209 pub Privacy Policy

1.1  This Privacy Policy is issued by 209 pub, the online gambling platform operating at 209pub.club (hereinafter referred to as "209 pub," "we," "us," or "our"). 209 pub is the data controller responsible for the personal data of registered players and website visitors processed through the Platform.

1.2  209 pub is designed and operated as a Filipino-first online casino platform, targeting adult players (21 years and above) in the Philippines. The Platform provides access to slots, live dealer games, sports betting, bingo, crash games, and other online gambling services.

1.3  For any questions about this Privacy Policy or about how 209 pub handles your personal data, you may contact our Data Privacy Officer at: [email protected] (plain text, not a clickable link).

2.1  This Privacy Policy applies to all personal data collected and processed by 209 pub in connection with:

• The use of the 209pub.club website, including browsing without registration;
• The registration and maintenance of a 209 pub player account;
• Deposits, withdrawals, and financial transactions conducted through the Platform;
• Participation in games, promotions, loyalty programs, and other Platform services;
• Communications with 209 pub's customer support team via live chat, email, or any other channel;
• Identity verification (KYC) and anti-money laundering (AML) compliance processes.

2.2  This Policy does not apply to third-party websites, applications, or services that may be linked from the 209 pub Platform. 209 pub is not responsible for the privacy practices of such third parties, and we encourage you to review their privacy policies independently.

3.1  209 pub collects the following categories of personal data from players and website visitors:

3.2  209 pub does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance (specifically, government ID details necessary for KYC). We do not collect biometric data, health data, or religious/political data from players.

4.1  Directly from you — when you register an account, complete KYC, make a deposit or withdrawal, contact support, set responsible gaming limits, or claim a promotion.

4.2  Automatically through the Platform — via cookies, session tracking, and server logs when you browse 209pub.club or play games. This includes your IP address, device identifiers, browser characteristics, pages visited, and session duration.

4.3  From third-party service providers — including identity verification (KYC) providers who validate your government-issued Philippine ID, payment processors (GCash, Maya, BPI, BDO, UnionBank) who provide transaction confirmation data, and fraud detection services.

4.4  From game providers — game providers supplying content to the 209 pub Platform may share game session data (bet amounts, outcomes, session timestamps) with 209 pub for the purpose of account management, dispute resolution, and responsible gaming monitoring.

5.1  209 pub processes your personal data for the following purposes, each grounded in a recognized legal basis under the Philippine Data Privacy Act of 2012 (R.A. 10173):

• Account registration and management — necessary for the performance of the contract between you and 209 pub (the Terms and Conditions).
• Identity verification (KYC) and age verification — compliance with legal obligation (PAGCOR regulations, AML requirements under R.A. 9160 as amended).
• Payment processing (deposits and withdrawals) — necessary for the performance of the contract and compliance with financial reporting obligations.
• Fraud prevention and security monitoring — legitimate interests of 209 pub and its players in maintaining a secure gambling environment.
• Anti-money laundering (AML) monitoring — compliance with legal obligation under the Anti-Money Laundering Act (R.A. 9160 as amended by R.A. 10365) and AMLC regulations.
• Responsible gaming monitoring and intervention — legitimate interests and, where applicable, compliance with PAGCOR responsible gaming requirements.
• Customer support and dispute resolution — necessary for the performance of the contract and legitimate business interests.
• Direct marketing and promotional communications — based on your explicit consent given at registration or updated in account settings.
• Platform analytics and improvement — legitimate interests of 209 pub in improving the player experience, using pseudonymized or aggregated data where possible.

