Privacy Policy

1 Who We Are

This Privacy Policy is issued by yyy77, the operator of the online gaming platform accessible at yyy77.co (the "Platform"). yyy77 is a PAGCOR-regulated online casino and sportsbook serving Filipino players across the Philippines. References to "yyy77", "we", "us", or "our" in this Policy refer to the yyy77 platform operator and its authorised affiliates involved in the delivery of gaming services to Philippine players.

yyy77 acts as the Personal Information Controller in respect of the personal data it collects from players and visitors to the Platform, as defined under the Philippine Data Privacy Act of 2012 (Republic Act 10173).

2 Scope of This Policy

This Privacy Policy applies to all personal data collected by yyy77 in connection with:

• The registration and maintenance of a player account on the yyy77 Platform;
• All transactions — deposits, withdrawals, wagers — conducted through the Platform;
• Use of the yyy77 website, mobile browser interface, or any other yyy77 digital product;
• Communications with yyy77 customer support by live chat, email, or any other channel;
• Participation in yyy77 promotions, bonuses, or loyalty programmes;
• General browsing of the yyy77.co website without creating an account.

This Policy does not apply to third-party websites, services, or platforms that may be accessible via links on the yyy77 Platform. yyy77 does not control and is not responsible for the privacy practices of any third party.

3 Personal Data We Collect

yyy77 collects the minimum personal data necessary to operate the Platform safely, legally, and in compliance with PAGCOR requirements. The categories of personal data we process are set out below.

yyy77 does not intentionally collect special categories of sensitive personal data (such as health data, religious beliefs, or political opinions) unless this is directly volunteered by you in the course of a responsible gaming self-assessment or support enquiry.

4 How We Collect Your Data

yyy77 collects personal data through the following means:

Direct Collection

• Information you provide when registering your yyy77 account — name, mobile number, email, date of birth;
• Identity and address documents submitted during KYC verification;
• Payment method details provided during deposit or withdrawal processes;
• Information provided when contacting yyy77 customer support;
• Responses to surveys, promotions, or feedback requests you choose to participate in.

Automated Collection

• Technical data collected automatically when you access the Platform — IP address, device information, browser type, and session duration — via server logs and cookies;
• Gaming activity data generated as you play games, place bets, and interact with the Platform;
• Payment transaction data generated when you make deposits or withdrawals through GCash, Maya, BPI, BDO, Metrobank, or other supported payment channels.

Third-Party Sources

• Identity verification data from PAGCOR's player database where applicable;
• Fraud and AML screening data from compliance service providers authorised to share such information with PAGCOR-licensed operators;
• GCash or Maya account status information received during payment processing, solely for transaction verification purposes.

5 Purpose & Legal Basis for Processing

yyy77 processes your personal data only where a lawful basis exists under the Philippine Data Privacy Act of 2012. The following table sets out the primary purposes of processing and the corresponding legal basis:

6 Data Sharing with Third Parties

yyy77 does not sell your personal data. We share personal data with third parties only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment processors: GCash, Maya, GrabPay, BPI, BDO, Metrobank, and other payment service providers receive the financial data necessary to process your transactions. These providers are subject to their own data protection obligations under Philippine law;
• Game content providers: Certified game studios — including PG Soft, Pragmatic Play, and others — receive anonymised gaming session data necessary to render and log game outcomes. Full identity data is not shared with game studios;
• KYC and AML service providers: Authorised identity verification and anti-money laundering screening providers receive the identity data necessary to complete regulatory verification checks;
• PAGCOR: yyy77 submits regular regulatory reports to PAGCOR as required by its licence. These reports include aggregated transaction data and, where specifically required, individual player data relating to AML compliance or dispute resolution;
• Philippine law enforcement and regulatory authorities: Where required by a valid order of a Philippine court or competent regulatory authority, yyy77 will disclose personal data as legally mandated;
• Technology and hosting providers: Cloud infrastructure and IT service providers who host the yyy77 Platform are bound by data processing agreements that restrict their use of personal data to the delivery of contracted services only.

7 Cross-Border Data Transfers

Some of yyy77's service providers — including game content studios and cloud infrastructure providers — may be located or operate servers in countries outside the Philippines. Where personal data is transferred internationally, yyy77 ensures that:

• The transfer is made only to countries or organisations that provide an adequate level of protection for personal data as determined by the National Privacy Commission, or;
• Appropriate contractual safeguards — including standard contractual clauses approved for international transfers — are in place between yyy77 and the receiving party;
• The transfer is limited to the minimum data necessary for the specific service being provided by the overseas recipient.

By using the yyy77 Platform and accepting this Privacy Policy, you consent to the international transfer of your personal data in the circumstances and with the safeguards described above.

8 Data Retention

yyy77 retains personal data only for as long as necessary to fulfil the purposes described in this Policy, or as required by applicable Philippine law and PAGCOR licensing obligations. The primary retention periods are:

At the end of the applicable retention period, personal data is securely deleted or anonymised in accordance with yyy77's data deletion procedures.

