pn77 Privacy Policy

1. Introduction

pn77 ("pn77," "we," "us," or "our") operates the online gaming platform at pn77.one (the "Platform") under a licence issued by the Philippine Amusement and Gaming Corporation (PAGCOR). We are committed to protecting the privacy and personal data of all individuals who interact with our Platform, including registered players, visitors, and applicants.

This Privacy Policy ("Policy") describes the categories of personal data we collect, the purposes for which we process it, the parties with whom we share it, how long we retain it, and the rights you hold as a data subject under Philippine law. This Policy applies to all processing activities conducted by pn77 in connection with the Platform, including account registration, gameplay, payment processing, customer support, and marketing communications.

By creating an account on pn77 or using any part of the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree to this Policy, you must not register an account or use the Platform.

2. Data Controller

pn77 acts as the Data Controller for all personal data collected through the Platform, as defined under the Philippine Data Privacy Act of 2012 (Republic Act 10173, "DPA") and its Implementing Rules and Regulations. As Data Controller, pn77 determines the purposes and means of processing your personal data.

pn77 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection legislation. You may contact the pn77 DPO at: [email protected] — this address is displayed as plain text only and is not a clickable link.

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register an account, make a transaction, contact support, or otherwise interact with pn77, we collect the following categories of personal data:

3.2 Data Collected Automatically

When you access and use the Platform, pn77 automatically collects the following data through cookies, log files, and similar technologies:

• IP address and approximate geographic location (region/province level)
• Device type, operating system, and browser version
• Session duration, pages visited, and navigation patterns within the Platform
• Game activity logs, including games played, bet amounts, outcomes, and timestamps
• Login timestamps, session identifiers, and device fingerprint data

3.3 Data from Third Parties

pn77 may receive personal data about you from third parties in the following circumstances: from payment processors (GCash, Maya, BPI, BDO, Metrobank, UnionBank) confirming the status of your transactions; from identity verification service providers confirming the validity of your submitted Philippine government ID; and from PAGCOR or other regulatory authorities in connection with licensing compliance obligations.

4. How We Use Your Personal Data

pn77 processes your personal data for the following purposes:

• Account Management: Registering and maintaining your pn77 account, verifying your identity and age (21+ requirement), and authenticating your logins.
• Service Delivery: Providing access to games, processing bets and payouts, crediting bonuses, and delivering customer support.
• Payment Processing: Facilitating deposits from and withdrawals to your registered Philippine payment methods, and verifying that payment instruments belong to you.
• Regulatory Compliance: Fulfilling PAGCOR licensing obligations, meeting Anti-Money Laundering Council (AMLC) reporting requirements, conducting mandatory KYC verification, and enforcing responsible gaming obligations.
• Responsible Gaming: Monitoring gameplay patterns to identify potential signs of problem gambling, enforcing deposit limits and self-exclusion orders, and delivering responsible gaming communications.
• Fraud Prevention and Security: Detecting and investigating fraudulent transactions, duplicate accounts, collusion, unauthorised access, and other security threats.
• Platform Improvement: Analysing aggregated usage data to improve game offerings, platform performance, and user experience.
• Marketing Communications: Sending promotional offers, new game announcements, and bonus notifications to players who have opted in to receive such communications. You may opt out at any time by contacting support.

5. Legal Basis for Processing

pn77 processes your personal data under the following legal bases as recognised by the Philippine Data Privacy Act of 2012:

• Consent: For marketing communications and for the processing of sensitive personal information where consent is required. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Performance of a Contract: For processing necessary to fulfil the Terms and Conditions between you and pn77, including account management, game access, and payment processing.
• Legal Obligation: For processing required to comply with PAGCOR regulations, AMLC reporting requirements, and any other applicable Philippine law.
• Legitimate Interests: For fraud prevention, security monitoring, platform analytics, and other processing activities where pn77's legitimate interests do not override your privacy rights.

6. Sharing of Personal Data

6.1 Regulatory Authorities

pn77 is required by PAGCOR licensing conditions and Philippine law to share certain player data with regulatory and law enforcement bodies, including but not limited to PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC), when required by applicable law or a valid legal process.

6.2 Service Providers

pn77 engages third-party service providers who process personal data on pn77's behalf and under pn77's instructions, including: payment processors (GCash, Maya, BPI, BDO, Metrobank, UnionBank, 7-Eleven, USDT processors, Coins.ph); identity verification providers; game content licensors (for the purposes of audit and RNG certification); and cloud infrastructure providers. All service providers are contractually bound to process data only as instructed by pn77 and to maintain appropriate security measures.

6.3 No Sale of Data

pn77 does not sell, rent, trade, or otherwise transfer your personal data to any third party for that party's own commercial purposes. This prohibition is absolute and applies regardless of any commercial consideration offered to pn77.

