77lj Privacy Policy —
How We Protect Your Data

1 Introduction

77lj is committed to protecting the privacy and personal data of all registered players and visitors to the 77lj platform. We understand that Filipino players trust us with sensitive personal and financial information, and we take that responsibility seriously.

This Privacy Policy applies to all personal data processed in connection with:

• The registration and maintenance of a 77lj player account.
• All gaming activities conducted on the 77lj platform, including casino games, slots, sports betting, and bingo.
• All deposit and withdrawal transactions processed through 77lj.
• Customer support interactions via live chat or email.
• Participation in promotions, bonuses, and loyalty programs offered by 77lj.
• General browsing and use of the 77lj website and mobile interface.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, which are incorporated by reference.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, 77lj operates as the personal information controller responsible for your personal data. Our registered Data Protection Officer (DPO) oversees compliance with all applicable data protection laws and serves as the primary point of contact for data privacy inquiries.

Contact details for our Data Protection Officer are provided in Section 15 of this Policy. All data privacy requests, complaints, and inquiries should be directed to the DPO in the first instance.

3 Personal Data We Collect

77lj collects the following categories of personal data in connection with your account and use of the platform:

77lj does not intentionally collect sensitive personal information (as defined under the Data Privacy Act) beyond what is strictly required for identity verification and AML compliance. We do not collect information on racial or ethnic origin, religious beliefs, health data, or political affiliation unless you voluntarily disclose such information in a support context.

4 How We Collect Your Data

77lj collects personal data through the following channels:

• Direct Collection: Information you provide when registering an account, completing KYC verification, submitting support requests, or participating in promotions.
• Automated Technical Collection: Data collected automatically as you use the 77lj platform, including device identifiers, IP addresses, and session data via cookies and similar tracking technologies (see Section 11).
• Payment Processing Partners: Transaction confirmation data received from GCash, Maya, InstaPay, PesoNet, and other payment service providers when you make deposits or withdrawals.
• Identity Verification Providers: Data returned from third-party KYC verification services used to confirm the authenticity of identity documents submitted during account verification.
• Fraud and Risk Management Systems: Technical signals and behavioral data collected by 77lj's fraud detection systems to identify suspicious activity and protect platform integrity.

5 Purposes of Processing

77lj processes your personal data for the following purposes:

• Account Registration and Management: Creating and maintaining your 77lj player account, verifying your identity, and managing account settings and preferences.
• Service Delivery: Providing access to casino games, slots, sports betting, bingo, and all other features of the 77lj platform.
• Payment Processing: Processing deposits and withdrawals through your chosen Philippine payment methods, including GCash, Maya, BPI, BDO, and others.
• Regulatory Compliance: Fulfilling obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), KYC regulations, and the Data Privacy Act of 2012.
• Fraud Prevention and Security: Detecting and preventing fraudulent transactions, account takeovers, money laundering, and other prohibited activities.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behaviors, enforcing self-exclusion requests, and applying deposit limits and session controls set by players.
• Customer Support: Responding to your queries, resolving disputes, and providing technical assistance.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have opted in to receive such communications. You may opt out at any time.
• Platform Improvement: Analyzing usage patterns and technical data to improve the performance, usability, and content of the 77lj platform.

6 Legal Bases for Processing

Under the Data Privacy Act of 2012, 77lj processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and 77lj, including account management, game access, and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulatory requirements, the Anti-Money Laundering Act, and tax reporting obligations.
• Legitimate Interest: Processing conducted in furtherance of 77lj's legitimate business interests, including fraud prevention, platform security, and service improvement, provided such interests do not override your fundamental rights.
• Consent: Processing for marketing communications and optional analytics, where we have obtained your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

7 Data Sharing and Disclosure

77lj does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate contractual protections:

• Payment Service Providers: GCash, Maya/PayMaya, BPI, BDO, Metrobank, UnionBank, Coins.ph, and other payment processors necessary to facilitate your transactions.
• Identity Verification Providers: Third-party KYC and AML compliance service providers who assist with identity document verification and fraud screening.
• Game Software Providers: Licensed game studios including JILI Gaming, Pragmatic Play, Evolution Gaming, and PG Soft, who may receive technical session data necessary to deliver their games on the 77lj platform.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other government bodies as required by applicable law.
• IT and Security Service Providers: Cloud hosting, cybersecurity, and platform maintenance vendors who process data on 77lj's behalf under strict data processing agreements.
• Legal Advisers: Legal counsel engaged by 77lj in connection with dispute resolution, regulatory matters, or litigation, subject to professional confidentiality obligations.

