Privacy Policy — 77ph6

This Privacy Policy ("Policy") describes how 77ph6 ("77ph6," "we," "our," or "us"), the operator of the online gaming platform accessible at 77ph6.app, collects, uses, stores, protects, and discloses personal data relating to registered users, visitors, and other individuals ("Data Subjects") who interact with the 77ph6 platform and its associated services.

77ph6 is a PAGCOR-registered online gaming platform operating under the laws of the Republic of the Philippines. This Policy has been drafted in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the guidelines issued by the National Privacy Commission ("NPC") of the Philippines.

By accessing 77ph6.app, registering an account, or using any of our services, you acknowledge that you have read and understood this Privacy Policy. This Policy should be read together with our Terms & Conditions, which govern the overall use of the 77ph6 platform.

For purposes of the Philippine Data Privacy Act of 2012, the personal data controller responsible for the processing of your data is:

The Data Privacy Officer (DPO) of 77ph6 is responsible for overseeing compliance with this Policy and with all applicable Philippine data protection legislation. The DPO can be contacted at the email address above for any data privacy-related queries, complaints, or requests.

77ph6 collects personal data across three main categories: data you provide directly, data generated through your use of the platform, and data obtained from third parties for identity verification purposes.

77ph6 does not collect sensitive personal information (as defined by RA 10173, such as racial origin, religious beliefs, health data, or political affiliations) except where explicitly required by PAGCOR regulations or Philippine law — for example, certain health disclosures in the context of responsible gaming self-exclusion requests.

77ph6 processes personal data for the following specific, legitimate purposes:

• Account Registration and Authentication: To create and maintain your 77ph6 account, verify your identity during login, and manage two-factor authentication.
• Know Your Customer (KYC) Compliance: To verify your age (21+ requirement) and identity as required by PAGCOR regulations and Philippine gambling law before permitting withdrawal of funds.
• Payment Processing: To process your deposits via GCash, Maya, or bank transfer, and to execute your withdrawal requests to your registered Philippine payment accounts.
• Anti-Money Laundering (AML) Compliance: To monitor transactions, generate mandatory regulatory reports, and fulfil 77ph6's obligations under Republic Act No. 9160 (Anti-Money Laundering Act) as amended.
• Fraud Prevention and Security: To detect and investigate fraud, account takeover attempts, multi-accounting, and other prohibited activities outlined in the Terms & Conditions.
• Platform Operation and Improvement: To deliver the 77ph6 gaming services, maintain platform stability, resolve technical issues, and analyse usage patterns to improve the user experience.
• Responsible Gaming: To monitor gaming behaviour for signs of problem gambling, enforce deposit limits and self-exclusion orders, and deliver responsible gaming communications.
• Customer Support: To investigate and resolve queries, complaints, and disputes submitted to the 77ph6 support team.
• Regulatory Reporting: To comply with reporting obligations to PAGCOR, the NPC, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities.
• Service Communications: To send transactional emails and SMS messages related to your account (deposit confirmations, withdrawal status, security alerts). Marketing communications are only sent with your explicit prior consent.

Under Section 12 of the Data Privacy Act of 2012, 77ph6 processes personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil the contract between you and 77ph6 (i.e., the provision of online gaming services) — including account management, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with PAGCOR licensing conditions, AMLA reporting obligations, NPC registration requirements, and other applicable Philippine laws.
• Legitimate Interests: Processing for fraud prevention, platform security, abuse detection, and internal analytics — where these interests are not overridden by your data protection rights.
• Consent: Processing for optional purposes such as marketing communications, where we have obtained your explicit prior consent. You may withdraw consent at any time by contacting [email protected] or updating your communication preferences in account settings.

77ph6 does not sell personal data. We may share your data with the following categories of third parties, strictly for the purposes described in this Policy:

• KYC and Identity Verification Providers: Accredited third-party identity verification services that assist 77ph6 in verifying government IDs and confirming player eligibility. These providers are bound by data processing agreements limiting their use of your data to KYC purposes only.
• Payment Service Providers: GCash (G-Xchange, Inc.), Maya (Voyager Innovations, Inc.), GrabPay, BPI, BDO, Metrobank, and InstaPay network providers — solely for the processing of deposits and withdrawals you initiate.
• Platform Technology Partners: Game software providers (such as Pragmatic Play, PG Soft, Jili Games) who deliver game content on the 77ph6 platform. These providers may receive session and wagering data necessary to operate their games, under contractual data protection obligations.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and any other competent Philippine government authority — where disclosure is required by law, court order, or regulatory directive.
• Fraud Prevention Networks: Industry fraud-sharing networks where participation is required by PAGCOR or where 77ph6 has a legitimate interest in preventing cross-platform fraud. Only the minimum necessary data is shared in such cases.

Where 77ph6 transfers personal data outside the Republic of the Philippines — for example, to game software providers whose servers are located abroad — such transfers are carried out in compliance with Section 21 of the Data Privacy Act of 2012 and NPC guidelines on cross-border data flows.

77ph6 ensures that cross-border transfers of personal data are subject to one of the following safeguards: contractual clauses providing adequate data protection standards; the receiving country having been recognised by the NPC as providing an adequate level of data protection; or explicit consent from the Data Subject where the transfer is necessary for the performance of a contract.

In all cases, 77ph6 maintains oversight of the processing activities of overseas data processors and retains the right to audit their compliance with applicable data protection standards.

