Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 77games ("77games", "we", "us", "our") collects, uses, stores, discloses, and protects the personal information of users ("you", "User", "Player") who access or use the 77games platform at 77games.club and all associated services (collectively, the "Service").

77games is committed to protecting your personal data in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). We also comply with applicable PAGCOR data governance requirements as they relate to online gaming operators.

By registering an account on 77games or otherwise using the Service, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the 77games platform.

            Our Commitment: 77games does not sell your personal data to third parties. We collect only what is necessary to operate the Service, comply with our legal obligations, and provide you with a safe and enjoyable gaming experience.
          

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, 77games acts as the Personal Information Controller (PIC) with respect to the personal data of its registered users and website visitors. As PIC, 77games determines the purposes and means of processing your personal data.

Where 77games engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, and cloud infrastructure providers — those parties act as Personal Information Processors (PIPs) and are bound by data processing agreements that require them to process your data only on 77games's instructions and in compliance with applicable law.

For all privacy-related inquiries, requests, and complaints, please contact our Data Protection Officer (DPO) using the details provided in Section 14 of this Policy.

3. Personal Data We Collect

77games collects the following categories of personal data from users of the Service:

3.1 Identity & Registration Data

Full legal name as it appears on your government-issued identification document
Date of birth (used to verify that you are at least 21 years of age)
Gender (optional, for personalization purposes)
Nationality and country of residence
Government-issued identification number (e.g., PhilSys ID, passport, driver's license)

3.2 Contact Data

Email address (primary communication channel)
Mobile phone number (used for account verification and security alerts)
Residential address (required for KYC verification and regulatory compliance)

3.3 Financial Data

GCash or PayMaya account number (for deposit and withdrawal processing)
Bank account details (account name, account number, bank name) for bank transfer transactions
Debit card details (card number, expiry date — stored in tokenized form only; full card data is never stored on 77games servers)
Transaction history, including deposit amounts, withdrawal amounts, dates, and payment methods

3.4 Gaming Activity Data

Game session logs, including games played, wagers placed, outcomes, and session duration
Bonus and promotion usage history
Responsible gaming settings, including deposit limits, session limits, and self-exclusion records
Customer support interaction records

3.5 Technical & Device Data

IP address and approximate geolocation derived from IP
Device type, operating system, and browser type and version
Unique device identifiers
Log data, including access times, pages viewed, and referring URLs
Cookie identifiers and similar tracking technology data (see Section 9)

            Sensitive Personal Information: Government-issued identification numbers and financial account details are classified as sensitive personal information under RA 10173. 77games processes this data only to the extent strictly necessary for identity verification, payment processing, and regulatory compliance, and applies enhanced security controls to its storage and handling.
          

4. How We Collect Your Data

77games collects personal data through the following means:

Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions.
Automatically — through cookies, web beacons, server logs, and similar technologies when you access and use the 77games platform (see Section 9).
From third-party identity verification providers — when we verify your identity and age using government database cross-referencing services, as required by PAGCOR regulations.
From payment processors — transaction confirmation data and fraud screening results from GCash, PayMaya, and banking partners.
From regulatory databases — self-exclusion lists and sanctions screening databases maintained by PAGCOR and other competent authorities.

5. Purpose & Legal Basis for Processing

The following table sets out the purposes for which 77games processes your personal data and the corresponding legal basis under RA 10173:

Purpose	Data Categories Used	Legal Basis
Account registration and management	Identity, Contact	Contract performance; Consent
Age and identity verification (KYC)	Identity, Government ID	Legal obligation (PAGCOR / AML regulations)
Processing deposits and withdrawals	Financial, Identity	Contract performance
Anti-money laundering (AML) compliance	Identity, Financial, Gaming Activity	Legal obligation (AMLA, RA 9160)
Fraud prevention and security	Technical, Financial, Identity	Legitimate interest; Legal obligation
Responsible gaming monitoring	Gaming Activity, Identity	Legal obligation (PAGCOR); Legitimate interest
Customer support	Identity, Contact, Gaming Activity	Contract performance; Legitimate interest
Marketing and promotional communications	Contact, Gaming Activity	Consent (opt-in only)
Platform analytics and improvement	Technical, Gaming Activity	Legitimate interest
Legal and regulatory reporting	Identity, Financial, Gaming Activity	Legal obligation

Where 77games relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. To withdraw consent for marketing communications, use the unsubscribe link in any marketing email or contact our DPO directly.

