201pub Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") applies to 201pub.co ("201pub", "we", "us", "our") and governs our collection, use, storage, disclosure, and protection of personal data relating to players, registered users, and visitors of the 201pub online gaming platform.

1.2 201pub operates in the Philippines under PAGCOR regulatory oversight and processes personal data in accordance with Republic Act 10173, the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as administered by the National Privacy Commission ("NPC").

1.3 By accessing or using 201pub, you consent to the collection and processing of your personal data as described in this Policy. If you do not consent, you must not use the platform.

2. Personal Data We Collect

201pub collects personal data in the following categories:

201pub does not collect sensitive personal data (as defined under the Philippine DPA) beyond what is strictly necessary for KYC verification and PAGCOR regulatory compliance. We do not collect racial or ethnic origin, political opinions, or health data except where directly relevant to responsible gaming obligations.

3. How We Collect Personal Data

201pub collects personal data through the following means:

• Direct registration: Data you provide when creating your 201pub account, including your mobile number, name, and date of birth;
• KYC submission: Identity and address documents submitted during the verification process;
• Platform use: Data generated automatically as you navigate, play games, and transact on 201pub;
• Payment processors: Transaction reference data passed to 201pub by GCash, Maya, BDO, BPI, and other integrated payment providers when you deposit or withdraw;
• Customer support: Communications you initiate with the 201pub support team via chat or email;
• Cookies and tracking technologies: See Section 9 of this Policy.

4. Purposes of Processing

201pub processes your personal data for the following purposes:

• Creating and managing your player account on 201pub;
• Processing deposits and withdrawals through GCash, Maya, BDO, and other accepted payment channels;
• Verifying your identity and age (21+) as required by PAGCOR regulations and the Philippine Anti-Money Laundering Act;
• Maintaining gaming records as required by PAGCOR for audit and regulatory purposes;
• Providing, operating, and improving the 201pub platform;
• Delivering customer support and responding to queries and complaints;
• Sending account-related notifications (transaction confirmations, security alerts, password resets);
• Administering bonuses, promotions, and loyalty programmes;
• Detecting and preventing fraud, money laundering, and abuse of the 201pub platform;
• Enforcing the 201pub Terms & Conditions and responsible gaming obligations;
• Complying with applicable Philippine law and responding to lawful requests from regulatory authorities including PAGCOR, the NPC, and the AMLC.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 201pub processes personal data on the following legal bases:

• Consent: For optional processing activities such as marketing communications, where you have provided explicit consent at registration or subsequently through account settings;
• Contractual necessity: Processing required to fulfil the player agreement between you and 201pub, including account management and payment processing;
• Legal obligation: Processing required for compliance with PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act, and other applicable Philippine law;
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.

6. Data Sharing & Disclosure

6.1 201pub does not sell personal data to third parties. We may share personal data in the following limited circumstances:

• Payment processors: GCash, Maya, BDO, BPI, Metrobank, Coins.ph, and 7-Eleven, for the purpose of processing deposits and withdrawals. Each processor has its own privacy policy and data protection obligations;
• Game content providers: Where game providers require player session identifiers to deliver live dealer or slot content to authenticated players;
• Identity verification providers: Third-party KYC service providers used to verify government-issued identification during the account verification process;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or regulatory mandate;
• Law enforcement: Philippine law enforcement agencies, where disclosure is required pursuant to a lawful court order or investigation into criminal activity;
• Professional advisors: Legal, accounting, and auditing firms engaged to provide professional services to 201pub, subject to confidentiality obligations.

6.2 All third-party service providers engaged by 201pub are subject to data processing agreements that require them to process personal data only in accordance with 201pub's instructions and in compliance with the Philippine DPA.

7. Data Retention

7.1 201pub retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law and PAGCOR regulations.

7.2 The following indicative retention periods apply:

• Account and gaming records: Retained for a minimum of five (5) years from account closure, as required by PAGCOR and AMLA regulations;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction;
• KYC documents: Retained for the duration of the account relationship and for five (5) years thereafter;
• Support communications: Retained for two (2) years from the date of the communication;
• Technical and usage logs: Retained for twelve (12) months, unless retained longer for security investigation purposes.

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

8. Security Measures

8.1 201pub implements appropriate technical and organisational security measures to protect personal data against unauthorized access, loss, alteration, or disclosure. These measures include:

• SSL/TLS encryption on all data transmitted between your device and the 201pub platform;
• Encryption at rest for sensitive data stored on 201pub servers;
• Access controls limiting data access to authorised 201pub personnel on a need-to-know basis;
• Multi-factor authentication for internal 201pub systems containing player data;
• Regular security assessments and vulnerability testing;
• Employee training on data protection obligations under the Philippine DPA.

9. Cookies & Tracking Technologies

9.1 201pub uses cookies and similar tracking technologies on 201pub.co to:

• Essential cookies: Maintain your authenticated session after login, remember your preferences, and enable core platform functionality. These cannot be disabled without impairing platform functionality.
• Analytics cookies: Collect aggregated, anonymized data about how players navigate and use 201pub, to improve the platform experience.
• Security cookies: Detect fraudulent activity, prevent automated bot access, and protect account security.

9.2 201pub does not use cookies to serve third-party advertising or to track your activity across unrelated websites.

9.3 You may adjust your browser settings to refuse or delete cookies; however, disabling essential cookies may affect your ability to use the 201pub platform, including the login function.

10. Your Rights Under the Philippine DPA

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data processed by 201pub:

• Right to be informed: The right to be notified of the processing of your personal data — addressed by this Privacy Policy;
• Right of access: The right to obtain a copy of the personal data 201pub 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 personal data where it is no longer necessary for the purpose for which it was collected, subject to 201pub's legal retention obligations;
• Right to object: The right to object to processing based on legitimate interests, including direct marketing;
• Right to data portability: The right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of the above rights, contact 201pub's Data Protection Officer using the contact details in Section 13. 201pub will respond to verifiable data subject requests within thirty (30) days, as required by the DPA IRR.

11. Minors & Age Restrictions

Parents and guardians who believe their child has registered on 201pub should contact 201pub support immediately. 201pub will investigate and take appropriate action as promptly as possible.

12. Changes to This Privacy Policy

12.1 201pub may update this Privacy Policy from time to time to reflect changes in applicable law, PAGCOR requirements, or our data processing practices.

12.2 Material changes will be communicated to registered players via their registered Philippine mobile number or email address, and through a prominent notice on the 201pub platform, at least fifteen (15) days before the changes take effect.

12.3 The effective date at the top of this document reflects the date of the most recent revision. Continued use of 201pub following notification of changes constitutes your acknowledgment of the updated Policy.

13. Contact & Data Protection Officer

201pub has designated a Data Protection Officer (DPO) as required by the Philippine Data Privacy Act. For any privacy-related inquiries, data subject requests, or concerns about 201pub's data processing practices, please contact:

You may also file a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe 201pub has violated your data protection rights.