131 pub Privacy
Policy

📋 1. Introduction

131 pub ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all users ("you," "your," or "Player") who access and use the 131 pub online gaming platform at 131pub.org.

This Privacy Policy is issued in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Republic of the Philippines and its Implementing Rules and Regulations, as well as the guidelines issued by the National Privacy Commission (NPC). It describes how 131 pub, as the personal information controller, collects, processes, stores, shares, and protects your personal data.

By registering for a 131 pub account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Privacy Policy, please discontinue use of the Platform immediately.

This Privacy Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, which are incorporated by reference.

📂 2. Personal Data We Collect

131 pub collects personal data through various means, including directly from you during registration and account use, automatically through your use of the Platform, and from third-party service providers. The categories of personal data we collect include:

2.1 Data You Provide Directly

• Identity Data: Full legal name, date of birth, gender, nationality.
• Contact Data: Email address, mobile number, residential address (city, province, region).
• Account Data: Username, password (stored in hashed form), security questions and answers.
• Verification Data: Government-issued ID (e.g., PhilSys ID, passport, driver's licence, UMID), selfie or photo for identity verification, proof of address.
• Financial Data: GCash account number, Maya account number, bank account details (account name and number only – we do not store full card numbers), transaction history on the Platform.
• Communications Data: Records of your correspondence with 131 pub support, including live chat transcripts and email exchanges.

2.2 Data Collected Automatically

• Technical Data: IP address, browser type and version, operating system, device type and identifiers, screen resolution.
• Usage Data: Pages visited, games played, session duration, click-stream data, search queries within the Platform.
• Location Data: General geographic location derived from your IP address (country and region level only).
• Cookie Data: Data collected through cookies and similar tracking technologies as described in Section 6.

2.3 Data from Third Parties

• Identity and fraud-check data from KYC (Know Your Customer) verification service providers.
• Payment confirmation data from GCash, Maya, and banking partners (transaction reference numbers and status only).
• Age verification data from authorised verification services.

⚙️ 3. How We Use Your Personal Data

131 pub processes your personal data only for specific, legitimate purposes. The table below summarises the primary purposes for which we use your data and the corresponding legal basis for each:

131 pub will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

⚖️ 4. Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173), 131 pub relies on the following legal bases to process your personal data:

• Consent: Where you have given clear, informed, and freely given consent to the processing of your personal data for a specific purpose, such as receiving promotional emails or SMS notifications from 131 pub. You may withdraw your consent at any time by updating your communication preferences in your account settings.
• Contract Performance: Where processing is necessary for the performance of a contract to which you are a party, or to take steps at your request prior to entering into a contract – for example, creating and managing your 131 pub account, processing your deposits and withdrawals, and providing gaming services.
• Legal Obligation: Where processing is necessary for compliance with a legal obligation to which 131 pub is subject, including anti-money laundering (AML) requirements, PAGCOR regulatory obligations, and tax reporting requirements.
• Legitimate Interests: Where processing is necessary for the legitimate interests pursued by 131 pub or a third party, provided that such interests are not overridden by your fundamental rights and freedoms. This includes fraud prevention, platform security, and improving our services.

🤝 5. Data Sharing & Disclosure

131 pub does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• KYC and Identity Verification Providers: Third-party services that assist us in verifying your identity and age in compliance with regulatory requirements.
• Payment Service Providers: GCash, Maya, and banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to facilitate deposits and withdrawals. These providers receive only the minimum data necessary to process your transaction.
• Game Software Providers: Providers of the games available on the 131 pub Platform may receive anonymised or pseudonymised usage data for game performance and fairness auditing purposes.
• IT and Cloud Service Providers: Providers of hosting, data storage, and technical infrastructure services who process data on our behalf under strict data processing agreements.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities where disclosure is required by law or court order.
• Professional Advisers: Lawyers, auditors, and accountants who require access to your data in the course of providing professional services to 131 pub, subject to professional confidentiality obligations.

