777pn Privacy Policy – How We Handle Your Personal Data

This Privacy Policy describes how 777pn ("we," "us," or "our") collects, processes, stores, shares, and protects the personal data of individuals who register for, access, or use the 777pn online casino and sports betting platform at 777pn.app (the "Platform").

This policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission (NPC) of the Philippines. Where applicable, this policy also reflects the principles of the General Data Protection Regulation (GDPR) in respect of European data subjects who may access the Platform.

By registering for a 777pn account or using any part of the Platform, you acknowledge that you have read, understood, and consent to the collection and processing of your personal data as described in this policy. If you do not consent to this policy, you must not use the 777pn Platform.

For the purposes of RA 10173 and its Implementing Rules and Regulations, 777pn is the Personal Information Controller (PIC) responsible for the personal data processed through the Platform. As PIC, 777pn determines the purposes and means of processing your personal data and is accountable for its protection.

777pn has appointed a Data Protection Officer (DPO) who oversees the Platform's compliance with Philippine data privacy laws and serves as the primary point of contact for data subject rights requests and privacy enquiries. Contact details for the DPO are set out in Section 15 of this policy.

777pn collects the following categories of personal data, depending on how you interact with the Platform:

Identity & Contact Data

• Full legal name as it appears on your government-issued ID
• Date of birth (to verify you are 21 years of age or above)
• Philippine mobile number (primary account identifier)
• Email address (if provided during registration or KYC)
• Residential address in the Philippines
• Nationality

Identity Verification (KYC) Documents

• Copy of a valid Philippine government-issued photo ID (e.g., PhilSys National ID, UMID, driver's license, passport, SSS/GSIS ID, PRC ID, voter's ID)
• Proof of residential address (e.g., utility bill, barangay certificate, bank statement)
• Proof of payment method ownership (e.g., screenshot of GCash account showing your name and mobile number)
• Source of funds declaration where required by AML obligations

Financial Data

• GCash account details (mobile number and registered name)
• Maya account details where applicable
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks) where used for transactions
• Transaction history: deposits, withdrawals, bonus credits, and adjustments

Gaming & Activity Data

• Game session logs including game titles played, bet amounts, winnings, and session duration
• Login history including timestamps and approximate location
• Bonus and promotional claims and wagering activity
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)
• Support and live chat interaction records

Technical Data

• IP address
• Device type, operating system, and browser type
• Mobile network information
• Cookies and session tokens (see Section 8)
• Page interaction data and navigation patterns

777pn collects your personal data through the following channels and methods:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, respond to surveys, or participate in promotions.
• Automatically — when you use the Platform, we automatically collect technical data including your IP address, device information, session data, and in-game activity through cookies, server logs, and analytics tools.
• From third-party payment processors — GCash (Globe Fintech Innovations), Maya (PayMaya Philippines), and participating Philippine banks provide us with transaction confirmation data necessary to credit your account and process withdrawals.
• From identity verification service providers — third-party KYC and AML screening services may share results of document verification, sanctions screening, and politically exposed person (PEP) checks with 777pn as part of our regulatory compliance obligations.
• From game providers — JILI Games, Pragmatic Play, and other certified game providers may share game session and RNG audit data with 777pn for dispute resolution and fair play verification purposes.

Under the Data Privacy Act of 2012, 777pn processes your personal data on the following legal bases:

• Consent — you provide explicit consent by accepting this Privacy Policy and the Terms & Conditions at registration. Where consent is the legal basis, you may withdraw it at any time (subject to legal retention obligations) by contacting our DPO.
• Contractual necessity — processing your registration data, payment information, and gaming activity data is necessary for 777pn to perform its contractual obligations to you as a Platform user.
• Legal obligation — certain processing activities are required by Philippine law, including KYC verification under BSP regulations, AML record-keeping under RA 9160 (Anti-Money Laundering Act), age verification under applicable gaming regulations, and tax reporting obligations.
• Legitimate interests — 777pn processes certain technical and activity data on the basis of legitimate interests, including fraud prevention, platform security, service improvement, and responsible gaming monitoring, provided these interests are not overridden by your data protection rights.