9 Security Measures

yyy77 implements technical and organisational security measures proportionate to the sensitivity of the personal data we hold. Our key security controls include:

• Transport encryption: All data transmitted between your device and yyy77 servers is encrypted using TLS 1.3 / 256-bit SSL;
• Data at rest: Personal data stored on yyy77 servers is encrypted using AES-256 encryption;
• Access controls: Access to personal data within yyy77 is restricted on a strict need-to-know basis. All internal access is logged and monitored;
• Two-factor authentication: SMS 2FA is available to all players and required for internal yyy77 staff systems handling personal data;
• Penetration testing: yyy77's Platform and infrastructure undergoes periodic independent security testing;
• Breach response: In the event of a personal data breach, yyy77 will notify the National Privacy Commission within 72 hours of discovery, and will notify affected individuals promptly where the breach poses a high risk to their rights.

10 Cookies & Similar Technologies

yyy77 uses cookies and similar tracking technologies on the Platform. A cookie is a small text file stored on your device when you access a website. yyy77 uses the following categories of cookies:

• Strictly necessary cookies: Required for the Platform to function. These include session cookies that maintain your login state and security tokens. These cookies cannot be disabled without impairing Platform functionality;
• Functional cookies: Remember your preferences such as language, display settings, and favourite game categories to personalise your yyy77 experience across sessions;
• Analytics cookies: Collect anonymised data about how players navigate the Platform — which pages are visited most, where users encounter difficulties — to help yyy77 improve the Platform. No individually identifiable data is collected for analytics purposes;
• Security cookies: Support fraud detection and account security by identifying unusual access patterns.

yyy77 does not use third-party advertising cookies or participate in cross-site behavioural advertising networks. You may clear cookies from your browser at any time. Clearing strictly necessary cookies will require you to log in again on your next visit.

11 Your Rights Under RA 10173

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by yyy77:

• Right to be Informed: You have the right to know what personal data yyy77 collects, why, and how it is processed. This Policy fulfils that right;
• Right to Access: You may request a copy of the personal data yyy77 holds about you, together with information about how it is processed;
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. Basic account details can be updated directly through your yyy77 account settings;
• Right to Erasure: You may request deletion of personal data that is no longer necessary for the purpose for which it was collected, subject to yyy77's legal retention obligations under AMLA and PAGCOR regulations;
• Right to Object: You may object to processing based on legitimate interest, including direct marketing communications. Marketing opt-out is available in your account settings;
• Right to Data Portability: You may request a copy of data you have provided to yyy77 in a structured, commonly used, machine-readable format;
• Right to Damages: You are entitled to seek compensation from yyy77 if you suffer actual damages as a result of a violation of your data privacy rights;
• Right to File a Complaint: You may file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe yyy77 has violated your data privacy rights.

To exercise any of these rights, contact the yyy77 Data Protection Officer at [email protected], marked "Attention: Data Protection Officer — Rights Request." yyy77 commits to acknowledging all rights requests within 5 Philippine business days and providing a substantive response within 15 calendar days.

12 Minors & Age Restriction

The yyy77 Platform is strictly restricted to persons aged 21 years and above, as required by PAGCOR regulations. yyy77 does not knowingly collect personal data from persons under the age of 21.

All accounts are subject to mandatory age verification through the KYC process, which requires a valid Philippine government-issued photo ID confirming date of birth. Any account found to belong to a person under 21 years of age will be immediately closed, the identity data retained only as required by PAGCOR, and the matter reported to PAGCOR as required by yyy77's licence conditions.

Parents and guardians who believe that a minor has registered on the yyy77 Platform should contact yyy77 support immediately at [email protected]. yyy77 will investigate and take appropriate action, including account closure and return of any deposited funds to the verified payment source, within 2 Philippine business days of receiving a substantiated report.

13 Marketing Communications

yyy77 will send promotional communications — including bonus offers, game announcements, and platform updates — only to players who have explicitly opted in to receiving such communications during registration or through their account settings.

Every marketing communication sent by yyy77 includes a clear and functional unsubscribe mechanism. You may opt out of marketing communications at any time by:

• Updating your notification preferences in your yyy77 account settings;
• Clicking the unsubscribe link in any marketing email from yyy77;
• Contacting yyy77 support via live chat and requesting removal from marketing lists.

Opt-out requests for marketing communications are processed within 2 Philippine business days. Please note that opting out of marketing communications does not prevent yyy77 from sending transactional communications — such as account confirmation emails, OTP messages, deposit confirmations, and withdrawal notifications — which are essential to the operation of your account.

14 Changes to This Privacy Policy

yyy77 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, or our data processing practices. The date of the most recent update is displayed at the top of this Policy.

Where yyy77 makes material changes to this Policy — changes that meaningfully affect how your personal data is processed — a notification will be displayed on the Platform for a minimum of 14 days prior to the effective date of the change. For significant changes that require fresh consent, yyy77 will request your explicit agreement before the revised processing commences.

Continued use of the yyy77 Platform following notification of any non-material change constitutes your acknowledgement of the updated Policy. For material changes requiring consent, continued use will constitute acceptance only after you have affirmatively acknowledged the update.

15 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way yyy77 handles your personal data, please contact us through the following channels:

• Data Protection Officer: [email protected] — mark your email "Attention: Data Protection Officer."
• General support enquiries: Available 24/7 via live chat from within your logged-in yyy77 account.
• FAQ: Visit the yyy77 FAQ page for answers to common questions about your account, payments, and data privacy.

If you are not satisfied with yyy77's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.