206pub Platform, we automatically collect certain technical data, including:

• IP address and approximate geographic location;
• Device type, operating system, and browser type;
• Session timestamps and duration;
• Pages and game categories accessed;
• Game play logs (for dispute resolution and game integrity monitoring purposes).

3.5 Communication Data

Records of communications between you and the 206pub support team — including live chat transcripts and any written correspondence — are retained to enable follow-up, quality assurance, and the resolution of disputes.

3.6 Summary of Data Categories

4. Purpose & Legal Basis for Processing

206pub processes your personal data for the following purposes, each with a corresponding legal basis under the Philippine Data Privacy Act of 2012:

Where processing is based on your consent — such as for receiving promotional communications from 206pub — you have the right to withdraw that consent at any time by updating your communication preferences in account settings or by contacting support. Withdrawal of consent for promotional communications does not affect the lawfulness of processing carried out before withdrawal.

5. Data Sharing & Third-Party Disclosure

5.1 206pub Does Not Sell Your Data

206pub does not sell, rent, or trade your personal data to any third party for commercial purposes. Sharing of personal data is limited strictly to the categories and circumstances described in this section.

5.2 Payment Service Providers

To process deposits and withdrawals, 206pub shares necessary transaction data with licensed Philippine payment service providers, including GCash (Mynt / G-Xchange Inc.), PayMaya (Voyager Innovations), BPI, BDO, and Metrobank. These providers process your transaction data under their own privacy policies and applicable Bangko Sentral ng Pilipinas (BSP) data protection obligations.

5.3 Game Technology Providers

206pub partners with licensed game technology providers to deliver the game library. Technical session data (not full identity data) may be transmitted to game servers operated by these providers to facilitate gameplay. All game providers engaged by 206pub are contractually obligated to process player data only as directed by 206pub and to maintain appropriate security standards.

5.4 Regulatory and Law Enforcement Authorities

206pub is legally required to share certain player information with regulatory and law enforcement bodies, including:

• PAGCOR — as the primary gaming regulator, PAGCOR may request player account and transaction data as part of its oversight functions;
• Anti-Money Laundering Council (AMLC) — 206pub is a covered person under the Anti-Money Laundering Act (Republic Act 9160, as amended) and is required to file covered transaction reports and suspicious transaction reports with the AMLC;
• Courts and law enforcement agencies — where compelled by valid court order or lawful demand from a duly authorized Philippine law enforcement agency.

206pub will, where legally permissible, notify you of such requests before complying. In certain circumstances — particularly those involving ongoing investigations — prior notification may not be legally permissible.

5.5 Professional Advisers

206pub may share relevant data with legal counsel, auditors, and other professional advisers engaged by 206pub, subject to applicable professional confidentiality obligations.

6. Data Retention

206pub retains personal data only for as long as is necessary for the purposes for which it was collected, and to comply with applicable legal, regulatory, and contractual obligations.

Specific retention periods applicable to 206pub player data are as follows:

• Active account data: Retained for the duration of the account relationship plus five (5) years following account closure, in compliance with PAGCOR's record-keeping requirements;
• KYC and identity verification documents: Retained for a minimum of five (5) years following the end of the account relationship, as required under the Anti-Money Laundering Act;
• Transaction records: Retained for a minimum of five (5) years following the date of each transaction;
• Support communication records: Retained for three (3) years following the close of each support interaction;
• Technical and usage logs: Retained for twelve (12) months from collection, after which they are anonymized or deleted.

Where personal data is no longer required for any legitimate purpose and no legal retention obligation applies, 206pub will securely delete or anonymize the data.

7. Security Measures

206pub implements appropriate technical and organizational measures to protect personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption in transit: All data transmitted between your device and the 206pub Platform is protected by 256-bit SSL/TLS encryption;
• Encryption at rest: Sensitive personal data stored on 206pub servers is encrypted using industry-standard algorithms;
• Access controls: Access to personal data is restricted to 206pub personnel and authorized service providers who require it for legitimate operational purposes, based on a principle of least privilege;
• Payment tokenization: Payment details are tokenized — 206pub does not store full GCash PINs, card numbers, or online banking passwords;
• Security monitoring: The 206pub Platform is monitored for unauthorized access attempts, anomalous activity, and potential security incidents;
• Incident response: 206pub maintains a data breach response procedure. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, 206pub will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

8. Cookies & Tracking Technologies

8.1 What Are Cookies

Cookies are small text files placed on your device by a website when you visit it. 206pub uses cookies and similar technologies (such as local storage) to operate and improve the Platform.