777pn uses your personal data for the following specific purposes:

• Account management — creating, maintaining, and administering your 777pn account, including identity verification and authentication.
• Transaction processing — processing deposits and withdrawals via GCash, Maya, QR Ph, and Philippine bank transfers; reconciling account balances; and maintaining transaction records.
• Regulatory compliance — fulfilling KYC obligations, conducting AML and sanctions screening, reporting to PAGCOR and other regulatory bodies as required, and cooperating with law enforcement agencies presenting lawful process.
• Customer support — responding to your enquiries, resolving disputes, investigating complaints, and providing technical assistance.
• Responsible gaming — monitoring gaming patterns to identify potential problem gambling behaviour, administering self-exclusion and deposit limit requests, and sending responsible gaming communications where appropriate.
• Fraud prevention and security — detecting, investigating, and preventing fraudulent transactions, bonus abuse, money laundering, and other prohibited conduct; maintaining platform security; and protecting the integrity of the gaming environment.
• Service improvement — analysing aggregated, anonymised usage data to improve platform performance, game recommendations, user interface design, and overall player experience.
• Marketing and promotions — sending you promotional offers, bonus notifications, and event announcements, where you have not opted out of marketing communications. You may opt out at any time by contacting support.

777pn does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your personal data only in the following circumstances and with the following categories of recipients:

• Payment processors — GCash (Globe Fintech Innovations Inc.), Maya (PayMaya Philippines Inc.), GrabPay, and participating Philippine banks receive the minimum data necessary to process your transactions. All payment processors are bound by their own privacy policies and Philippine BSP regulations.
• KYC and AML service providers — third-party identity verification and sanctions screening providers process your identity documents and personal data on behalf of 777pn to fulfil regulatory KYC and AML obligations. These providers operate as Personal Information Processors (PIPs) under Data Processing Agreements.
• Game providers — JILI Games, Pragmatic Play, PG Soft, Evolution Gaming, and other licensed game developers receive session data necessary for game operation, RNG certification, and dispute resolution. Game providers do not receive your full personal profile.
• Platform service providers — hosting, cloud infrastructure, cybersecurity, customer support software, and analytics providers who process data on 777pn's behalf under strict Data Processing Agreements and confidentiality obligations.
• Regulatory and law enforcement authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), or any other Philippine government authority presenting a lawful request, court order, or regulatory direction. 777pn complies with all lawful disclosures required by Philippine law.
• Business transfers — in the event that 777pn undergoes a merger, acquisition, or sale of all or part of its business, your personal data may be transferred to the successor entity, subject to equivalent data protection obligations.

All third parties with whom 777pn shares personal data are contractually required to process that data in accordance with RA 10173 and applicable Philippine data privacy regulations.

777pn uses cookies and similar tracking technologies on the Platform for the following purposes:

• Essential cookies — required for the Platform to function, including session authentication tokens that keep you logged in, security cookies that prevent CSRF attacks, and load-balancing cookies. These cannot be disabled without impairing Platform functionality.
• Functional cookies — remember your preferences such as language settings, display preferences, and the "Remember Me" login option.
• Analytics cookies — collect anonymised data about how players use the Platform, which pages are most visited, how long sessions last, and where users encounter difficulties. This data is used exclusively to improve Platform performance and user experience.
• Security and fraud prevention cookies — detect suspicious behaviour, identify repeated failed login attempts, and flag unusual transaction patterns that may indicate fraudulent activity.

777pn does not use third-party advertising or behavioural tracking cookies that share your data with external advertisers. You may manage cookie preferences through your browser settings; however, disabling essential cookies may prevent you from accessing certain Platform features.

