pr77 Privacy Policy – How We Handle Your Personal Information

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by the operator of pr77 (hereinafter "pr77," "we," "us," or "our") and governs the collection, use, storage, disclosure, and protection of personal data obtained from users ("you," "your," or "User") of the pr77 online gaming platform accessible at pr77.cam and any related mobile or web-based applications.

pr77 is committed to protecting your privacy and complying with the Republic Act No. 10173, known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), the issuances of the National Privacy Commission ("NPC"), and the data governance requirements of the Philippine Amusement and Gaming Corporation ("PAGCOR"). By registering for and using the pr77 platform, you acknowledge that you have read, understood, and consent to the data practices described in this Policy.

This Policy applies to all personal data collected through the pr77 platform, regardless of the device or method used to access it, including desktop browsers, mobile browsers, and any future pr77 applications. It should be read in conjunction with our Terms & Conditions.

2. Personal Data We Collect

pr77 collects personal data in two primary ways: information you provide directly during registration and account use, and information collected automatically through your interaction with the platform. The categories of personal data we process are as follows:

2.1 Data You Provide Directly

Data Category	Specific Data Points	Collection Occasion
Identity Data	Full legal name, date of birth, nationality, gender	Account registration and KYC verification
Contact Data	Philippine mobile number, email address, residential address	Account registration
Identification Documents	Government-issued ID (passport, driver's license, UMID, national ID), selfie photograph	KYC / identity verification
Financial Data	GCash number, Maya account, bank account details (account name and number only), transaction history	Deposit and withdrawal processing
Account Credentials	Username, hashed password, security preferences	Account registration
Communication Data	Support chat transcripts, email correspondence, feedback submissions	Customer support interactions

2.2 Data Collected Automatically

When you access and use the pr77 platform, we automatically collect certain technical and behavioural data, including:

• Device and Technical Data: IP address, device type and model, operating system, browser type and version, screen resolution, and device identifiers
• Usage and Gameplay Data: Games played, betting history, session duration, game preferences, win/loss records, and wagering patterns
• Location Data: Approximate geographic location derived from IP address for geo-restriction compliance and fraud prevention
• Log Data: Access logs, login timestamps, page navigation paths, and error reports
• Cookie and Tracking Data: Session cookies, functional cookies, and analytics data as described in Section 9 of this Policy

We do not collect precise GPS-level location data. Location inference is limited to country and approximate region-level data derived from your IP address.

3. Legal Basis and Purposes for Processing

pr77 processes your personal data only where we have a lawful basis to do so under the Data Privacy Act of 2012. The following table outlines our processing purposes and corresponding legal bases:

Processing Purpose	Legal Basis
Account creation, login authentication, and account management	Performance of contract (your pr77 account agreement)
Identity verification (KYC) and age confirmation (21+ requirement)	Legal obligation (PAGCOR regulations and DPA compliance)
Processing deposits and withdrawal transactions in Philippine Peso	Performance of contract
Anti-money laundering (AML) monitoring and reporting	Legal obligation (Republic Act No. 9160, as amended)
Fraud detection, security monitoring, and abuse prevention	Legitimate interest (platform integrity and user protection)
Responsible gaming monitoring and intervention	Legal obligation (PAGCOR responsible gaming requirements)
Customer support and dispute resolution	Performance of contract and legitimate interest
Sending transactional notifications (deposits, withdrawals, security alerts)	Performance of contract
Sending promotional communications (bonuses, offers)	Consent (opt-in during registration or account settings)
Platform analytics and service improvement	Legitimate interest

4. How We Share Your Personal Data

pr77 does not sell, rent, or commercially trade your personal data to third parties. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to data processing agreements or legal requirements:

4.1 Service Providers and Data Processors

We engage third-party service providers who process personal data on our behalf and under our instructions, including:

• Payment processors: GCash (Mynt), Maya (Voyager Innovations), BancNet, InstaPay, and other Philippine payment providers to facilitate transactions
• KYC and identity verification providers: To perform automated document verification and facial matching services
• Game software suppliers: Pragmatic Play, Evolution Gaming, Jili, PG Soft, CQ9, and JDB receive session identifiers and game outcome data to operate their games; they do not receive your full identity information
• Cloud infrastructure and hosting providers: For platform operation and data storage, under contractual data protection obligations
• Fraud detection and cybersecurity providers: For platform security and abuse prevention

All third-party processors are required to implement appropriate technical and organizational security measures and are prohibited from using your data for their own purposes.