7. International Data Transfers

Where pn77 transfers your personal data to entities located outside the Republic of the Philippines — for example, to cloud infrastructure providers or game content licensors — pn77 ensures that such transfers are conducted in accordance with the requirements of the Philippine Data Privacy Act, including the execution of data transfer agreements incorporating the standard contractual clauses recognised by the National Privacy Commission.

pn77 takes reasonable steps to ensure that recipients of your personal data in other jurisdictions apply data protection standards substantially equivalent to those required under Philippine law.

8. Data Retention

pn77 retains your personal data for as long as your account remains active and for such further period as is required by applicable law or legitimate business necessity. Specifically:

• Account and Identity Data: Retained for the duration of the account relationship and for a minimum of five (5) years after account closure, as required by PAGCOR regulations and AMLC record-keeping requirements.
• Transaction and Payment Data: Retained for a minimum of five (5) years from the date of the transaction, in accordance with Philippine AML law.
• Game Activity Logs: Retained for three (3) years from the date of activity for audit and dispute resolution purposes.
• Support Communications: Retained for two (2) years from the date of resolution.
• Marketing Preferences: Retained until you withdraw consent or close your account, whichever is earlier.

Upon expiry of the applicable retention period, pn77 will securely delete or anonymise your personal data in accordance with its data disposal procedures.

9. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pn77:

• Right to Access: You may request a copy of the personal data pn77 holds about you, along with information about how it is processed.
• Right to Correction: You may request that inaccurate or incomplete personal data held by pn77 be corrected or completed.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to pn77's legal retention obligations.
• Right to Object: You may object to processing based on legitimate interests, including profiling for marketing purposes.
• Right to Restrict Processing: You may request that pn77 restrict processing of your data in certain circumstances, such as while a correction request is being assessed.
• Right to Data Portability: You may request a copy of your personal data in a structured, machine-readable format where processing is based on consent or contract and is carried out by automated means.

To exercise any of these rights, submit a written request to pn77's Data Protection Officer at: [email protected] (plain text — not clickable). pn77 will respond to rights requests within thirty (30) days of receipt. Requests may be subject to identity verification before processing.

If you are not satisfied with pn77's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph).

10. Cookies and Tracking Technologies

pn77 uses the following categories of cookies and similar technologies on the Platform:

• Strictly Necessary Cookies: Required for the Platform to function. These include session cookies that maintain your logged-in state and security cookies that protect against cross-site request forgery. These cannot be disabled without rendering the Platform non-functional.
• Performance Cookies: Collect anonymised data about how players use the Platform — pages visited, error messages encountered, load times — to help pn77 improve Platform performance. No personal identification is involved.
• Fraud Prevention Cookies: Used to detect and prevent fraudulent activity, including bot access and account takeover attempts. These use device fingerprinting techniques.

pn77 does not use advertising cookies, third-party behavioural tracking cookies, or social media tracking pixels. You may configure your browser to refuse or delete cookies; however, disabling strictly necessary cookies will prevent you from logging into your pn77 account.

11. Children's Privacy

The pn77 Platform is strictly prohibited for individuals under twenty-one (21) years of age, in accordance with PAGCOR regulations. pn77 does not knowingly collect or process personal data from individuals under the age of twenty-one (21). If pn77 discovers or has reason to believe that personal data has been collected from an individual under twenty-one (21), pn77 will immediately close the account, void all associated bets, and securely delete the personal data collected.

If you are a parent or guardian and believe your child has registered an account on pn77, please contact us immediately at [email protected].

12. Security Measures

pn77 implements the following technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction:

• 256-bit SSL/TLS encryption for all data in transit between your device and pn77 servers
• Encryption at rest for all sensitive personal data stored on pn77 servers
• Passwords stored using industry-standard one-way hashing with per-account salts — pn77 staff cannot read your password
• Role-based access controls limiting pn77 staff access to personal data on a need-to-know basis
• Continuous monitoring and intrusion detection systems
• Regular third-party security audits and penetration testing
• Two-factor authentication available to all registered players

Notwithstanding these measures, no data transmission or storage system is completely secure. If you have reason to believe that your pn77 account has been compromised, contact pn77 support immediately.

13. Changes to This Privacy Policy

pn77 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR requirements. When material changes are made, pn77 will notify registered players by email to their registered address and/or by a prominent notice on the Platform at least fourteen (14) days before the changes take effect, except where immediate changes are required by law or regulation.

Your continued use of the Platform after the effective date of a revised Privacy Policy constitutes your acceptance of the revised Policy. We recommend that you review this Policy periodically to stay informed about how pn77 protects your personal data.

14. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or pn77's data processing practices, please contact the pn77 Data Protection Officer:

• Email: [email protected] (plain text — not a clickable link)
• Live Chat: Available 24/7 from within your logged-in pn77 account
• Response Time: Data rights requests acknowledged within 24 hours; fully responded to within 30 days

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe pn77 has violated your data privacy rights under the Data Privacy Act of 2012.