777pn implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, destruction, or accidental loss. Our security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and 777pn servers.
• AES-256 encryption for personal data and financial records stored at rest.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Role-based access controls limiting data access to authorised personnel on a strict need-to-know basis.
• Regular penetration testing and vulnerability assessments by independent cybersecurity professionals.
• Automated anomaly detection systems monitoring for unusual access patterns or data exfiltration attempts.
• Physical security controls for data centre infrastructure.
• Employee data privacy training and confidentiality obligations.

777pn retains your personal data for the periods set out below, after which it is securely deleted or anonymised:

• Account and identity data — retained for the duration of your account plus 5 years following account closure, in compliance with AML record-keeping requirements under RA 9160.
• KYC documents — retained for 5 years from the date of the last transaction on your account, as required by AMLC regulations.
• Financial transaction records — retained for 5 years from the date of each transaction, for AML compliance and tax reporting purposes.
• Game session logs — retained for 2 years from the date of each session, for dispute resolution and responsible gaming monitoring purposes.
• Support and chat records — retained for 2 years from the date of the interaction.
• Marketing consent records — retained until you withdraw consent plus 1 year, for accountability purposes.
• Technical and log data — retained for 12 months from collection, for security monitoring and fraud prevention purposes.

Where a legal dispute, regulatory investigation, or law enforcement matter is ongoing, 777pn may retain relevant personal data beyond the standard retention periods until the matter is fully resolved.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights in respect of your personal data held by 777pn:

To exercise any of the above rights, please contact 777pn's Data Protection Officer using the contact details provided in Section 15. We will respond to your request within 15 business days of receipt. Identity verification will be required before your request is processed to protect against unauthorised access to your data.

If you believe that 777pn has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.

The 777pn Platform is strictly intended for persons aged 21 years and above, in accordance with Philippine regulations governing casino-style gambling. 777pn does not knowingly collect personal data from individuals under the age of 21.

Where 777pn discovers that personal data has been collected from a person under 21 years of age, such data will be deleted immediately and the associated account will be permanently closed. If you are a parent or guardian and believe that your minor child has provided personal data to 777pn, please contact our DPO immediately using the contact details in Section 15.

The 777pn Platform may contain references to third-party services such as GCash, Maya, and partner game providers. These third-party services operate under their own privacy policies, which 777pn does not control. We encourage you to review the privacy policies of any third-party service you interact with in connection with your 777pn account.

777pn is not responsible for the data collection, processing, or privacy practices of third-party services. The inclusion of a third-party payment processor or game provider on the Platform does not constitute an endorsement of their privacy practices.

777pn reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, NPC guidance, platform operations, or data processing activities. Material changes — those that significantly affect how your data is processed or your rights as a data subject — will be communicated to you via a notice on the Platform and/or by SMS to your registered mobile number, with at least 14 days' notice before the changes take effect.

Non-material updates such as corrections to typographical errors, clarification of existing provisions, or minor administrative changes may be published without advance notice and will take effect immediately upon publication.

The "Last Reviewed" date at the top of this policy indicates when it was most recently updated. We encourage you to review this policy periodically to stay informed of how 777pn handles your personal data.

Your continued use of the Platform following the effective date of any amended Privacy Policy constitutes your acceptance of the updated policy. If you do not accept the changes, you must cease using the Platform and may request account closure pursuant to the Terms & Conditions.

For any questions, concerns, or requests related to this Privacy Policy or the processing of your personal data, please contact the 777pn Data Protection Officer (DPO) or general support team through the following channels:

• Live Chat Support: Available 24/7 via the chat widget on the 777pn Platform — the fastest channel for most enquiries.
• Email: [email protected] — for written data privacy requests. Please allow up to 5 business days for an initial acknowledgement and up to 15 business days for full resolution.

When submitting a data subject rights request, please provide your registered 777pn mobile number, the nature of your request, and any relevant details. Identity verification will be required before any access, correction, deletion, or portability request is processed.