🍪 6. Cookies & Tracking Technologies

131 pub uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and support security functions. The types of cookies we use are:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session cookies that keep you logged in to your 131 pub account and security cookies that help detect fraudulent activity. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, preferred game categories, and display options to personalise your 131 pub experience.
• Analytics Cookies: Help us understand how players use the Platform – which pages are visited most, where players encounter difficulties, and how we can improve the overall experience. Data collected is aggregated and anonymised.
• Security Cookies: Used to detect and prevent fraudulent logins, bot activity, and other security threats to your 131 pub account.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 131 pub Platform. A cookie consent banner is displayed on your first visit to the Platform, where you can make your preferences for non-essential cookies.

🗓️ 7. Data Retention

131 pub retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account Data: Retained for the duration of your active account relationship with 131 pub, plus a minimum of five (5) years following account closure, in accordance with Philippine AML and gaming regulatory requirements.
• Transaction and Financial Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• KYC and Verification Documents: Retained for the duration of your account plus five (5) years after account closure.
• Customer Support Communications: Retained for three (3) years from the date of the last communication.
• Technical and Usage Logs: Retained for up to twelve (12) months for security and fraud prevention purposes.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years to demonstrate compliance.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymised in accordance with our data disposal procedures.

🔐 8. Data Security

131 pub implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and the 131 pub Platform is encrypted using 256-bit SSL/TLS protocols. Sensitive data at rest, including passwords and financial information, is encrypted using industry-standard algorithms.
• Access Controls: Access to personal data is restricted to authorised 131 pub personnel and service providers on a strict need-to-know basis. All staff with access to personal data undergo regular data privacy training.
• Two-Factor Authentication (2FA): 131 pub offers 2FA for player accounts to provide an additional layer of security against unauthorised access.
• Regular Security Audits: The Platform undergoes regular penetration testing and security audits by independent third-party security specialists.
• Incident Response: 131 pub maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission and affected players within the timeframes required by law.

While 131 pub takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is 100% secure. You are responsible for keeping your 131 pub login credentials confidential and for notifying us immediately if you suspect any unauthorised access to your account.

✋ 9. Your Data Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by 131 pub:

• Right to be Informed: You have the right to be informed about how your personal data is collected and processed, as set out in this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data 131 pub holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You can update most of your account information directly through your 131 pub account settings.
• Right to Erasure: You have 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 our legal retention obligations.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to 131 pub's overriding legitimate grounds.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the details provided in Section 13. We will respond to all verified requests within fifteen (15) business days in accordance with NPC guidelines.

🔞 10. Children's Privacy & Age Restriction

The 131 pub Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. 131 pub does not knowingly collect personal data from individuals under the age of 21.

As part of our registration process, all players are required to confirm that they are at least 21 years of age and to submit valid proof of age as part of our KYC verification procedures. Accounts found to belong to persons under 21 years of age will be immediately suspended and all personal data associated with such accounts will be deleted in accordance with our data retention procedures, except where retention is required by law.

If you are a parent or guardian and believe that a minor has registered on the 131 pub Platform, please contact us immediately at the details provided in Section 13 so that we can take appropriate action.

🔗 11. Third-Party Links

The 131 pub Platform may contain links to third-party websites or services, such as payment provider portals. This Privacy Policy applies solely to the 131 pub Platform and does not cover the privacy practices of any third-party websites or services.

131 pub is not responsible for the privacy practices, content, or security of any third-party websites. We encourage you to review the privacy policies of any third-party services you access through or in connection with the 131 pub Platform before providing any personal data to those services.

📝 12. Changes to This Privacy Policy

131 pub 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 we make material changes to this Privacy Policy, we will:

• Update the "Last updated" date at the top of this page.
• Display a prominent notice on the 131 pub Platform informing players of the changes.
• Where required by the National Privacy Commission or applicable law, seek fresh consent from affected players.

We encourage you to review this Privacy Policy periodically to stay informed about how 131 pub protects your personal data. Your continued use of the Platform following the posting of any amendments constitutes your acknowledgement of the revised Privacy Policy.

📧 13. Contact Us & Data Protection Officer

131 pub has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012 and the National Privacy Commission. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact us:

• Data Protection Officer: 131 pub DPO
• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the 131 pub Platform
• Response Time: We aim to acknowledge all privacy-related enquiries within 3 business days and resolve them within 15 business days.

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC can be reached through their official government channels.