77ph6 Privacy Policy

1 Who We Are — Data Controller

77ph6 is the data controller responsible for the personal data collected and processed through the 77ph6 Platform accessible at 77ph6.vip. 77ph6 operates under PAGCOR licensing and processes personal data in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC).

For all data privacy inquiries, the 77ph6 Data Protection Officer (DPO) may be contacted at [email protected] with the subject line DATA PRIVACY — DPO. We aim to respond to all data subject requests within fifteen (15) days of receipt, in accordance with NPC advisory guidelines.

2 Personal Data We Collect

77ph6 collects the minimum personal data necessary to operate a PAGCOR-licensed platform and comply with Philippine legal obligations. The following table sets out the categories of data collected:

77ph6 does not collect full bank account numbers, credit card numbers, or raw payment credentials. All payment processing is handled by PCI-DSS compliant third-party payment service providers.

3 How We Collect Your Data

77ph6 collects personal data through the following methods:

• Direct submission: Data you provide when registering an Account, completing KYC verification, making deposits or withdrawals, contacting support, or completing any form on the Platform;
• Automated collection: Technical data and usage data collected automatically when you access the Platform via cookies, server logs, and analytics tools;
• Third-party sources: Identity verification data received from KYC/AML service providers who cross-reference government databases; fraud risk data from payment processors; and regulatory data from PAGCOR where required;
• Payment providers: Transaction confirmation data from GCash, Maya, BPI, BDO, UnionBank, and other payment service partners used on the Platform.

4 Legal Basis for Processing

Under the Philippine Data Privacy Act, 77ph6 processes personal data on the following legal bases:

1. Contractual necessity: Processing required to create and manage your Account, process deposits and withdrawals, and deliver the Platform services you have requested;
2. Legal obligation: Processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA) as administered by the AMLC, Philippine tax obligations, and NPC requirements under RA 10173;
3. Legitimate interests: Processing for fraud prevention, security monitoring, platform integrity, and improvement of the Platform experience — where such interests are not overridden by your data protection rights;
4. Consent: Processing for direct marketing communications and analytics-based personalisation, where you have provided freely given, specific, informed consent. You may withdraw marketing consent at any time by contacting 77ph6 support.

5 How We Use Your Personal Data

77ph6 uses collected personal data for the following purposes:

• Creating, verifying, and managing your 77ph6 Account;
• Processing deposits and withdrawals to your GCash, Maya, or Philippine bank accounts;
• Conducting KYC and AML checks as required by PAGCOR and the AMLC;
• Verifying that you meet the mandatory 21+ age requirement under Philippine law;
• Detecting, investigating, and preventing fraud, cheating, multi-accounting, and other prohibited activities;
• Providing customer support via live chat and email in English and Filipino (Tagalog);
• Sending transactional communications — deposit confirmations, withdrawal notifications, OTP codes — to your registered mobile number or email;
• Administering responsible gaming tools including deposit limits, self-exclusion, and cool-off periods;
• Complying with PAGCOR regulatory reporting obligations and responding to lawful requests from Philippine government authorities;
• Analysing Platform usage patterns to improve game selection, interface performance, and user experience (anonymised or pseudonymised where possible);
• Sending promotional communications where you have opted in to marketing — you may opt out at any time.

6 Data Sharing & Third-Party Disclosure

77ph6 does not sell, rent, or trade your personal data. We share personal data only where necessary and on a need-to-know basis with the following categories of recipients:

• PAGCOR: As our regulatory authority, PAGCOR may require access to certain player and transaction data as part of its licensing oversight functions;
• Anti-Money Laundering Council (AMLC): Transaction records and identity data where required under the Anti-Money Laundering Act and its implementing rules;
• Payment service providers: GCash, Maya, BPI, BDO, UnionBank, and other processors receive only the data required to execute your specific transaction;
• KYC/Identity verification providers: Government ID data is shared with accredited Philippine identity verification service providers solely for the purpose of KYC compliance;
• Game technology providers: Certain anonymised technical and usage data is shared with game providers (e.g., live casino operators, slot software licensors) for game performance monitoring only;
• Legal and law enforcement authorities: 77ph6 will disclose personal data to competent Philippine authorities — including the NBI, PNP, and courts — where required by law, court order, or valid legal process;
• Professional advisors: Legal counsel, auditors, and compliance consultants under confidentiality obligations.

