207 pub Privacy Policy

1. Data Controller

207 pub is the data controller responsible for the personal data collected through the 207pub.club platform. As data controller, 207 pub determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Data Privacy Act of 2012 (Republic Act 10173) and its implementing rules and regulations.

207 pub operates under the regulatory oversight of the Philippine Amusement and Gaming Corporation (PAGCOR). Certain data processing activities are carried out in compliance with PAGCOR's data governance requirements, which may impose additional obligations on how player data is collected, stored, and reported.

2. Personal Data We Collect

207 pub collects the following categories of personal data from registered players and platform visitors:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification number (e.g., Philippine National ID, passport, driver's licence, SSS/GSIS number).
• Contact Data: Email address, mobile phone number, and residential address (including barangay, city/municipality, province, and postal code).
• Account Data: Username, encrypted password, account registration date, account status, and account preferences.
• Financial Data: GCash account number, PayMaya account number, bank account details (account name, account number, bank name), deposit history, withdrawal history, and transaction records. Full payment card numbers are never stored by 207 pub.
• Gaming Data: Betting history, game session logs, wagering amounts, win/loss records, bonus usage history, and responsible gaming tool settings.
• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and session timestamps.
• Communications Data: Records of your communications with 207 pub support, including live chat transcripts and email correspondence.
• Usage Data: Pages visited, features accessed, time spent on the platform, and navigation patterns within the 207 pub interface.

3. How We Collect Your Data

207 pub collects personal data through the following means:

• Direct Collection: Data you provide when registering an account, completing identity verification, making a deposit or withdrawal, contacting support, or updating your account profile.
• Automated Collection: Technical and usage data collected automatically when you access the platform, including through cookies, server logs, and analytics tools operated by 207 pub.
• Third-Party Sources: Identity verification data from regulated KYC (Know Your Customer) service providers; fraud prevention data from anti-money laundering screening services; and payment confirmation data from GCash, PayMaya, and partner banks.
• Regulatory Sources: Self-exclusion status and related data from PAGCOR's centralized player protection registry, where applicable.

4. Purpose of Processing

207 pub processes your personal data for the following purposes:

• To create, verify, and manage your 207 pub player account.
• To process deposits, withdrawals, and all financial transactions associated with your account.
• To verify your identity and age (21+) in compliance with PAGCOR requirements and Philippine anti-money laundering laws.
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities.
• To provide customer support and resolve complaints or disputes.
• To administer bonuses, promotions, and loyalty programs in accordance with their applicable terms.
• To operate and improve the 207 pub platform, including game performance optimization and user experience enhancements.
• To send you transactional communications related to your account, including deposit confirmations, withdrawal notifications, and security alerts.
• To comply with legal and regulatory obligations, including reporting requirements imposed by PAGCOR and the Anti-Money Laundering Council (AMLC).
• To enforce the 207 pub Terms and Conditions and protect the rights and interests of the platform and its players.

5. Legal Basis for Processing

207 pub processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform the contract between you and 207 pub, including account management, payment processing, and game operation.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate Interests: Processing carried out for the legitimate interests of 207 pub, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including the sending of promotional communications where you have opted in to receive them.

6. Data Sharing and Disclosure

207 pub does not sell, rent, or trade your personal data to any third party for marketing or commercial purposes. Your data may be shared with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, and partner banks, to the extent necessary to process your deposits and withdrawals.
• Identity Verification Providers: Regulated KYC and age verification service providers engaged by 207 pub to fulfill its player verification obligations.
• Fraud and AML Screening Services: Third-party providers used to screen transactions and player activity for fraud and money laundering indicators.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law or regulatory directive.
• Law Enforcement Agencies: Philippine law enforcement authorities, where disclosure is required in connection with a criminal investigation or court order.
• Professional Advisers: Legal counsel, auditors, and compliance consultants engaged by 207 pub, subject to professional confidentiality obligations.

All third-party service providers engaged by 207 pub are required to process personal data only in accordance with 207 pub's instructions and to implement appropriate technical and organizational security measures.

7. Data Retention

207 pub retains personal data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and Identity Data: Retained for a minimum of five (5) years from the date of account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act of 2001 (as amended).
• Gaming and Betting History: Retained for a minimum of three (3) years from the date of each gaming session.
• Support Communications: Retained for two (2) years from the date of the last communication in a support thread.
• Technical and Usage Logs: Retained for twelve (12) months from the date of collection, unless a longer period is required for security investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 207 pub's data disposal procedures. Anonymized data may be retained indefinitely for statistical and analytical purposes.

8. Cookies and Tracking Technologies

207 pub uses the following categories of cookies and similar technologies on the platform:

• Strictly Necessary Cookies: Essential for the operation of the platform, including session management, authentication, and security. These cookies cannot be disabled without affecting core platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalized experience.
• Analytics Cookies: Used by 207 pub's internal analytics tools to understand how players use the platform, identify performance issues, and improve the user experience. These cookies collect aggregated, anonymized data.

207 pub does not use third-party advertising or retargeting cookies. You can manage or disable non-essential cookies through your browser settings at any time. Note that disabling functional cookies may affect your platform experience. For detailed information on the specific cookies used, please contact the 207 pub Data Privacy Officer.

9. Security Measures

207 pub implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• AES-256 encryption for all personal data stored at rest.
• TLS 1.3 encryption for all data transmitted between your device and the 207 pub platform.
• Multi-factor authentication options for player accounts.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• 24/7 security monitoring and automated intrusion detection systems.
• Regular staff training on data protection and information security obligations.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012 (Republic Act 10173), you have the following rights with respect to your personal data held by 207 pub:

• Right to be Informed: The right to be informed of how your personal data is collected, used, and processed — which is the primary purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data that 207 pub holds about you, together with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by 207 pub.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 207 pub's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data where such processing is based on legitimate interests, including the right to opt out of promotional communications at any time.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that 207 pub has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact the 207 pub Data Privacy Officer using the contact details provided in Section 14 of this Policy. 207 pub will respond to all data privacy requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11. Children's Privacy

The 207 pub platform is strictly intended for adults aged 21 years and above. 207 pub does not knowingly collect personal data from individuals under the age of 21. If 207 pub becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be suspended pending investigation.

If you are a parent or guardian and believe that your child has registered on the 207 pub platform, please contact our support team immediately so that we can take appropriate action.

12. International Data Transfers

207 pub primarily stores and processes personal data within the Philippines. Where it is necessary to transfer personal data to service providers located outside the Philippines — for example, in connection with cloud infrastructure or identity verification services — 207 pub ensures that such transfers are carried out in compliance with the Data Privacy Act of 2012 and NPC guidelines on cross-border data transfers.

All international data transfers are subject to appropriate safeguards, including contractual data processing agreements that require recipient organizations to maintain data protection standards equivalent to those required under Philippine law.

13. Updates to This Privacy Policy

207 pub reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes will be communicated to registered players via the email address associated with their account and/or via a prominent notice on the platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the 207 pub platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically.

14. Contact and Data Privacy Officer

207 pub has appointed a Data Privacy Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the 207 pub DPO:

• Email: [email protected] (plain text — not a clickable link)
• General Support: [email protected] (plain text — not a clickable link)
• Response Time: Within 15 business days of receipt of your request.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with 207 pub's response to your data privacy concern.