1. Introduction
200pub ("we," "us," "our," or "the Company") operates the online casino and sports betting platform accessible at 200pub.club (the "Platform"). We are committed to protecting the privacy and personal data of all users, including registered players and visitors from across the Philippines — whether you're in Metro Manila, Cebu, Davao, or anywhere else in the country.
This Privacy Policy ("Policy") describes how 200pub collects, uses, discloses, stores, and protects your personal information when you access or use the Platform. It is drafted in compliance with Republic Act No. 10173, known as the Philippine Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").
By registering an account, accessing the Platform, or otherwise providing personal information to 200pub, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must not use the Platform.
2. Data Controller
For the purposes of the Philippine Data Privacy Act, 200pub is the personal information controller ("PIC") responsible for the personal data collected through the Platform. 200pub determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable data protection laws.
200pub has appointed a Data Protection Officer ("DPO") as required under the DPA. Contact details for the DPO are set out in Section 15 of this Policy.
3. Categories of Personal Data We Collect
3.1 Registration Data
When you create a 200pub account, we collect: full name, date of birth, mobile number (Philippine format), email address, and chosen password (stored in hashed form — never in plain text).
3.2 Identity Verification (KYC) Data
To comply with PAGCOR's Know Your Customer requirements and the Anti-Money Laundering Act, we may collect: government-issued photo identification (e.g., Philippine passport, SSS ID, PhilHealth ID, driver's license, UMID), proof of address, and a selfie or live photo for facial verification.
3.3 Financial Data
When you make deposits or withdrawals, we collect transaction records including: GCash or Maya account reference numbers, BPI/BDO/Metrobank account details (last four digits and account name only), transaction amounts in Philippine Peso, and timestamps. 200pub does not store full bank account numbers or card numbers on our servers.
3.4 Usage and Device Data
We automatically collect: IP address, device type and operating system, browser type and version, session duration, pages visited, game history, betting records, and login timestamps.
3.5 Communications Data
Records of your communications with 200pub's customer support team, including live chat transcripts and email correspondence, are retained for quality assurance and dispute resolution purposes.
4. How We Collect Your Data
200pub collects personal data through the following means:
- Direct submission: Information you provide when registering, completing KYC, making transactions, or contacting support.
- Automated collection: Technical data collected automatically through cookies, web beacons, and server logs when you use the Platform.
- Third-party sources: Identity verification and fraud screening data from licensed KYC service providers; payment transaction data from GCash, Maya, and banking partners; and regulatory data from PAGCOR where required.
5. Purposes of Processing Your Personal Data
200pub processes your personal data for the following specific, legitimate purposes:
- Account creation, authentication, and management.
- Processing deposits, withdrawals, and in-platform transactions in Philippine Peso.
- Identity verification and KYC compliance as required by PAGCOR and Philippine AML law.
- Detection, prevention, and investigation of fraud, money laundering, and other prohibited conduct.
- Providing customer support and resolving disputes.
- Sending transactional notifications (deposit confirmations, withdrawal status, security alerts) via SMS to your registered Philippine mobile number or by email.
- Sending promotional communications and bonus offers, where you have consented to receive them.
- Responsible gaming monitoring — including identifying patterns that may indicate problem gambling and applying player-requested limits or self-exclusion.
- Complying with legal obligations under Philippine law, PAGCOR regulations, and court or regulatory orders.
- Platform improvement, security monitoring, and analytics to enhance the player experience.
6. Legal Basis for Processing
Under the Philippine Data Privacy Act, 200pub relies on the following lawful bases for processing your personal data:
- Contractual necessity: Processing required to perform our contract with you (the Terms and Conditions), including account management and transaction processing.
- Legal obligation: Processing required to comply with Philippine law — including the Anti-Money Laundering Act, PAGCOR regulations, and the Data Privacy Act itself.
- Legitimate interests: Processing for fraud prevention, security monitoring, and platform improvement, where such interests are not overridden by your privacy rights.
- Consent: Processing for direct marketing communications, where you have explicitly opted in. You may withdraw consent at any time by contacting support or updating your notification preferences.
7. Disclosure and Sharing of Personal Data
200pub does not sell your personal data to third parties. We may share your personal data only in the following circumstances and only to the extent necessary:
- Payment processors: GCash, Maya, BPI, BDO, Metrobank, and other payment service providers receive transaction data necessary to process your deposits and withdrawals.
- Game providers: Pragmatic Play, JILI, Evolution Gaming, and other certified studios receive anonymized session data to facilitate gameplay and resolve game disputes.
- KYC and fraud screening partners: Licensed identity verification service providers receive KYC documents solely for verification purposes.
- Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and Philippine law enforcement agencies, where 200pub is legally required to disclose information.
