Privacy Policy — 77ny Casino

1. Introduction

This Privacy Policy ("Policy") describes how 77ny ("we", "us", "our", "Platform") collects, uses, stores, and discloses personal information relating to individuals ("you", "Player", "User") who register for, access, or use the 77ny online gaming platform at https://77ny.org.

77ny is committed to protecting the privacy of its players and to handling personal data responsibly, transparently, and in compliance with applicable data privacy laws in the Philippines, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

By creating a 77ny account or using any feature of the Platform, you acknowledge that you have read and understood this Privacy Policy and you consent to the collection, use, and disclosure of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform and contact support to arrange account closure.

This Policy should be read together with the 77ny Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2. Data Controller

For the purposes of applicable data privacy legislation, 77ny acts as the data controller in respect of personal data collected from players and users of the Platform. As data controller, 77ny determines the purposes and means of processing your personal data.

If you have any questions, concerns, or requests relating to the processing of your personal data, you may contact 77ny's designated Data Privacy Officer (DPO) using the contact details provided in Section 15 of this Policy.

3. Data We Collect

77ny collects the following categories of personal data. We collect only what is necessary for the purposes described in this Policy:

We do not collect sensitive personal information such as biometric data, religious beliefs, political opinions, or health records, unless specifically required by law or regulatory authority for identity verification purposes.

4. How We Collect Your Data

77ny collects personal data through the following methods:

• Direct Interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or completing profile settings.
• Automated Technologies: Data collected automatically as you interact with the Platform, including cookies, server logs, device fingerprinting, and session tracking tools. See Section 9 for full details on our cookie practices.
• Third-Party Sources: Data received from identity verification providers, payment processors (such as GCash, Maya, BPI, BDO), fraud prevention services, and data analytics partners — all of whom are contractually bound to handle your data securely.
• KYC and Compliance Checks: During identity and age verification, data may be cross-referenced with external identity verification databases or government-issued ID validation systems as required by applicable regulations.
• Responsible Gaming Monitoring: Behavioral and usage data is automatically analysed by our responsible gaming systems to identify patterns that may indicate problem gambling, in accordance with our duty of care to players.

5. How We Use Your Data

77ny processes your personal data only for legitimate, specific, and clearly defined purposes. The legal bases and corresponding purposes are as follows:

• Contractual Necessity: To create and manage your player account, process deposits and withdrawals, provide access to games and Platform features, and fulfill our obligations under the 77ny Terms & Conditions.
• Legal Obligation: To conduct KYC and Anti-Money Laundering (AML) verification, comply with regulatory reporting obligations, respond to lawful requests from authorities, and fulfill age verification requirements under Philippine gaming regulations.
• Legitimate Interests: To detect, investigate, and prevent fraud, collusion, and other prohibited activities; to monitor platform security and integrity; to improve the platform through analytics; and to manage responsible gaming obligations.
• Consent: To send you promotional communications, personalized offers, and marketing materials — but only where you have provided explicit, recorded consent. You may withdraw this consent at any time.
• Vital Interests: In exceptional circumstances, to protect the safety and wellbeing of a player or third party where there is an imminent risk of harm.

77ny does not use your personal data for automated decision-making that produces significant legal effects without human oversight, except where expressly permitted by applicable law and where appropriate safeguards are in place.

6. Data Sharing & Disclosure

77ny does not sell or rent your personal data to any third party for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment Processors: GCash, Maya, GrabPay, BPI, BDO, Metrobank, QR Ph, and 7-Eleven CLiQQ — to facilitate deposits and withdrawals on your behalf.
• Identity Verification Providers: Third-party KYC and AML service providers who assist in verifying your identity and ensuring compliance with regulatory requirements.
• Game Software Providers: Third-party game developers whose titles are hosted on the 77ny platform may receive anonymized session and gameplay data for the purposes of RNG certification and game integrity monitoring.
• Fraud Prevention Services: Providers of fraud detection, chargeback monitoring, and cybersecurity tools who process limited technical and transactional data to protect the integrity of the Platform.
• Regulatory Authorities: Philippine government agencies, law enforcement bodies, and gaming regulators, where disclosure is required by law, court order, or regulatory directive.
• Professional Advisors: Legal counsel, auditors, and accountants, where access to personal data is required to provide professional services to 77ny, subject to confidentiality obligations.

All third-party service providers engaged by 77ny are subject to data processing agreements that require them to handle your personal data securely and only for the purposes for which it was shared.

7. Data Retention

77ny retains your personal data for as long as is necessary to fulfil the purposes described in this Policy, subject to the following retention principles:

• Active Accounts: Personal data is retained for the duration of your account relationship with 77ny and for a period of at least five (5) years following account closure, in accordance with AML and regulatory record-keeping obligations.
• Transaction Records: Financial transaction data, including deposit and withdrawal records, is retained for a minimum of five (5) years following the date of each transaction, as required under applicable Philippine financial regulations.
• KYC Documents: Identity verification documents are retained for at least five (5) years after the termination of the player relationship, or longer if required by regulatory directive.
• Support Communications: Customer support interactions are retained for three (3) years to facilitate dispute resolution and quality assurance.
• Marketing Data: Consent records and marketing preferences are retained for the duration of your account and for one (1) year following withdrawal of consent, to demonstrate compliance with consent requirements.
• Inactive Accounts: If your account has been inactive for 12 months or more, 77ny may archive your account data. Archived data remains subject to the retention periods above and is not accessible for active platform use.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in a manner that prevents re-identification.

