1. Introduction and Scope
77pt ("we," "us," "our") operates the online gaming platform accessible at 77pt.club (the "Platform"). This Privacy Policy describes how 77pt collects, processes, stores, shares, and protects the personal information of individuals who access or use the Platform ("you," "your," "the Player").
This Policy applies to all personal data collected through the 77pt website, account registration and verification processes, financial transactions, customer support interactions, and any other interactions you have with 77pt. By registering an account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy.
77pt operates as a PAGCOR-licensed online gaming platform and is subject to the data governance obligations arising from that regulatory status, including obligations under Philippine anti-money laundering law (Republic Act No. 9160, as amended) and PAGCOR's data reporting requirements.
2. Personal Data We Collect
77pt collects personal data through several channels in the ordinary course of operating a regulated online gaming platform. The categories of personal data we collect include:
2.1 Registration and Identity Data
- Full legal name as it appears on a government-issued identification document
- Date of birth (required to verify the 21-year minimum age requirement under PAGCOR regulations)
- Residential address in the Philippines
- Mobile number (used as a primary account identifier and for OTP-based security)
- Email address
- Username and encrypted password credentials
2.2 Identity Verification (KYC) Data
- Copies of government-issued identification documents (e.g., PhilSys ID, passport, driver's license, UMID, SSS ID, PRC ID, voter's ID)
- Selfie or liveness verification images where required for KYC
- Proof of address documentation where required
2.3 Financial Transaction Data
- GCash account number or registered mobile number
- Maya account details
- Bank account details for BPI, BDO, UnionBank, Metrobank, or other supported bank transfer recipients
- Transaction histories: deposit amounts, withdrawal amounts, dates, and payment references
- Cryptocurrency wallet addresses where USDT TRC20 is used
2.4 Gaming Activity Data
- Game session records: games played, bets placed, outcomes, win/loss history
- Bonus and promotion redemption records
- Responsible gaming tool settings (deposit limits, self-exclusion status, session limits)
2.5 Technical and Device Data
- IP address and approximate geolocation at the time of login
- Device type, operating system, and browser information
- Session timestamps and duration
- Cookie and tracking data as described in Section 6
2.6 Communications Data
- Records of live chat conversations with 77pt customer support
- Email correspondence with 77pt support teams
- Complaint and dispute records
3. How We Use Your Personal Data
77pt processes your personal data for the following purposes:
- Account creation and management: To register your 77pt account, authenticate your identity at login, and maintain your account profile.
- Age and identity verification: To confirm that you meet the 21-year minimum age requirement and to comply with PAGCOR's KYC obligations for licensed operators.
- Financial transactions: To process deposits, credit winnings to your wallet, and execute withdrawal requests to your nominated GCash, Maya, or bank account.
- Platform operation and game delivery: To deliver the games, sports betting markets, and promotional features available on the 77pt Platform.
- Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, account compromise, and other illegal activities affecting the Platform.
- Anti-money laundering compliance: To meet the reporting and record-keeping obligations imposed by Philippine AML law and PAGCOR regulations.
- Responsible gaming: To monitor gaming patterns that may indicate problematic gambling behaviour and to administer responsible gaming tools activated by the player.
- Customer support: To respond to your inquiries, complaints, and service requests through live chat, email, or other support channels.
- Marketing communications (with consent): To send you information about 77pt promotions, bonuses, and platform updates where you have consented to receive such communications.
- Legal and regulatory compliance: To comply with applicable Philippine laws, PAGCOR directives, court orders, or requests from competent regulatory authorities.
4. Legal Basis for Processing
Under the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, 77pt processes your personal data on the following legal bases:
- Performance of a contract: Processing necessary to fulfil the Terms and Conditions you accepted upon account registration, including operating your gaming account and processing financial transactions.
- Legal obligation: Processing required to comply with PAGCOR licensing conditions, Philippine AML obligations, and other applicable legal requirements.
- Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring where these interests are not overridden by your data protection rights.
- Consent: Processing for marketing communications, where we rely on your opt-in consent. You may withdraw consent for marketing at any time without affecting the lawfulness of prior processing.
5. Sharing of Personal Data
77pt does not sell or trade your personal data. We share personal data only in the following limited circumstances:
- Payment processors: GCash (Mynt/Globe Fintech), Maya (PayMaya Philippines), BPI, BDO, UnionBank, and other payment service providers receive the minimum data necessary to process your financial transactions.
- Game providers: Third-party game studios (PG Soft, Jili, JDB, Pragmatic Play, and others) receive session-level data required to deliver and certify their games. These providers are contractually prohibited from using your data for their own marketing purposes.