- Professional advisers: Legal counsel, auditors, and compliance consultants, under strict confidentiality obligations.
All third parties with whom 200pub shares personal data are required to process such data only for the specific purpose disclosed and in accordance with applicable data protection standards.
8. Data Retention
200pub retains your personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following retention periods:
- Active account data: Retained for the duration of your account's active status plus five (5) years after account closure, to comply with AML record-keeping requirements.
- KYC documents: Retained for a minimum of five (5) years following the end of the business relationship, as required by PAGCOR and the AMLC.
- Transaction records: Retained for a minimum of five (5) years in compliance with Philippine financial record-keeping obligations.
- Support communications: Retained for two (2) years for dispute resolution and quality assurance purposes.
- Marketing consents and opt-outs: Retained indefinitely to demonstrate compliance with your communication preferences.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents reconstruction of the original data.
9. Data Security
200pub implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:
- TLS 1.2/1.3 encryption for all data transmitted between your device and 200pub's servers.
- Password hashing using industry-standard cryptographic algorithms — plain-text passwords are never stored.
- Role-based access controls limiting employee access to personal data on a need-to-know basis.
- Regular security assessments and penetration testing of the Platform infrastructure.
- Two-factor authentication (2FA) for player accounts and internal system access.
Despite these measures, no online platform can guarantee absolute security. In the event of a personal data breach that poses a risk to your rights and freedoms, 200pub will notify the National Privacy Commission and affected players in accordance with NPC Circular 16-03 and applicable breach notification requirements.
10. Your Data Privacy Rights
Under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by 200pub:
- Right to be Informed: The right to know what personal data 200pub collects and how it is processed — which this Policy fulfils.
- Right of Access: The right to request a copy of your personal data held by 200pub.
- Right to Rectification: The right to have inaccurate or incomplete personal data corrected.
- Right to Erasure (Right to be Forgotten): The right to request deletion of your personal data, subject to 200pub's 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, machine-readable format.
- Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (privacy.gov.ph) if you believe your data rights have been violated.
To exercise any of these rights, please contact 200pub's Data Protection Officer using the details in Section 15. We will respond to verified requests within fifteen (15) working days, as required by NPC guidelines.
11. Cookies and Tracking Technologies
200pub uses cookies and similar tracking technologies on the Platform. Cookies are small text files placed on your device that help us recognize returning users, maintain your login session, and improve Platform performance.
11.1 Types of Cookies Used
- Strictly necessary cookies: Required for the Platform to function, including session management and security tokens. Cannot be disabled.
- Performance cookies: Collect anonymized data about how players use the Platform to help us identify areas for improvement.
- Functional cookies: Remember your preferences, such as language settings and game lobby filters.
You can manage non-essential cookies through your browser settings. Disabling certain cookies may affect Platform functionality. 200pub does not use third-party advertising or cross-site tracking cookies.
12. Minors and Age Restriction
The 200pub Platform is strictly for individuals who are 21 years of age or older, in accordance with PAGCOR's regulations on online gaming in the Philippines. 200pub does not knowingly collect personal data from individuals under the age of 21. If we discover that personal data has been submitted by or on behalf of a person under 21, we will immediately suspend the relevant account and delete the associated personal data. Parents and guardians are encouraged to use parental controls and supervise minors' internet access to prevent underage registration attempts.
13. Cross-Border Data Transfers
Some of 200pub's third-party service providers — including game providers and cloud infrastructure partners — may be located outside the Philippines. Where personal data is transferred outside the Philippines, 200pub ensures that adequate safeguards are in place as required by the DPA and NPC regulations, including contractual clauses requiring the recipient to provide a standard of data protection comparable to that required under Philippine law. 200pub will only engage service providers in jurisdictions that offer adequate data protection standards or where appropriate contractual safeguards have been implemented.
14. Amendments to This Policy
200pub may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or regulatory requirements. When material changes are made, we will notify registered players via SMS to your registered Philippine mobile number or by email, and post the updated Policy on the Platform with a revised "Last Updated" date. Your continued use of the Platform following notification constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically to stay informed about how 200pub protects your personal data.
15. Contact and Data Protection Officer
If you have any questions about this Privacy Policy, wish to exercise your data privacy rights, or want to report a data privacy concern, please contact 200pub's Data Protection Officer through the following channels:
- Live Chat: 24/7 support chat available directly on the 200pub.club website. Request to speak with the Data Protection Officer.
- Email: [email protected] — mark your message "Attn: Data Protection Officer" (plain text — not a clickable link).
Alternatively, you may file a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights under RA 10173 have been violated. The NPC's website is accessible by searching "National Privacy Commission Philippines" in your browser.