pub222 Privacy Policy — How We Protect Your Personal Data

1 Who We Are — The Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, pub222 acts as the Personal Information Controller (PIC) with respect to personal data collected through pub222.club and associated services. pub222 operates as a PAGCOR-licensed online gaming platform serving registered players in the Philippines.

pub222 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data privacy law. Inquiries relating to data privacy may be directed to pub222's support team via Live Chat at pub222.club or by email at the address listed in Section 11 of this Policy.

2 What Personal Information We Collect

pub222 collects personal information in the following categories:

2.1 Information You Provide Directly

• Identity information: Full legal name, date of birth, gender, and nationality as provided during account registration and KYC verification;
• Contact information: Philippine mobile number and email address;
• Government-issued identification: Copies or images of Philippine government ID documents submitted for KYC purposes (e.g., PhilSys National ID, passport, driver's license, UMID, SSS ID, PRC ID, Voter's ID);
• Financial information: GCash or PayMaya account details, BPI/BDO/Metrobank account information, and transaction history relating to deposits and withdrawals on pub222; and
• Communications: Records of support conversations via Live Chat or email.

2.2 Information Collected Automatically

• Device information: Device type, operating system, browser type and version, and screen resolution;
• Network information: IP address, internet service provider, and approximate geographic location derived from IP;
• Session data: Login timestamps, session duration, pages visited, games played, bets placed, and actions taken within the pub222 platform; and
• Cookies and similar technologies: As described in Section 9 of this Policy.

3 Legal Bases and Purposes for Processing

pub222 processes personal information only where a lawful basis exists under RA 10173. The primary legal bases and corresponding purposes are:

• Contract performance: To create and manage your pub222 account, process deposits and withdrawals, credit bonuses, and provide gameplay services — all of which are necessary to perform the contract between you and pub222;
• Legal obligation: To conduct KYC identity verification, comply with anti-money laundering reporting requirements under the Philippine AMLA, fulfill PAGCOR regulatory reporting obligations, and retain records as required by Philippine law;
• Legitimate interests: To detect, prevent, and investigate fraud, bonus abuse, money laundering, and other prohibited conduct; to operate and improve the pub222 platform; and to manage responsible gaming obligations; and
• Consent: To send you marketing communications, promotional offers, and bonus notifications — where you have explicitly opted in to receive such communications. You may withdraw this consent at any time via your account settings or by contacting support.

4 How We Use Your Personal Information

pub222 uses the personal information it holds for the following specific purposes:

1. Creating, verifying, and managing your pub222 account;
2. Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods;
3. Conducting age and identity verification in compliance with PAGCOR licensing requirements — confirming that all players are 21 years of age or older;
4. Detecting and preventing fraudulent transactions, account takeovers, bonus abuse, and money laundering;
5. Providing customer support through the Live Chat function;
6. Sending account-related notifications such as deposit confirmations, withdrawal updates, OTP codes, and security alerts — these communications are operational and cannot be opted out of while your account is active;
7. Sending promotional and marketing communications where you have consented to receive them;
8. Monitoring gameplay patterns for responsible gaming compliance and applying protective measures where appropriate under PAGCOR's responsible gaming framework;
9. Fulfilling PAGCOR regulatory reporting and audit requirements; and
10. Complying with applicable Philippine laws, including but not limited to RA 10173, the Anti-Money Laundering Act (AMLA), and applicable tax laws.

5 Sharing of Personal Information

pub222 may share personal information with the following categories of recipient, strictly on a need-to-know basis and subject to appropriate confidentiality obligations:

5.1 Game Studio Partners

Certified game studios whose titles are available on pub222 may receive anonymized or aggregated gameplay data for game performance and RNG audit purposes. Individual player identity information is not shared with game studios.

5.2 Payment Processors

pub222 shares the minimum financial information necessary to process your deposit or withdrawal with payment providers including GCash, PayMaya, BPI, BDO, and Metrobank. Payment processors operate under their own privacy policies and applicable Philippine financial regulations.

5.3 Regulatory Authorities

pub222 is required to share player information with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities upon lawful request or as required by pub222's licensing conditions. pub222 will comply with all such lawful demands and will notify affected Players where legally permitted to do so.

5.4 Service Providers

pub222 engages third-party service providers for functions including cloud hosting, KYC verification technology, customer support platforms, and fraud detection services. These providers act as Personal Information Processors (PIPs) on pub222's behalf and are contractually bound to process personal data only in accordance with pub222's documented instructions and applicable Philippine data privacy law.

5.5 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of assets involving pub222, personal information held by pub222 may be transferred to the acquiring entity, subject to that entity assuming equivalent data protection obligations. Affected Players will be notified as required by RA 10173.