4.2 Regulatory and Legal Disclosures

pr77 may disclose your personal data without your prior consent where we are required to do so by applicable law, regulation, or binding order, including:

• PAGCOR, in connection with the oversight of our licensed gaming operations
• The Anti-Money Laundering Council (AMLC), under Suspicious Transaction Report (STR) or Covered Transaction Report (CTR) obligations
• The National Privacy Commission (NPC), during breach notifications or regulatory inquiries
• Law enforcement agencies or courts, pursuant to a valid subpoena, court order, or legal process under Philippine law

Where legally permissible, pr77 will notify you of such disclosures. However, in cases involving law enforcement investigations, we may be legally prohibited from doing so.

5. Data Retention

pr77 retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your account, plus five (5) years after account closure — in compliance with PAGCOR record-keeping requirements
• Financial transaction records: Retained for a minimum of five (5) years in compliance with AMLC regulations
• KYC documents: Retained for five (5) years post-account closure or as required by PAGCOR
• Customer support records: Retained for three (3) years following resolution of the matter
• Technical logs and IP records: Retained for twelve (12) months for security and fraud investigation purposes
• Marketing consent records: Retained for the duration of the consent plus three (3) years for compliance audit purposes

At the end of applicable retention periods, personal data is securely deleted or anonymized in a manner that prevents re-identification.

6. Data Security Measures

pr77 implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption in transit: All data exchanged between your browser or device and pr77 is encrypted using 256-bit SSL/TLS protocols
• Encryption at rest: Sensitive personal data stored in our databases is encrypted using AES-256 encryption
• Access controls: Internal access to personal data is restricted on a role-based, need-to-know basis with multi-factor authentication required for administrative access
• Two-factor authentication (2FA): Available for all user accounts via SMS OTP to your registered Philippine mobile number
• Intrusion detection systems: Automated monitoring for suspicious access patterns, unauthorized API calls, and potential security incidents
• Regular security assessments: Periodic penetration testing and vulnerability assessments of the platform infrastructure
• Staff data protection training: All pr77 personnel handling personal data receive regular training on data protection obligations and security practices

Notwithstanding these measures, no data transmission over the internet or electronic storage system is completely secure. You play an important role in protecting your own account by maintaining strong, unique passwords and enabling two-factor authentication.

7. Cookies and Tracking Technologies

7.1 Types of Cookies Used

pr77 uses cookies and similar tracking technologies to operate the platform and improve your experience. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for platform functionality, including maintaining your login session, storing your account preferences, and ensuring secure navigation. These cannot be disabled without impacting platform function.
• Functional Cookies: Remember your preferences such as language settings, game lobby filters, and display preferences to provide a more personalized experience.
• Analytics Cookies: Collect anonymized information about how users interact with the platform — pages visited, session duration, and navigation paths — to help us improve platform performance.
• Security Cookies: Used for fraud detection and to verify that login attempts originate from trusted devices and locations.

7.2 Managing Cookies

You may control or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the pr77 platform, including your ability to maintain a logged-in session. Instructions for managing cookies are available through your browser's help documentation.

8. Your Rights Under the Philippine Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by pr77. You may exercise any of these rights by contacting our Data Protection Officer at [email protected]:

pr77 will respond to all data subject requests within ten (10) business days of receipt. In complex cases, we may extend this period by an additional twenty (20) business days, with notification. If you believe your privacy rights have not been adequately addressed, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

9. Children's Privacy and the 21+ Requirement

The pr77 platform is strictly for individuals aged 21 and above. We do not knowingly collect, use, or retain personal data of individuals under the age of 21. If we become aware that a user under 21 has registered on the platform, we will immediately close that account, delete the associated personal data to the extent permitted by our legal retention obligations, and refund any balance held, subject to verification requirements.

If you believe that a person under 21 has created a pr77 account, please contact us immediately at [email protected] so that we can take appropriate action.

10. International Data Transfers

pr77 primarily stores and processes your personal data on servers located within or accessible to Philippine-compliant infrastructure. Where data is processed or accessed by service providers located outside the Philippines (for example, certain game software suppliers or cloud infrastructure providers), pr77 ensures that appropriate contractual safeguards are in place — including standard data protection clauses and data processing agreements — to ensure your data receives an equivalent level of protection to that required under the Philippine Data Privacy Act.

11. Changes to This Privacy Policy

pr77 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or operational requirements. When material changes are made, we will notify registered users via SMS to the registered mobile number or via a prominent notice upon login. The updated Policy will always be available at pr77.cam/privacy-policy. We recommend reviewing this page periodically. Your continued use of the pr77 platform after the effective date of any changes constitutes your acceptance of the revised Policy.

12. Contact Our Data Protection Officer

For all privacy-related queries, requests to exercise your data subject rights, or to report a potential data breach, please contact pr77's designated Data Protection Officer:

• Email: [email protected]
• Response time: Within 10 business days for standard requests
• Languages supported: English and Filipino
• NPC complaint channel: If we are unable to resolve your concern, you may contact the National Privacy Commission of the Philippines directly via privacy.gov.ph