Introduction
206pub ("206pub," "we," "us," or "our") is committed to protecting the privacy and personal data of every individual who accesses or uses the 206pub online gaming platform at https://206pub.net (the "Platform"). This Privacy Policy ("Policy") describes how 206pub collects, uses, stores, discloses, and protects personal information in connection with your use of the Platform and any related services.
This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Republic of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). By accessing the Platform, registering an account, or otherwise providing your personal information to 206pub, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.
Scope: This Policy applies to all personal data collected by 206pub through the Platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and any other use of 206pub services. It applies to all registered players and visitors, including those accessing the Platform from Metro Manila, Cebu, Davao, and all other regions of the Philippines.
This Policy should be read together with the 206pub Terms & Conditions, which govern your use of the Platform. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.
Data Controller
For the purposes of the Data Privacy Act of 2012 and this Policy, 206pub acts as the personal information controller ("PIC") in respect of the personal data it collects and processes in connection with the Platform. As PIC, 206pub determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable Philippine data protection law.
206pub has designated a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and applicable data protection legislation. If you have any questions, concerns, or requests relating to the processing of your personal data, you may contact the 206pub DPO using the contact details provided in Section 15 of this Policy.
Data We Collect
206pub collects the following categories of personal data in connection with your use of the Platform:
3.1 Identity & Contact Data
- Full legal name as it appears on your government-issued identification;
- Date of birth (used to verify the 21+ age requirement);
- Nationality and country of residence;
- Residential address, including barangay, city or municipality, province, and postal code;
- Email address and mobile number.
3.2 Identity Verification Data
- Copies of government-issued photo identification (e.g., Philippine passport, UMID, SSS ID, PhilSys National ID, or driver's license);
- Proof of address documentation (e.g., utility bill, bank statement, or barangay certificate);
- Selfie or live photo submitted for identity verification purposes;
- Any additional documentation requested for Know Your Customer (KYC) compliance.
3.3 Financial Data
- Payment method details, including GCash account reference, PayMaya account reference, BPI, BDO, or Metrobank account details (we do not store full bank account numbers or card numbers);
- Transaction history, including deposit amounts, withdrawal amounts, dates, and payment method used;
- Account balance information.
3.4 Gaming & Activity Data
- Game participation history, including games played, wager amounts, outcomes, and session durations;
- Bonus and promotion usage history;
- Responsible gaming tool settings, including deposit limits, session limits, and self-exclusion status;
- Customer support interaction records, including chat logs and email correspondence.
3.5 Technical & Device Data
- IP address and approximate geolocation derived from IP;
- Device type, operating system, and browser type and version;
- Unique device identifiers;
- Log data, including access times, pages viewed, and referring URLs;
- Cookie and similar tracking technology data as described in Section 8.
Sensitive Personal Information: Certain data we collect, such as government-issued ID numbers and financial account references, may constitute sensitive personal information under the Data Privacy Act of 2012. 206pub applies heightened security measures to the storage and processing of such data and limits access to authorized personnel only.
How We Collect Data
206pub collects personal data through the following means:
- Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
- Automated collection: Technical and device data collected automatically when you access the Platform, through cookies, web beacons, server logs, and similar technologies;
- Third-party sources: Identity verification data from KYC service providers; payment confirmation data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank; fraud prevention data from third-party fraud detection services;
- Publicly available sources: Information available from public registries or databases where relevant to regulatory compliance obligations.
How We Use Your Data
206pub processes your personal data for the following purposes:
| Purpose | Data Categories Used |
|---|---|
| Account registration and management | Identity & contact data, identity verification data |
| Age verification (21+ requirement) | Date of birth, identity verification data |
| Processing deposits and withdrawals | Financial data, identity data |
| Providing and improving gaming services | Gaming & activity data, technical data |
| KYC and anti-money laundering compliance | Identity data, financial data, verification data |
| Fraud prevention and security | All categories as necessary |
| Responsible gaming monitoring and tools | Gaming & activity data, identity data |
| Customer support | Identity data, gaming data, support records |
| Marketing and promotions (with consent) | Identity & contact data, gaming activity data |
| Legal and regulatory compliance | All categories as required by law |
206pub will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.
Legal Basis for Processing
206pub processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:
- Contractual necessity: Processing required to perform the contract between you and 206pub, including account management, payment processing, and delivery of gaming services;
- Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including anti-money laundering obligations, KYC requirements, and regulatory reporting;
- Legitimate interests: Processing necessary for 206pub's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests;
- Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
Data Sharing & Disclosure
206pub does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:
- Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals;
- KYC and identity verification providers: Third-party service providers engaged to assist with identity verification and age verification;
- Fraud prevention and security providers: Third-party services used to detect and prevent fraudulent activity on the Platform;
- IT and platform service providers: Cloud hosting, data storage, and technical infrastructure providers who process data on 206pub's behalf under data processing agreements;
- Regulatory and law enforcement authorities: Philippine government agencies, including the National Privacy Commission, and law enforcement bodies, where disclosure is required by law or in response to a lawful request;
- Professional advisers: Legal counsel, auditors, and other professional advisers bound by confidentiality obligations.
Data Processing Agreements: All third-party service providers who process personal data on behalf of 206pub are required to enter into data processing agreements that obligate them to process such data only on 206pub's instructions and in accordance with applicable data protection law.