6 Data Retention

pub222 retains personal information only for as long as is necessary for the purposes described in this Policy, or as required by applicable Philippine law and PAGCOR regulatory requirements. The general retention principles applied by pub222 are:

• Active account data: Retained for the duration of the account relationship and for a period of five (5) years following account closure, in accordance with PAGCOR recordkeeping requirements and Philippine anti-money laundering regulations;
• KYC documents: Retained for a minimum of five (5) years from the date of submission or from the date of account closure, whichever is later, as required by AMLA implementing rules;
• Transaction records: Retained for a minimum of five (5) years as required by the AMLC;
• Customer support communications: Retained for two (2) years from the date of the relevant interaction; and
• Marketing consent records: Retained until consent is withdrawn and for a reasonable period thereafter to demonstrate compliance.

Upon expiry of the applicable retention period, personal information is securely deleted or anonymized in accordance with pub222's data disposal procedures.

7 Data Security

pub222 implements organizational and technical security measures appropriate to the nature of the personal information processed and the risks associated with its processing. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and pub222 servers;
• Encryption of sensitive data at rest, including KYC documents and financial information;
• Role-based access controls limiting access to personal data to authorized personnel with a documented operational need;
• Regular security assessments and penetration testing of the pub222 platform;
• Multi-factor authentication requirements for internal pub222 staff accessing production systems containing personal data; and
• Documented incident response procedures for personal data breaches, including notification obligations under RA 10173 and the NPC's Circular on Personal Data Breach Management.

8 Your Data Privacy Rights Under RA 10173

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal information held by pub222:

To exercise any of these rights, contact pub222's Data Protection Officer via Live Chat or email as described in Section 11. pub222 will respond to verified requests within the timeframes required by RA 10173 — generally within fifteen (15) days of receiving a complete, verifiable request. pub222 may need to verify your identity before processing your request to prevent unauthorized disclosure.

If you believe that pub222 has not handled your personal information in accordance with applicable law, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

9 Cookies and Similar Technologies

pub222 uses cookies and similar tracking technologies on the pub222.club website to support platform functionality, measure performance, and improve the user experience. The categories of cookies used by pub222 are as follows:

• Strictly necessary cookies: Essential for the pub222 platform to function — including maintaining your login session, security tokens, and account preferences. These cannot be disabled without affecting platform functionality;
• Analytics cookies: Used to understand how Players navigate and use pub222, which pages are most visited, and where technical issues occur. This data is aggregated and does not identify individual Players; and
• Functionality cookies: Remember your preferences, such as display language and regional settings, to provide a more personalized experience on repeat visits.

pub222 does not use third-party advertising or behavioral tracking cookies for the purpose of serving advertisements on external websites. Your browser settings can be used to manage or delete cookies, but disabling strictly necessary cookies may impair your ability to use pub222's core functions, including login and gameplay.

10 Cross-Border Data Transfers

Some of pub222's service providers — including cloud hosting and KYC technology providers — may be located or operate servers outside the Philippines. Where personal data is transferred to jurisdictions other than the Philippines, pub222 ensures that such transfers are subject to appropriate safeguards, including contractual data processing agreements that impose data protection standards consistent with RA 10173 and NPC guidelines on cross-border transfers. pub222 does not transfer personal data internationally where adequate protections cannot be confirmed.

11 Children and Minors

pub222 is strictly a 21+ platform. pub222 does not knowingly collect personal information from persons under 21 years of age. If pub222 discovers that personal information has been submitted by a player who is under 21, the account will be closed, the data will be deleted in accordance with pub222's disposal procedures, and the matter will be referred to PAGCOR as required by licensing conditions.

If you are a parent or guardian and believe your minor child has submitted personal information to pub222, please contact pub222 immediately via Live Chat so that appropriate action can be taken.

12 Amendments to This Policy

pub222 may update or amend this Privacy Policy from time to time to reflect changes in applicable law, PAGCOR regulatory requirements, or pub222's data processing practices. Material changes will be communicated to registered Players via their registered Philippine mobile number or email address at least fourteen (14) days before the amended Policy takes effect. The current version of this Policy, including its effective date and version number, is always available at pub222.club/privacy-policy. Continued use of pub222 after the effective date of any amendment constitutes acceptance of the revised Policy.

13 Contact and Data Privacy Inquiries

For questions, complaints, or requests relating to this Privacy Policy or pub222's handling of your personal data, please contact pub222 through the following channels:

• Live Chat: Available 24/7 on pub222.club — Filipino-speaking and English-speaking agents available at all hours. For formal data privacy requests, state "Data Privacy Request" at the start of your message so it can be routed to the Data Protection Officer.
• Email: [email protected] — include "Privacy Policy Inquiry" in your subject line.

pub222 will respond to all formal data privacy inquiries within fifteen (15) calendar days of receipt. For complaints that cannot be resolved directly with pub222, you may escalate to the National Privacy Commission (NPC) of the Philippines through the NPC's official complaint process.