6.1  209 pub does not sell, rent, or trade your personal data to unaffiliated third parties for their own commercial use. We share your data only in the following limited circumstances:

• Payment processors: GCash (Mynt), Maya (Voyager Innovations), BPI, BDO, UnionBank, and other payment providers receive the transaction data necessary to process your deposits and withdrawals. These providers process data under their own privacy policies and applicable Philippine financial regulations.
• Identity verification (KYC) providers: Third-party KYC services receive your identity documents and personal details for the sole purpose of verifying your identity and age. They operate under data processing agreements with 209 pub.
• Game providers: Game suppliers receive the account identifiers and session data necessary to operate their games on the 209 pub Platform. They are prohibited from using this data for any purpose other than game delivery and technical support.
• Fraud and security services: Specialized fraud detection and cybersecurity providers may receive technical data (IP addresses, device fingerprints, session metadata) to protect the Platform and its players.
• Regulatory and law enforcement authorities: 209 pub will disclose personal data to PAGCOR, the AMLC, the National Privacy Commission, or other authorized Philippine government bodies where legally required, including in response to lawful court orders or regulatory investigations.
• Corporate transactions: In the event of a merger, acquisition, or sale of all or part of 209 pub's business, player data may be transferred to the acquiring entity, subject to equivalent privacy protections being maintained.

7.1  Some of 209 pub's service providers — including game providers and platform technology suppliers — may be located outside the Philippines and may process your data in other jurisdictions, including within the Asia-Pacific region.

7.2  Where personal data is transferred outside the Philippines, 209 pub ensures that appropriate safeguards are in place, consistent with the requirements of the Philippine Data Privacy Act of 2012, including contractual protections requiring receiving parties to maintain data protection standards equivalent to those required under Philippine law.

7.3  209 pub does not knowingly transfer personal data to jurisdictions that do not provide an adequate level of data protection without appropriate safeguards.

8.1  209 pub retains personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

8.2  At the end of the applicable retention period, personal data will be securely deleted or anonymized. Anonymized data (from which you cannot be identified) may be retained indefinitely for aggregate analytics purposes.

9.1  209 pub uses cookies and similar tracking technologies on the 209pub.club website to support platform functionality, security, and analytics. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in to your 209 pub account and security cookies that help protect against fraud. These cookies cannot be disabled without breaking core Platform functionality.
• Functional Cookies: These remember your preferences — language settings, responsible gaming limit choices, and recently played games — to improve your experience on return visits.
• Analytics Cookies: Used to understand how players interact with the Platform — which pages are most visited, where players encounter errors, and how the lobby navigation performs. Data collected is pseudonymized and used in aggregate form. You may opt out of analytics cookies in your browser settings.

9.2  209 pub does not use third-party advertising cookies or cross-site tracking cookies for targeted advertising purposes. We do not participate in advertising networks that track your behavior across other websites.

9.3  You can manage cookie settings through your browser's built-in controls. Most modern browsers allow you to view, delete, and block cookies. Note that disabling strictly necessary cookies will impair your ability to log in and use the Platform.

10.1  Under the Philippine Data Privacy Act of 2012 (R.A. 10173), you have the following rights with respect to your personal data held by 209 pub:

10.2  To exercise any of the above rights, submit a written request to 209 pub's Data Privacy Officer via the live chat support channel or by email to: [email protected]. Please include your full name, registered email address, and a description of the right you wish to exercise. 209 pub will acknowledge your request within 3 business days and respond substantively within 30 calendar days.

10.3  Where a request cannot be fulfilled in full (for example, because data must be retained to satisfy a legal obligation), 209 pub will provide a written explanation of the limitation applied.

11.1  209 pub does not knowingly collect personal data from individuals under the age of 21. The Platform is strictly intended for adults aged 21 and above in accordance with PAGCOR guidelines. Registration and gameplay by persons under 21 is prohibited under 209 pub's Terms and Conditions.

11.2  Where 209 pub discovers that personal data has been collected from a person under the age of 21 — including through age verification failure — all such data will be deleted, the associated account will be closed, and any deposits will be returned to the originating payment method where technically feasible.

11.3  If you are a parent or guardian and believe that a minor has provided personal data to 209 pub, please contact our support team immediately so that appropriate action can be taken.

12.1  209 pub implements technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and 209 pub servers;
• Industry-standard hashing for password storage — plain text passwords are never stored;
• Two-factor authentication (2FA) available on all player accounts;
• Access controls limiting staff access to player data to those with a genuine operational need;
• Regular security reviews and penetration testing of Platform infrastructure;
• Automated fraud and anomaly detection monitoring for suspicious account activity.