6. Sharing Your Personal Data

77games does not sell, rent, or trade your personal data to any third party for their own marketing 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:

6.1 Regulatory and Law Enforcement Authorities

77games is required by Philippine law to share certain personal data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent government authorities upon lawful request or as required by applicable regulations. This includes mandatory reporting of suspicious transactions under the Anti-Money Laundering Act (RA 9160, as amended).

6.2 Payment Service Providers

To process your deposits and withdrawals, 77games shares necessary financial and identity data with our payment partners, including GCash, PayMaya, and accredited banking institutions (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank). These providers are bound by their own privacy policies and applicable financial regulations.

6.3 Identity Verification Providers

To fulfill our KYC obligations under PAGCOR regulations, 77games may share identity documents and personal details with accredited third-party identity verification service providers. These providers process your data solely for verification purposes and are contractually prohibited from using it for any other purpose.

6.4 Technology and Infrastructure Providers

77games uses cloud hosting, cybersecurity, and analytics service providers to operate and maintain the platform. These providers act as Personal Information Processors and are bound by data processing agreements that restrict their use of your data to the provision of services to 77games.

6.5 Game Content Providers

Where you play games supplied by third-party game studios integrated into the 77games platform, limited technical data (such as session tokens and game results) may be shared with those studios for the purpose of game delivery and integrity verification. No directly identifiable personal data is shared with game studios beyond what is technically necessary.

            No Data Sales: 77games strictly prohibits the sale or commercial transfer of user personal data to any third party for advertising, profiling, or any other commercial purpose not directly related to the provision of the 77games Service.
          

7. Data Retention

77games retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

Data Category	Retention Period	Basis
Account registration and KYC data	5 years after account closure	PAGCOR regulations; AML obligations
Financial transaction records	5 years from transaction date	AMLA (RA 9160, as amended)
Gaming activity logs	3 years after account closure	PAGCOR regulations; Dispute resolution
Customer support records	2 years after resolution	Legitimate interest; Legal claims
Marketing consent records	Until consent withdrawn + 1 year	RA 10173 accountability requirement
Technical and device logs	12 months from collection	Security and fraud prevention
Self-exclusion records	Duration of exclusion + 5 years	PAGCOR responsible gaming requirements

Upon expiry of the applicable retention period, 77games will securely delete or anonymize your personal data in accordance with our data disposal procedures. Anonymized data that can no longer identify you may be retained indefinitely for statistical and analytical purposes.

8. Security Measures

77games implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

Encryption in transit: All data transmitted between your device and the 77games platform is encrypted using TLS 1.2 or higher (256-bit SSL).
Encryption at rest: Sensitive personal data stored on 77games servers is encrypted using AES-256 encryption.
Access controls: Access to personal data is restricted to authorized 77games personnel on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication.
Payment data tokenization: Debit card and payment account details are tokenized — 77games never stores raw card numbers on its servers.
Intrusion detection: 77games employs real-time intrusion detection and prevention systems to monitor for unauthorized access attempts.
Regular security audits: The platform undergoes periodic third-party security assessments and penetration testing.
Staff training: All 77games personnel with access to personal data receive regular data privacy and security training.

            Data Breach Notification: In the event of a personal data breach that is likely to result in serious harm to affected individuals, 77games will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected users without undue delay, in accordance with NPC Circular 16-03.
          

While 77games 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 77games immediately if you suspect unauthorized access to your account.

