phnn77 Privacy Policy

1 Introduction

phnn77 ("phnn77," "we," "us," or "our") is committed to protecting the privacy and personal data of every player and visitor who interacts with our Platform. This Privacy Policy ("Policy") describes how phnn77 collects, processes, stores, shares, and protects personal information in connection with your use of the phnn77 website, mobile application, and all associated gaming services (collectively, the "Platform").

This Policy is issued in compliance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC"). phnn77 is registered as a personal information controller under applicable Philippine data privacy regulations.

By accessing or using the phnn77 Platform, creating an account, or submitting any personal information to us, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please discontinue use of the Platform immediately.

2 Data We Collect

phnn77 collects personal data that is necessary to provide our gaming services, comply with legal obligations, and maintain the security and integrity of the Platform. The categories of personal data we collect include:

phnn77 does not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect information about your race, religion, political affiliations, or health status unless directly relevant to a responsible gaming assessment conducted at your request.

3 How We Collect Data

phnn77 collects personal data through the following means:

• Direct Submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated Technologies: Data collected automatically when you access the phnn77 Platform, including cookies, web beacons, log files, and similar tracking technologies that record your device information, IP address, and browsing behavior on our Platform.
• Third-Party Payment Providers: Transaction data received from GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors when you make deposits or request withdrawals.
• Identity Verification Services: Data received from third-party KYC and identity verification providers engaged by phnn77 to assist with age verification and fraud prevention.
• Publicly Available Sources: In limited circumstances, phnn77 may supplement your profile with information from publicly available sources for fraud prevention and AML compliance purposes.

4 Legal Basis for Processing

phnn77 processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to provide the gaming services you have registered for, process your transactions, and manage your account.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for phnn77's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Consent: Where phnn77 relies on your consent as the legal basis for processing — such as for marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5 How We Use Your Data

phnn77 uses the personal data we collect for the following purposes:

• To create, verify, and manage your phnn77 player account.
• To process deposits, withdrawals, and other financial transactions on the Platform.
• To verify your identity and age in compliance with PAGCOR regulations and Philippine law.
• To detect, investigate, and prevent fraud, money laundering, and other illegal activity.
• To monitor your gaming activity for responsible gaming purposes and to enforce deposit limits, loss limits, and self-exclusion requests.
• To provide customer support and respond to your inquiries and complaints.
• To send you transactional communications, including account notifications, deposit confirmations, and withdrawal updates.
• To send you promotional communications about phnn77 offers and bonuses, where you have consented to receive such communications.
• To improve the phnn77 Platform, personalize your gaming experience, and develop new features and services.
• To comply with our legal and regulatory obligations, including reporting to PAGCOR and the Anti-Money Laundering Council (AMLC).

6 Sharing Your Data

phnn77 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary and permitted by law:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers engaged to process your deposits and withdrawals. These providers process your financial data under their own privacy policies and are bound by applicable data protection obligations.
• Identity Verification Providers: Third-party KYC and age verification services engaged by phnn77 to assist with regulatory compliance. These providers receive only the minimum data necessary to perform verification.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Law Enforcement: Philippine law enforcement agencies and courts, where phnn77 is legally required or permitted to disclose personal data in connection with the investigation or prosecution of criminal activity.
• Technology and Service Providers: Cloud hosting providers, cybersecurity firms, analytics platforms, and customer support software vendors engaged by phnn77 to operate and maintain the Platform. All such providers are bound by data processing agreements that restrict their use of your data.
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of all or part of phnn77's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

phnn77 requires all third-party service providers who process personal data on our behalf to implement appropriate technical and organizational security measures and to process such data only in accordance with our instructions and applicable Philippine data privacy law.

7 Data Retention

phnn77 retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with phnn77, plus a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and Philippine AML regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act and PAGCOR regulations.
• KYC and Identity Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant verification process.
• Customer Support Records: Retained for three (3) years from the date of the last interaction, or longer where required for dispute resolution or legal proceedings.
• Technical and Usage Data: Retained for up to two (2) years from collection, unless a longer retention period is required for security or fraud investigation purposes.
• Marketing Consent Records: Retained for the duration of your consent and for three (3) years following withdrawal of consent, to demonstrate compliance.