12.2  Notwithstanding these measures, no data transmission over the internet or electronic storage system can be guaranteed as 100% secure. Players are encouraged to use strong, unique passwords and to enable 2FA on their 209 pub accounts as an additional personal security measure.

12.3  In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 209 pub will notify the National Privacy Commission within 72 hours of becoming aware of the breach, as required by R.A. 10173. Affected players will be notified without undue delay where the breach is likely to result in a high risk to their personal data.

13.1  209 pub will only send you promotional and marketing communications — including bonus offers, new game announcements, tournament invitations, and VIP program updates — if you have provided explicit opt-in consent to receive them. Consent can be given during the registration process or updated at any time in your Account Settings.

13.2  You may withdraw your marketing consent at any time, with effect immediately upon receipt of your withdrawal notice. Withdrawal of marketing consent does not affect your ability to use the 209 pub Platform, receive transactional communications (deposit confirmations, withdrawal notifications, account security alerts), or claim bonuses you navigate to directly.

13.3  Transactional and account-related communications (deposit receipts, withdrawal status, KYC requests, account security notifications, responsible gaming tool confirmations) are sent regardless of your marketing preferences, as they are necessary for the operation of your account.

13.4  209 pub does not engage in SMS marketing without prior consent. Promotional SMS communications are separate from the OTP / 2FA SMS codes sent for account security purposes, which are always operational.

14.1  209 pub processes your game activity data, deposit and withdrawal patterns, and session behavior data for responsible gaming monitoring purposes. This processing is carried out in 209 pub's legitimate interests and in compliance with PAGCOR responsible gaming requirements, and is aimed at identifying players who may be experiencing gambling-related harm.

14.2  Where responsible gaming monitoring identifies indicators of potential problem gambling, 209 pub may use this data to: send in-platform responsible gaming messages; proactively offer responsible gaming tools; apply additional verification steps before processing certain transactions; or, in serious cases, impose account limits or initiate contact through the support team.

14.3  Responsible gaming data is treated with heightened sensitivity. Access to this data is restricted to 209 pub's responsible gaming team and senior compliance staff, and is not used for marketing or commercial profiling purposes.

14.4  Where a player activates a self-exclusion, the associated data (account details, exclusion period, reason where provided) is retained for the duration of the exclusion and for five years thereafter, to prevent the re-registration of excluded players. For more information on responsible gaming tools, visit our Responsible Gaming page.

15.1  The 209 pub Platform incorporates game content, payment processing, and technical infrastructure provided by third-party service providers. While these providers operate on or within the 209 pub Platform, they are governed by their own privacy policies in addition to any data processing agreements with 209 pub.

15.2  Game providers supplying content to 209 pub are required, under their contractual agreements with 209 pub, to process player data only for purposes directly related to game delivery and technical support. They are not permitted to use 209 pub player data for independent marketing or commercial purposes.

15.3  Payment processors (GCash, Maya, BPI, BDO, UnionBank, and others) operate as independent data controllers for the data they receive in connection with payment transactions, and are regulated by Bangko Sentral ng Pilipinas (BSP) and the Anti-Money Laundering Council (AMLC). 209 pub is not responsible for how these entities handle your financial data under their own policies.

16.1  209 pub may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or the services we offer. When we make material changes — those that substantively affect your rights or how we use your data — we will notify you by a prominent notice on the Platform and/or by email to your registered address, at least 7 days before the change takes effect.

16.2  The "Last Updated" date at the top of this page reflects the most recent revision. We encourage you to review this Privacy Policy periodically, particularly when you receive a notification about changes.

16.3  Continued use of the 209 pub Platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the updated Policy. If you do not agree with the changes, you should close your account and discontinue use of the Platform before the changes take effect.

17.1  For any questions, concerns, or requests relating to this Privacy Policy or to 209 pub's handling of your personal data, please contact our Data Privacy Officer through:

17.2  If you are not satisfied with 209 pub's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC). The NPC is the supervisory authority for the Data Privacy Act of 2012 and accepts complaints from Philippine residents regarding organizations' data handling practices.

17.3  This Privacy Policy constitutes the complete statement of 209 pub's practices with respect to the personal data collected through the Platform and supersedes all prior privacy notices or statements issued by 209 pub in respect of the same subject matter.