9. Cookies & Tracking Technologies

77games uses cookies and similar tracking technologies to operate the platform, remember your preferences, analyze usage patterns, and support security functions. The following types of cookies are used:

Cookie Type	Purpose	Duration
Strictly Necessary	Session management, authentication, security (CSRF protection). Required for the platform to function. Cannot be disabled.	Session / up to 24 hours
Functional	Remembering your language preference, game settings, and responsible gaming configurations.	Up to 12 months
Analytics	Understanding how users navigate the platform to improve performance and user experience. Data is aggregated and anonymized where possible.	Up to 12 months
Security & Fraud Prevention	Device fingerprinting and behavioral analysis to detect fraudulent activity and protect your account.	Up to 6 months

You can manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair the functionality of the 77games platform and may prevent you from logging in or accessing certain features. Disabling analytics or functional cookies will not affect your ability to use the core gaming service.

10. 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 77games. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

📋

Right to Be Informed Know what personal data we collect, why we collect it, and how it is used — as set out in this Policy.

🔍

Right to Access Request a copy of the personal data we hold about you, including information on how it has been processed.

✏️

Right to Rectification Request correction of inaccurate or incomplete personal data we hold about you.

🗑️

Right to Erasure Request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to legal retention obligations.

🚫

Right to Object Object to the processing of your personal data for direct marketing or where processing is based on legitimate interest.

📦

Right to Data Portability Receive your personal data in a structured, commonly used, machine-readable format where technically feasible.

⚠️

Right to Damages Claim compensation for damages sustained due to inaccurate, incomplete, outdated, or unlawfully obtained personal data.

📣

Right to Complain Lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

77games will respond to all verified data privacy rights requests within fifteen (15) business days of receipt. We may request proof of identity before processing your request to protect against unauthorized access to your data.

            Note on Retention Obligations: Certain rights, such as the right to erasure, may be limited where 77games is required by law to retain your data — for example, under PAGCOR regulations or the Anti-Money Laundering Act. In such cases, we will inform you of the applicable retention obligation.
          

11. Minors and Age Restriction

The 77games platform is strictly intended for persons aged twenty-one (21) years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. 77games does not knowingly collect personal data from individuals under the age of 21.

If 77games becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the personal data in question, and report the matter to the appropriate regulatory authorities as required by law.

If you are a parent or guardian and believe that your child has registered an account on 77games, please contact our Data Protection Officer immediately using the details in Section 14 so that we can take prompt action.

            Underage Gambling: Gambling by persons under 21 years of age is illegal in the Philippines. 77games enforces strict age verification at registration and at the point of withdrawal. Any account found to belong to a person under 21 will be immediately closed and all funds frozen pending regulatory review.
          

12. Cross-Border Data Transfers

In the course of operating the 77games platform, your personal data may be transferred to and processed in countries other than the Philippines — for example, where our cloud infrastructure providers or game content suppliers maintain data centers. Such transfers may occur to countries that have different data protection laws from those in the Philippines.

Where personal data is transferred outside the Philippines, 77games ensures that appropriate safeguards are in place to protect your data, including:

Contractual clauses that require the recipient to protect your personal data to a standard equivalent to that required under RA 10173.
Transfers only to countries or organizations that have been assessed as providing an adequate level of data protection.
Compliance with NPC guidelines on cross-border data transfers.

By using the 77games platform, you consent to the transfer of your personal data to other countries as described in this Section, subject to the safeguards outlined above.

13. Changes to This Privacy Policy

77games 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 material changes are made, we will notify registered users by email or by posting a prominent notice on the 77games platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision. We encourage you to review this Policy periodically. Your continued use of the 77games platform after the effective date of any revised Policy constitutes your acceptance of the updated terms.

The current version of this Privacy Policy is always available at 77games.club/privacy-policy.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 77games, please contact our Data Protection Officer (DPO):

Data Protection Officer — 77games

Email: [email protected]

General Support: [email protected]

Live Chat: Available 24/7 via the 77games platform

Response Time: Within 15 business days for formal data privacy requests

If you are not satisfied with our response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.

Contents