Cookies & Tracking Technologies
206pub uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security and fraud prevention functions. The following types of cookies may be used:
- Strictly necessary cookies: Essential for the operation of the Platform, including session management, authentication, and security. These cannot be disabled without affecting Platform functionality;
- Functional cookies: Used to remember your preferences and settings, such as language preferences and responsible gaming tool configurations;
- Analytics cookies: Used to collect aggregated, anonymized data about how users interact with the Platform, helping 206pub improve its services;
- Security cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats.
You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. 206pub does not use cookies to serve third-party advertising on the Platform.
Data Retention
206pub retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:
- Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements under Philippine law;
- Financial transaction data: Retained for a minimum of five (5) years from the date of the transaction;
- Gaming activity data: Retained for the duration of your account and for three (3) years following account closure;
- Customer support records: Retained for three (3) years from the date of the interaction;
- Technical and device data: Retained for up to twelve (12) months from collection, unless required for longer periods for security or fraud investigation purposes.
Upon expiry of the applicable retention period, 206pub will securely delete or anonymize your personal data in accordance with its data disposal procedures. Where data is anonymized rather than deleted, the anonymized data may be retained indefinitely for analytical purposes.
Data Security
206pub implements appropriate technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:
- Encryption of personal data in transit using industry-standard TLS/SSL protocols;
- Encryption of sensitive personal data at rest using AES-256 or equivalent encryption standards;
- Role-based access controls limiting access to personal data to authorized personnel on a need-to-know basis;
- Regular security assessments, vulnerability scanning, and penetration testing of the Platform;
- Multi-factor authentication requirements for administrative access to systems containing personal data;
- Staff training on data protection obligations and security best practices.
Security Incidents: In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 206pub will notify the National Privacy Commission and affected data subjects in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-03. Despite our best efforts, no security system is impenetrable, and 206pub cannot guarantee the absolute security of your personal data.
Your Rights as a Data Subject
Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 206pub:
- Right to be informed: The right to be informed of how your personal data is being collected and processed, as set out in this Policy;
- Right of access: The right to request a copy of the personal data 206pub holds about you and information about how it is processed;
- Right to rectification: The right to request correction of inaccurate or incomplete personal data;
- Right to erasure or blocking: The right to request deletion or blocking of your personal data where processing is unlawful or the data is no longer necessary for the purposes for which it was collected, subject to 206pub's legal retention obligations;
- Right to object: The right to object to the processing of your personal data on grounds relating to your particular situation, including processing for direct marketing purposes;
- Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible;
- Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission if you believe your data protection rights have been violated.
To exercise any of the above rights, please submit a written request to the 206pub Data Protection Officer using the contact details in Section 15. 206pub will respond to your request within thirty (30) days of receipt, or within such other timeframe as required by applicable law. We may need to verify your identity before processing your request.
Marketing Opt-Out: If you have consented to receive marketing communications from 206pub, you may withdraw that consent at any time by contacting our support team. Withdrawal of consent will not affect the lawfulness of any processing carried out prior to withdrawal, and will not affect your ability to use the Platform.
Children's Privacy
The 206pub Platform is strictly intended for individuals who are at least twenty-one (21) years of age. 206pub does not knowingly collect personal data from individuals under the age of 21. The minimum age requirement is enforced through mandatory age verification during the registration process.
If 206pub becomes aware that personal data has been collected from an individual under the age of 21, it will take immediate steps to delete such data and close the associated account. Any winnings generated by an underage player will be void and non-payable in accordance with the 206pub Terms & Conditions.
If you are a parent or guardian and believe that your child under the age of 21 has provided personal data to 206pub, please contact us immediately using the details in Section 15 so that we can take appropriate action.
Cross-Border Data Transfers
In the course of providing the Platform and related services, 206pub may transfer your personal data to recipients located outside the Republic of the Philippines, including to cloud service providers and technology partners operating in other jurisdictions. Any such cross-border transfer of personal data will be carried out in accordance with the requirements of the Data Privacy Act of 2012 and the rules issued by the National Privacy Commission governing cross-border data flows.
Where personal data is transferred outside the Philippines, 206pub will ensure that appropriate safeguards are in place to protect your data, which may include contractual clauses approved by the NPC, adequacy determinations, or other lawful transfer mechanisms. By using the Platform, you acknowledge and consent to such transfers where necessary for the provision of 206pub's services.
Policy Updates
206pub reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made to this Policy, 206pub will notify registered players by posting a notice on the Platform or by sending an email to the address registered on your account, prior to the changes taking effect.
The updated Policy will be effective from the date indicated at the top of the document. Your continued use of the Platform after the effective date of any amendment constitutes your acknowledgment of the updated Policy. We encourage you to review this Policy periodically to stay informed of how 206pub protects your personal data.
Contact Us
If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 206pub, please contact our Data Protection Officer. Our team is available to assist players from all across the Philippines, including Metro Manila, Cebu, Davao, and Quezon City.
Data Protection Officer
Email: [email protected]
Support Email: [email protected]
Response Time: Within 30 days of receipt of your request
Language: English
You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that 206pub has not handled your personal data in accordance with applicable data protection law. Information about the NPC and how to file a complaint is available through official Philippine government channels.