8. Data Security

77ny implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, loss, destruction, or alteration. These measures include:

• Transport Encryption: All data transmitted between your device and 77ny servers is encrypted using TLS 1.2 or higher (256-bit SSL), making interception by unauthorized parties computationally infeasible.
• Encryption at Rest: Sensitive personal and financial data stored in 77ny databases is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is restricted to authorized 77ny personnel and contractors who require it to perform their job functions. Access is granted on a least-privilege basis and is logged for audit purposes.
• Two-Factor Authentication: Administrative and operational systems that hold player data are protected with multi-factor authentication requirements.
• Security Monitoring: 77ny employs intrusion detection systems, real-time security event monitoring, and automated anomaly detection to identify and respond to potential security incidents promptly.
• Regular Audits: Security controls and data handling practices are subject to periodic internal and external audits to identify and remediate vulnerabilities.

In the event of a data breach that is likely to result in a risk to the rights and freedoms of affected individuals, 77ny will notify the relevant regulatory authorities and affected players in accordance with applicable data breach notification requirements.

9. Cookies & Tracking Technologies

77ny uses cookies and similar tracking technologies to enhance platform functionality, maintain session security, and analyze platform usage. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential to the operation of the 77ny Platform. They enable core functions such as maintaining your login session, remembering your security preferences, and ensuring the platform loads correctly. These cookies cannot be disabled without affecting platform functionality.
• Performance & Analytics Cookies: These cookies collect anonymized information about how players interact with the Platform — including pages visited, session duration, and error events — to help 77ny improve platform performance and user experience.
• Functional Cookies: These cookies remember your preferences and settings (such as language preferences and display settings) to provide a more personalized platform experience.
• Security Cookies: Used to detect and prevent fraudulent activity, bot access, and unauthorized account access attempts.

You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will affect your ability to use key platform features, including logging in. 77ny does not use cookies to deliver third-party advertising or to track your activity on external websites.

10. Your Data Rights

Under the Philippine Data Privacy Act of 2012 and applicable data privacy principles, you have the following rights with respect to your personal data held by 77ny:

• Right to be Informed: You have the right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
• Right to Access: You have the right to request a copy of the personal data we hold about you, including information about the purposes of processing and the categories of data involved.
• Right to Correction: You have the right to request correction of any inaccurate, incomplete, or outdated personal data we hold about you.
• Right to Erasure: You have 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 our legal retention obligations described in Section 7.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests where your individual circumstances warrant it.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that we transmit that data to another controller where technically feasible.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to File a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact the 77ny Data Privacy Officer using the contact details in Section 15. We will respond to all valid requests within 15 business days. We may ask you to verify your identity before processing your request.

11. Minors

The 77ny Platform is strictly intended for adults aged 21 years and above. 77ny does not knowingly collect personal data from individuals below the age of 21. If we become aware that personal data has been collected from an underage individual, we will immediately suspend the associated account and delete the data in question, in accordance with applicable law.

If you are a parent or guardian and you believe that a minor in your care has provided personal data to 77ny or has accessed the Platform, please contact us immediately using the details in Section 15. We will investigate and take appropriate action without delay.

12. International Data Transfers

77ny primarily stores and processes player data within the Philippines. In some instances, personal data may be transferred to and processed by service providers located in other jurisdictions, including for the purposes of cloud infrastructure hosting, KYC verification services, and fraud prevention analytics.

Where personal data is transferred outside the Philippines, 77ny ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards include:

• Standard contractual clauses approved by the National Privacy Commission or equivalent regulatory authority.
• Transfers to jurisdictions recognized as providing an adequate level of data protection.
• Data processing agreements requiring overseas recipients to implement security measures equivalent to those described in Section 8 of this Policy.

No personal data is sold or transferred to overseas commercial entities for marketing, advertising, or profiling purposes.

13. Third-Party Links

The 77ny Platform may contain references to third-party services such as payment providers (GCash, Maya, BPI, BDO) and game software providers. These third parties operate their own platforms and are subject to their own privacy policies, which are separate from this Policy.

77ny is not responsible for the privacy practices or the content of third-party platforms. We encourage you to review the privacy policies of any third-party service you interact with in connection with your use of 77ny, particularly payment processors, before providing personal data to those services.

14. Changes to This Policy

77ny reserves the right to update or modify this Privacy Policy at any time. When material changes are made, we will notify you by one or more of the following methods: a prominent notice on the Platform upon your next login, an email notification to your registered email address, or an in-platform notification through your account dashboard.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Your continued use of the 77ny Platform following publication of a revised Privacy Policy constitutes your acceptance of the changes. If you do not agree with a revised Policy, you must cease using the Platform and request account closure through customer support.

We encourage you to review this Policy periodically to stay informed about how 77ny is protecting your personal data.

15. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 77ny, please contact our Data Privacy Officer through the following channels:

• Email: [email protected]
• Live Chat: Available 24/7 through the Platform interface
• Response Time: Within 24 hours for email; under 2 minutes for live chat

For data access, correction, or deletion requests, please include your registered account email address and a description of your request. We may require you to verify your identity before processing sensitive data requests.

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have not been adequately addressed by 77ny.