77ph6 retains personal data for as long as is necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods driven by legal and regulatory obligations:

On expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be attributed to any individual. Where legal proceedings or regulatory investigations are ongoing at the time of scheduled deletion, data will be retained until the matter is fully resolved.

77ph6 implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, and destruction:

• Encryption in Transit: All data exchanged between your device and 77ph6 servers is encrypted using TLS 1.3 / 256-bit SSL protocols. Connections that do not meet minimum security standards are rejected.
• Encryption at Rest: Personal data stored on 77ph6 servers is encrypted using AES-256 encryption. Database backups are encrypted using the same standard.
• Password Security: Account passwords are hashed using bcrypt with a work factor calibrated to current processing capabilities. Plain-text passwords are never stored or transmitted.
• Access Controls: Access to personal data within 77ph6's systems is restricted on a strict need-to-know basis. All staff access to production data is logged, reviewed, and subject to quarterly access audits.
• Two-Factor Authentication: 77ph6 supports and encourages the use of two-factor authentication (2FA) via Philippine mobile OTP for all player accounts to prevent unauthorised access.
• Vulnerability Management: 77ph6 conducts regular security assessments, penetration testing, and code reviews to identify and remediate vulnerabilities before they can be exploited.
• Infrastructure Security: 77ph6 servers are hosted in data centres with ISO 27001-certified physical security controls, redundant network infrastructure, and 24/7 monitoring.

77ph6 uses cookies and similar tracking technologies on the 77ph6.app platform. A cookie is a small text file stored on your device by your browser when you visit a website. Cookies do not contain viruses and cannot access other files on your device.

77ph6 uses the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the operation of the 77ph6 platform. They maintain your logged-in session, store your account preferences, and enable core security features such as anti-CSRF tokens. These cookies cannot be disabled without impairing platform functionality.
• Performance and Analytics Cookies: These cookies collect anonymised data about how users interact with the 77ph6 platform — which pages are visited most, how long sessions last, and where errors occur. This data is used solely to improve the platform experience. 77ph6 does not share analytics data with third-party advertising networks.
• Functional Cookies: These cookies remember your language settings, display preferences, and responsible gaming reminder configurations, so you do not need to re-enter them every session.

77ph6 does not use third-party advertising cookies, social media tracking pixels, or cross-site behavioural profiling technologies. You may manage cookie settings through your browser at any time; however, disabling strictly necessary cookies may prevent you from accessing certain platform features.

The 77ph6 platform is strictly restricted to individuals who are 21 years of age or older, as mandated by PAGCOR regulations and applicable Philippine gambling law. 77ph6 does not knowingly collect personal data from persons under 21 years of age.

Age verification is a mandatory step in the KYC process. Any account found to be registered by a person under the age of 21 will be immediately closed, all associated data will be processed in accordance with PAGCOR's requirements for underage account records, and the matter may be referred to PAGCOR.

To exercise any of your rights under the Data Privacy Act of 2012 — including access, rectification, erasure, objection, portability, or the right to file a complaint — submit a written request to our Data Privacy Officer at:

77ph6 will acknowledge your request within 3 business days. Requests will be processed within 15 business days of receipt of complete information. Where 77ph6 is unable to fulfil a request within this timeframe — for example, due to the complexity of the request — you will be notified of the reason for the delay and given an estimated completion date. There is no charge for exercising your data rights unless requests are manifestly unfounded or excessive.

In the event of a personal data breach that is likely to result in a real risk of serious harm to the Data Subjects affected, 77ph6 will:

• Notify the National Privacy Commission within 72 hours of becoming aware of the breach, as required by NPC Circular 16-03 and related issuances.
• Notify affected Data Subjects without undue delay where the breach is likely to result in a high risk to their rights and freedoms — providing a plain description of the nature of the breach, the likely consequences, and the measures taken or proposed to address it.
• Conduct a full post-incident investigation and implement remedial measures to prevent recurrence.
• Maintain a data breach register documenting all incidents, their causes, and the remedial actions taken, available for inspection by the NPC upon request.

If you are not satisfied with 77ph6's response to a data rights request or data privacy complaint, you have the right to lodge a complaint directly with the National Privacy Commission of the Philippines:

77ph6 will cooperate fully with any NPC investigation and will implement any remedial actions directed by the NPC in connection with a complaint or inquiry.

77ph6 may update this Privacy Policy from time to time to reflect changes in law, regulation, NPC guidance, PAGCOR requirements, platform features, or business practices. The "Last Updated" date at the top of this document will be revised whenever changes are made.

For material changes that significantly affect how we process your personal data, 77ph6 will provide notice via the email address registered to your account at least 14 days before the changes take effect, where practicable. Minor changes — such as typographical corrections, updated contact details, or clarifications that do not alter the substance of our data processing practices — may be made without advance notice.

Continued use of the 77ph6 platform following the effective date of an updated Privacy Policy constitutes your acknowledgment of the revised Policy. If you do not accept the changes, you must stop using the platform and request account closure via [email protected].

For all privacy-related queries, data rights requests, or concerns regarding this Privacy Policy, please contact the 77ph6 Data Privacy Officer:

We welcome questions about this Policy. Transparency about how we handle your personal data is something we take seriously at 77ph6, and we are committed to giving you clear, honest answers.