- PAGCOR and regulatory authorities: As a PAGCOR-licensed operator, 77pt is required to share certain player activity data and AML reports with PAGCOR and, where required by law, with Philippine law enforcement agencies.
- Identity verification services: KYC documentation may be processed by third-party identity verification providers operating under data processing agreements with 77pt.
- Legal proceedings: Personal data may be disclosed to courts, law enforcement, or regulatory bodies in connection with legal proceedings, investigations, or to exercise or defend legal claims.
All third-party service providers engaged by 77pt are required to implement appropriate technical and organisational measures to protect personal data and to process data only in accordance with 77pt's instructions.
6. Cookies and Tracking Technologies
77pt uses cookies and similar tracking technologies to operate the Platform effectively. Types of cookies used include:
- Strictly necessary cookies: Required for the Platform to function — including session authentication, security tokens, and load-balancing. These cannot be disabled without affecting Platform functionality.
- Functional cookies: Remember your preferences such as language settings, last-used payment method, and game lobby view settings.
- Analytics cookies: Help 77pt understand how players navigate the Platform — which pages are visited, how long sessions last, and where errors occur — to improve the user experience.
- Anti-fraud cookies: Used to detect and prevent suspicious access patterns, including detection of automated bots and duplicate account creation attempts.
You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to the 77pt Platform.
7. Data Security
77pt implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Specific measures include:
- SSL/TLS encryption for all data in transit between your device and 77pt servers
- Encrypted storage of passwords using industry-standard hashing algorithms; passwords are never stored in plain text
- Access controls ensuring that 77pt staff access personal data only on a need-to-know basis
- Two-factor authentication (2FA) options available to players for account access
- Regular security assessments and monitoring of the Platform infrastructure
In the event of a personal data breach that poses a risk to your rights and freedoms, 77pt will notify the National Privacy Commission (NPC) as required by RA 10173 and will inform affected players where the breach is likely to result in a high risk to their rights.
8. Data Retention
77pt retains personal data for as long as is necessary to fulfil the purposes set out in this Policy and to comply with applicable legal, regulatory, and audit obligations. Specific retention periods include:
- Account and KYC data: Retained for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing conditions and Philippine AML record-keeping requirements.
- Financial transaction records: Retained for a minimum of five (5) years as required by Philippine AML law (RA 9160, as amended).
- Gaming activity logs: Retained for a minimum of two (2) years following the relevant session, or longer where required for dispute resolution or regulatory reporting.
- Customer support communications: Retained for two (2) years following the resolution of the relevant support interaction.
- Marketing consent records: Retained until consent is withdrawn and for a reasonable period thereafter to demonstrate compliance.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with the NPC's guidelines on disposal of personal data.
9. Your Data Subject Rights
Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of the personal data 77pt holds about you:
- Right to be informed: The right to be notified of how your personal data is collected and processed — as set out in this Policy.
- Right of access: The right to request a copy of the personal data 77pt holds about you and information about how it is processed.
- Right to rectification: The right to request correction of any inaccurate or incomplete personal data. You may update some information directly in your account settings; other corrections require a support request.
- Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes collected, subject to 77pt's legal retention obligations under PAGCOR and AML regulations.
- Right to object: The right to object to the processing of your personal data for direct marketing purposes at any time.
- Right to data portability: The right to receive certain personal data you have provided to 77pt in a structured, machine-readable format.
- Right to file a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe 77pt has processed your personal data in violation of RA 10173.
To exercise any of these rights, contact 77pt's Data Protection Officer at [email protected]. We will respond to requests within the timeframes prescribed by the NPC's implementing rules.
10. Children and Minors
The 77pt Platform is strictly prohibited for use by persons under 21 years of age, in accordance with PAGCOR regulations. 77pt does not knowingly collect personal data from individuals below this age threshold. Where 77pt discovers that personal data has been collected from an underage individual, such data will be deleted promptly and the relevant account will be closed. If you believe a minor has accessed the 77pt Platform, please contact support immediately at [email protected].
11. Changes to This Privacy Policy
77pt reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or PAGCOR requirements. The date of the most recent revision is displayed at the top of this page. Where changes are material, 77pt will notify registered players via the Platform or via the registered email address. Continued use of the 77pt Platform following notification of a revised Policy constitutes your acceptance of the updated terms.
12. Contact and Data Protection Officer
For any privacy-related queries, data subject access requests, complaints, or to exercise your rights under RA 10173, you may contact 77pt's designated Data Protection Officer:
- Email: [email protected]
- Live Chat: Available 24/7 within the 77pt Platform at 77pt.club
- Response time: Live chat — immediate; Email — within 15 business days as required by NPC guidelines
For complaints not resolved through 77pt's internal process, you may escalate to the National Privacy Commission (NPC) of the Philippines.