77phl Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how 77phl ("the Company," "we," "us," or "our") collects, uses, stores, and protects the personal information of individuals ("you," "your," or "Player") who access or use the 77phl online gaming platform available at https://77phl.net (the "Platform").

This Policy applies to all personal data processed by 77phl in connection with your use of the Platform, including data collected during account registration, identity verification, gameplay, financial transactions, customer support interactions, and marketing communications.

By registering an account on the Platform or otherwise providing your personal data to 77phl, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy.

2. Data Controller Information

77phl acts as the data controller in respect of the personal data it collects and processes in connection with the Platform. As data controller, 77phl determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

If you have any questions or concerns about how your personal data is handled, you may contact our Data Protection Officer (DPO) using the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

77phl collects the following categories of personal data:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification number (e.g., Philippine National ID, passport, driver's licence).
• Contact Data: Email address, mobile phone number, and residential address (including city, province, and postal code).
• Financial Data: Bank account details, e-wallet account information (GCash, PayMaya), transaction history, deposit and withdrawal records.
• Account Data: Username, encrypted password, account preferences, gaming history, bonus usage, and session logs.
• Technical Data: IP address, device type, operating system, browser type and version, time zone, and other technical identifiers collected automatically when you access the Platform.
• Usage Data: Information about how you use the Platform, including pages visited, games played, time spent, and clickstream data.
• Communications Data: Records of your communications with 77phl customer support, including live chat transcripts, emails, and support ticket history.
• Marketing Preferences: Your preferences regarding receiving marketing communications from 77phl.

We do not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required for responsible gaming purposes (e.g., self-exclusion requests).

4. How We Collect Your Data

77phl collects personal data through the following means:

• Direct Interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Technologies: Data collected automatically through cookies, web beacons, pixel tags, and similar tracking technologies when you access the Platform.
• Third-Party Sources: Data received from identity verification providers, payment processors, fraud prevention services, and analytics providers, where permitted by law.
• Publicly Available Sources: In limited circumstances, data from publicly available sources such as government databases, where necessary for identity verification or fraud prevention.

5. Legal Basis for Processing

77phl processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing necessary to perform our contract with you, including operating your account, processing transactions, and providing gaming services.
• Legal Obligation: Processing necessary to comply with applicable laws and regulations, including anti-money laundering requirements, KYC obligations, and tax reporting.
• Legitimate Interests: Processing necessary for our legitimate business interests, including fraud prevention, platform security, and improving our services, where such interests are not overridden by your rights.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, particularly in relation to marketing communications and non-essential cookies.

6. How We Use Your Personal Data

77phl uses your personal data for the following purposes:

• To create, manage, and maintain your 77phl account.
• To verify your identity and age in compliance with KYC requirements and Philippine law (21+ age restriction).
• To process deposits, withdrawals, and other financial transactions.
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities.
• To provide customer support and respond to your enquiries.
• To send you transactional communications, including account notifications, deposit confirmations, and security alerts.
• To send you marketing communications about 77phl promotions and offers, where you have consented to receive such communications.
• To personalise your gaming experience and recommend games or promotions relevant to your interests.
• To monitor and analyse Platform usage for the purpose of improving our services.
• To comply with our responsible gaming obligations, including monitoring for signs of problem gambling.
• To comply with applicable laws, regulations, and court orders.

7. Sharing Your Personal Data

77phl does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your financial transactions.
• Identity Verification Providers: Third-party KYC and age verification service providers engaged to verify your identity and age.
• IT and Security Providers: Cloud hosting, cybersecurity, and fraud prevention service providers who process data on our behalf under strict data processing agreements.
• Regulatory Authorities: Government agencies, law enforcement bodies, and regulatory authorities, where required by law or court order, including the National Privacy Commission (NPC) and relevant anti-money laundering authorities.
• Professional Advisers: Lawyers, auditors, and other professional advisers, where necessary for the conduct of our business.

All third parties with whom we share personal data are required to maintain appropriate security measures and to process your data only for the specified purposes and in accordance with our instructions.

8. Cookies and Tracking Technologies

8.1 77phl uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that allow us to recognise you, remember your preferences, and analyse how the Platform is used.

8.2 We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled and do not require your consent.
• Functional Cookies: Remember your preferences such as language settings and login status to improve your experience.
• Analytics Cookies: Collect anonymised data about how you use the Platform to help us improve performance and usability.
• Marketing Cookies: Used to deliver relevant promotions and track the effectiveness of our marketing campaigns. These are only set with your consent.

8.3 You may manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. For more information on managing cookies, refer to your browser's help documentation.

9. Data Retention

9.1 77phl retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and our legitimate business interests.

9.2 Specifically, we retain:

• Account and Identity Data: For the duration of your account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering regulations.
• Financial Transaction Records: For a minimum of five (5) years from the date of the transaction, as required by Philippine law.
• Customer Support Records: For up to three (3) years from the date of the interaction.
• Marketing Preferences: Until you withdraw your consent or request deletion.
• Technical and Usage Data: For up to twenty-four (24) months from collection, unless required for longer retention by law.

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

10. Security Measures

77phl 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:

• SSL/TLS encryption for all data transmitted between your device and the Platform.
• AES-256 encryption for sensitive data stored on our servers.
• Multi-factor authentication options for player accounts.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Strict access controls limiting employee access to personal data on a need-to-know basis.
• Comprehensive staff training on data protection and information security.
• An incident response plan for managing and reporting data breaches in accordance with the Data Privacy Act of 2012.

While 77phl takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately of any suspected unauthorised access to your account.

11. Your Rights Under Philippine Law

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 77phl:

• Right to be Informed: The right to be informed of how your personal data is collected, used, and stored.
• Right of Access: The right to request a copy of the personal data we hold about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to our legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• 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 your data protection rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 15. We will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.

12. Children's Privacy

The 77phl Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact our support team immediately.

13. International Data Transfers

In certain circumstances, your personal data may be transferred to and processed in countries outside the Philippines, for example where our third-party service providers operate internationally. Where such transfers occur, 77phl ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to provide a level of data protection equivalent to that required under Philippine law. By using the Platform, you consent to such transfers where necessary for the provision of our services.

14. Changes to This Privacy Policy

77phl reserves the right to update or amend this Privacy Policy at any time. Any material changes will be communicated to registered players via email or a prominent notice on the Platform prior to the changes taking effect. The "Last Updated" date at the top of this Policy will be revised accordingly. Your continued use of the Platform following the effective date of any amendment constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically to stay informed about how we protect your information.

15. Contact and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact the 77phl Data Protection Officer:

• Email: [email protected]
• Subject Line: Data Privacy Request – [Your Full Name]
• Live Chat: Available 24/7 via your account dashboard
• Response Time: We aim to acknowledge all data privacy requests within 72 hours and resolve them within 30 days

Our Data Protection Officer is registered with the National Privacy Commission of the Philippines and is responsible for overseeing 77phl's compliance with the Data Privacy Act of 2012 and this Policy.