8.2 Cookies Used by 206pub

8.3 Cookie Management

Strictly necessary cookies cannot be disabled as they are required for the Platform to function. Analytics cookies can be controlled through your browser settings — most modern browsers allow you to block or delete cookies. Note that disabling certain cookies may affect the functionality of the 206pub Platform. 206pub does not use third-party behavioral advertising cookies.

9. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012 (Republic Act 10173), you have the following rights in relation to personal data held by 206pub:

• Right to be Informed: The right to know whether 206pub holds personal data about you and to receive information about how it is processed — which is the primary purpose of this Policy;
• Right of Access: The right to request a copy of the personal data 206pub holds about you and information about the purposes for which it is processed;
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. Most profile information can be updated directly within your 206pub account settings; corrections to identity documents require support contact;
• Right to Erasure: The right to request deletion of personal data in certain circumstances — for example, where the data is no longer necessary for the purposes it was collected. This right is subject to overriding legal obligations, including PAGCOR and AMLA record-keeping requirements that require 206pub to retain certain data for defined periods;
• Right to Data Portability: The right to receive certain personal data in a structured, commonly used format;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. You can withdraw consent for promotional communications at any time via account settings;
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe 206pub has violated your data privacy rights.

To exercise any of the above rights, please contact the 206pub Data Privacy Officer via the live chat support channel or through written correspondence. 206pub will respond to verified requests within fifteen (15) working days of receipt, or within such other period as may be prescribed by the NPC.

206pub may need to verify your identity before processing a privacy rights request to ensure the security of your personal data.

10. Minors & Age Policy

The 206pub Platform is strictly intended for use by adults who are 21 years of age or older, in accordance with PAGCOR's regulations governing online gaming in the Philippines. 206pub does not knowingly collect or process personal data of individuals under the age of 21.

If 206pub becomes aware that personal data has been collected from an individual under 21, the affected account will be immediately suspended, the personal data will be deleted to the extent permitted by applicable law, and any deposited funds will be returned to the originating payment method following identity verification of the lawful owner.

If you believe that a person under the age of 21 has registered a 206pub account, please report this immediately to the 206pub support team via live chat. 206pub treats such reports as a compliance priority.

11. Cross-Border Data Transfers

Some of the third-party service providers engaged by 206pub — including game technology providers and analytics platforms — may process personal data on servers located outside the Philippines. Where such transfers occur, 206pub ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Philippine Data Privacy Act of 2012.

These safeguards may include standard contractual data protection clauses, binding corporate rules, or confirmation that the recipient country provides an adequate level of data protection as assessed by the National Privacy Commission or a relevant authority.

12. Changes to This Privacy Policy

206pub reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or the way the Platform operates. The updated effective date will be displayed at the top of this page.

Where changes are material — meaning they meaningfully affect how your personal data is processed or your rights under this Policy — 206pub will notify registered players via platform notification or to the contact details registered on your account, with a minimum of fourteen (14) days' notice before the changes take effect.

Continued use of the 206pub Platform following notification of material changes constitutes acceptance of the updated Privacy Policy.

13. Contact & Privacy Complaints

For all privacy-related inquiries, access requests, correction requests, objections, or complaints, please contact the 206pub Data Privacy Officer through the following channels:

• Live Chat: Available 24 hours a day, 7 days a week via the 206pub Platform. This is the fastest way to reach the privacy team.
• Email: [email protected] — please include "Privacy Request" in the subject line and your registered 206pub username or mobile number to facilitate a faster response.

206pub will acknowledge receipt of your inquiry within two (2) working days and will provide a substantive response within fifteen (15) working days. If your inquiry is complex or involves a large volume of data, 206pub may request an extension of this timeframe, in which case you will be notified.

If you are not satisfied with 206pub's response to your privacy inquiry or complaint, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines, the government body responsible for enforcing the Data Privacy Act of 2012. Information about filing a complaint with the NPC is available on the NPC's official website.