8 International Data Transfers

Some of 77lj's service providers and game software partners are located outside the Philippines. Where personal data is transferred to jurisdictions outside the Philippines, 77lj ensures that appropriate safeguards are in place to protect your data, including:

• Standard contractual clauses approved by the National Privacy Commission or equivalent data protection authority.
• Contractual data processing agreements requiring receiving parties to maintain data protection standards equivalent to those applicable in the Philippines.
• Transfers to jurisdictions recognized by the NPC as providing adequate levels of data protection.

You may request further information about the specific safeguards applied to international transfers of your personal data by contacting our Data Protection Officer.

9 Data Retention Periods

77lj retains your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy and to comply with applicable legal obligations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your account's active status plus 5 years following account closure, as required by PAGCOR regulations and the AMLA.
• KYC and Identity Verification Records: Retained for a minimum of 5 years following account closure or the last transaction, as required under anti-money laundering regulations.
• Transaction and Financial Records: Retained for a minimum of 5 years from the date of each transaction, in accordance with BIR and AMLA requirements.
• Customer Support Records: Retained for 3 years from the date of the last interaction, for dispute resolution and quality assurance purposes.
• Marketing Data: Retained until you withdraw consent or for a maximum of 3 years from the date of last engagement, whichever is earlier.
• Technical and Usage Data: Retained for a maximum of 24 months, after which it is anonymized or deleted.

Upon expiry of the applicable retention period, 77lj will securely delete or anonymize your personal data in accordance with our data disposal procedures.

10 Security Measures

77lj implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure:

• Encryption: All data transmitted between your device and 77lj servers is encrypted using TLS (Transport Layer Security) 1.2 or higher. Sensitive data at rest, including financial and identity records, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized 77lj personnel on a strict need-to-know basis. All internal access is logged and subject to regular review.
• Multi-Factor Authentication: 77lj systems employ multi-factor authentication for internal administrative access to data systems.
• Penetration Testing: 77lj conducts regular security audits and penetration testing to identify and remediate vulnerabilities.
• Incident Response: 77lj maintains a documented data breach response plan. In the event of a personal data breach affecting your rights, we will notify you and the National Privacy Commission within 72 hours of becoming aware, as required under the Data Privacy Act.
• Staff Training: All 77lj employees who handle personal data receive regular data protection and privacy training.

11 Cookies and Tracking Technologies

77lj uses cookies and similar tracking technologies to operate and improve the platform. The following types of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the 77lj platform, including maintaining your login session, remembering your game preferences, and ensuring platform security. These cannot be disabled without affecting platform functionality.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players navigate and use the 77lj platform. This data helps us improve the platform's performance and usability.
• Functional Cookies: Used to remember your preferences such as preferred language, display settings, and previously accessed game categories.
• Marketing Cookies: Used to deliver relevant promotional content to players who have opted in to receive marketing communications. These are only placed with your consent.

You may manage your cookie preferences through your browser settings. Note that disabling certain categories of cookies may affect your experience on the 77lj platform.

12 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 77lj:

• Right to be Informed: The right to know what personal data 77lj collects and how it is used — fulfilled through this Privacy Policy.
• Right to Access: The right to request a copy of the personal data 77lj holds about you, along with information about how it is processed.
• Right to Rectification: The right to have inaccurate or incomplete personal data corrected. You may update most account details directly from your 77lj account settings.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 77lj's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for marketing purposes or where processing is based on legitimate interest.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another service provider where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe 77lj has violated your data protection rights. The NPC may be contacted via its official website at privacy.gov.ph.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. We will respond to all valid requests within 15 business days. We may request proof of identity before processing your request to protect against unauthorized access to your data.

13 Minors and Age Restriction

The 77lj platform is strictly intended for persons who are 21 years of age or older, in compliance with PAGCOR's requirements for casino-style gaming in the Philippines. 77lj does not knowingly collect personal data from persons under the age of 21.

If 77lj becomes aware that it has inadvertently collected personal data from a person under 21, we will promptly close the associated account, delete the collected data to the extent permitted by law, and take appropriate action in accordance with our regulatory obligations.

Parents or guardians who believe a minor has registered on the 77lj platform are encouraged to contact our customer support team immediately.

14 Updates to This Privacy Policy

77lj 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. Material changes to this Policy will be communicated to registered players via email notification to the address on file and/or via a prominent notice on the 77lj platform.

The "Last Updated" date at the top of this document reflects the most recent revision. Your continued use of the 77lj platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically.

15 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or 77lj's data processing practices, please contact our Data Protection Officer:

• Data Protection Officer, 77lj
• Email: [email protected] — please include "Privacy / DPO Request" in your subject line.
• Live Chat: Available 24/7 via the 77lj platform. Advise the support agent that your query relates to a data privacy matter and it will be escalated to the DPO team.

We aim to acknowledge all data privacy requests within 3 business days and to provide a full response within 15 business days. Complex requests may require additional time, in which case we will inform you of the extended timeline.