7 Data Retention

77ph6 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and KYC data: Retained for a minimum of five (5) years from the date of Account closure, as required by the AMLC under the Anti-Money Laundering Act;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction;
• Communications and support records: Retained for three (3) years from the date of the communication;
• Technical and log data: Retained for one (1) year from the date of collection, unless retained longer in connection with an active investigation or legal proceeding;
• Self-exclusion records: Retained indefinitely to ensure that self-excluded players cannot register new accounts using the same identity.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised.

8 Security Measures

77ph6 implements technical and organisational security measures appropriate to the risk profile of the personal data processed. These measures include:

• 256-bit TLS/SSL encryption for all data in transit between your device and 77ph6 servers;
• AES-256 encryption at rest for sensitive data categories including identity documents and financial data;
• Bcrypt hashing of all Account passwords — passwords are never stored in plain text;
• Two-Factor Authentication (2FA) via OTP available to all Account holders and enforced for sensitive operations;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Real-time login anomaly detection triggering automatic Account holds and player notification for suspicious access;
• Regular third-party security audits and penetration testing of the Platform;
• Segregated storage of KYC documents with access logs and access time limitations.

9 Cookies & Tracking Technologies

The 77ph6 Platform uses cookies and similar tracking technologies to maintain session state, analyse usage patterns, and improve Platform performance. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function — session authentication, security tokens, and load balancing. These cannot be disabled without impairing Platform functionality;
• Functional cookies: Remember your language preferences, responsible gaming settings, and last-played games;
• Analytics cookies: Collect anonymised data on page visits, click paths, and session duration to help 77ph6 improve Platform design. No personally identifiable information is included in analytics data;
• Security cookies: Used to detect bot activity, credential stuffing attempts, and CSRF attacks.

77ph6 does not use advertising or targeting cookies. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair or prevent Platform access.

10 Your Rights Under RA 10173

As a data subject under the Philippine Data Privacy Act, you have the following rights in relation to your personal data held by 77ph6:

To exercise any of the above rights, submit a request to [email protected] with the subject line DATA PRIVACY REQUEST. Include your registered mobile number or email for identity verification. 77ph6 will respond within fifteen (15) days.

11 Minors & Age Restriction

Parents and guardians who believe a minor has registered an Account on the Platform should contact 77ph6 DPO at [email protected] immediately for expedited resolution.

12 Cross-Border Data Transfers

Some of 77ph6's technology service providers — including cloud infrastructure, KYC verification, and game technology partners — may process personal data outside the Philippines. Where cross-border data transfers occur, 77ph6 ensures that:

• The recipient country or organisation provides an adequate level of data protection equivalent to that required by RA 10173;
• Appropriate contractual safeguards are in place, including data processing agreements aligned with NPC requirements;
• Personal data transferred cross-border is limited to the minimum necessary for the specific service purpose.

Details of specific cross-border transfers may be obtained by contacting the 77ph6 DPO.

13 Amendments to This Policy

77ph6 reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. Where changes are material, 77ph6 will notify registered Players via the mobile number or email address on file not less than seven (7) days before the revised Policy takes effect. The revised Policy will be posted on this page with an updated "Last Revised" date. Your continued use of the Platform following the effective date of any revision constitutes acceptance of the revised Policy.

14 Contact Us & Data Protection Officer

For all data privacy matters — access requests, corrections, erasure requests, complaints, or general inquiries about how 77ph6 handles your personal data — contact us as follows:

This Privacy Policy was last revised on 1 June 2026.