Upon expiry of the applicable retention period, phnn77 will securely delete or anonymize your personal data in accordance with our internal data disposal procedures. Where anonymization is not technically feasible, data will be securely destroyed.

8 Data Security

phnn77 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security framework includes:

• Encryption: All data transmitted between your device and the phnn77 Platform is protected using industry-standard TLS/SSL encryption. Sensitive data at rest, including financial information and identity documents, is encrypted using AES-256 encryption.
• Access Controls: Access to personal data within phnn77 is restricted on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular security training.
• Two-Factor Authentication: phnn77 supports and encourages the use of two-factor authentication (2FA) for player accounts to provide an additional layer of protection against unauthorized access.
• Penetration Testing and Audits: phnn77 conducts regular security assessments, vulnerability scans, and penetration tests to identify and remediate potential weaknesses in our systems.
• Incident Response: phnn77 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, phnn77 will notify the National Privacy Commission and affected individuals in accordance with the timelines prescribed by the Data Privacy Act.

9 Cookies and Tracking Technologies

phnn77 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and support our security and fraud prevention systems. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function. These cookies enable core features such as account login, session management, and security. They cannot be disabled without affecting Platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings, display preferences, and previously visited game categories, to provide a more personalized experience.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the phnn77 Platform, including pages visited, time spent, and navigation paths. This data helps us improve the Platform and user experience.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the Platform.

You can manage your cookie preferences through your browser settings. Most browsers allow you to refuse or delete cookies. Please note that disabling certain cookies may affect the functionality of the phnn77 Platform and your ability to access some features.

phnn77 does not use cookies to serve third-party advertising or to track your activity across unrelated websites.

10 Your Privacy Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by phnn77:

• Right to Be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data phnn77 holds about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• 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 phnn77's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on phnn77's legitimate interests.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe phnn77 has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, please contact phnn77's Data Protection Officer using the contact details provided in Section 14 of this Policy. phnn77 will respond to all verified requests within thirty (30) days, or within such extended period as permitted by applicable law where the request is complex or numerous.

11 Protection of Minors

The phnn77 Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law and PAGCOR regulations governing online gaming. phnn77 does not knowingly collect personal data from individuals under the age of 21.

phnn77 employs age verification procedures during the account registration process and during KYC verification to prevent underage individuals from accessing the Platform. If phnn77 discovers or has reason to believe that personal data has been collected from a person under 21 years of age, we will immediately suspend the relevant account, delete the personal data collected, and return any deposits made, in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that your child has registered on the phnn77 Platform or submitted personal data to us, please contact our support team immediately so that we can take appropriate action.

12 International Data Transfers

phnn77 primarily processes and stores personal data within the Republic of the Philippines. In certain circumstances, personal data may be transferred to or accessed from servers or service providers located outside the Philippines — for example, where phnn77 uses cloud infrastructure or technology vendors with operations in other countries.

Where such international transfers occur, phnn77 ensures that appropriate safeguards are in place to protect your personal data, including:

• Transferring data only to countries or organizations that provide an adequate level of data protection as recognized by the National Privacy Commission.
• Implementing contractual clauses in agreements with overseas service providers that require them to protect personal data to standards equivalent to those required under the Data Privacy Act of 2012.
• Conducting due diligence on all overseas data processors to verify their data security practices before engaging their services.

13 Changes to This Policy

phnn77 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. When material changes are made, phnn77 will post a notice on the Platform and update the "Last Updated" date at the top of this document. Where required by law, phnn77 will seek your renewed consent before processing your personal data under the revised Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how phnn77 protects your personal data. Your continued use of the phnn77 Platform following the publication of an updated Privacy Policy constitutes your acknowledgment of the changes.

14 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way phnn77 handles your personal data, please contact our Data Protection Officer. We are committed to addressing all privacy-related inquiries promptly and transparently.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.

For responsible gaming concerns or self-exclusion requests, please visit our Responsible Gaming page.