Privacy Policy – 77kbs.com

77kbs.com ("the Company," "we," "us," or "our") is committed to protecting the privacy and personal data of all users ("Player," "User," or "you") who access and use the 77kbs.com platform. This Privacy Policy ("Policy") describes our practices regarding the collection, use, disclosure, storage, and protection of your personal information in connection with your use of our website, mobile platform, 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, and its Implementing Rules and Regulations, as well as applicable guidelines issued by the National Privacy Commission (NPC). By registering an account or using the 77kbs.com Platform, 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.

1. Information We Collect

77kbs.com collects personal information that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

1.1 Identity & Registration Data

• Full legal name as it appears on your government-issued ID
• Date of birth (to verify you are 21 years of age or older)
• Gender
• Nationality and country of residence
• Username and password (stored in encrypted form)

1.2 Contact Information

• Email address
• Mobile phone number
• Residential address (barangay, city, province, ZIP code)

1.3 Identity Verification (KYC) Documents

• Government-issued photo ID (e.g., PhilSys ID, passport, driver's license, UMID, SSS/GSIS card, voter's ID)
• Proof of address (e.g., utility bill, bank statement dated within 90 days)
• Selfie or live photo for identity confirmation
• Proof of payment method (e.g., screenshot of GCash or PayMaya account, bank account details)

1.4 Financial & Transaction Data

• Deposit and withdrawal history
• Payment method details (GCash number, PayMaya number, bank account details – card numbers are never stored in full)
• Transaction amounts in Philippine Peso (PHP / ₱)
• Bonus and promotional activity records

1.5 Gaming Activity Data

• Game history, wager amounts, wins, and losses
• Session duration and frequency of play
• Responsible gaming tool usage (deposit limits, self-exclusion requests)

1.6 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser version
• Cookies and session identifiers
• Log data including access times and pages visited

2. How We Collect Your Information

77kbs.com 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 collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification providers, payment processors (e.g., GCash, PayMaya, BPI, BDO, Metrobank), fraud prevention services, and regulatory bodies such as PAGCOR, where permitted by law.

3. How We Use Your Information

77kbs.com processes your personal data for the following purposes:

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, 77kbs.com processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to upon registration.
• Legal obligation: Processing required to comply with PAGCOR regulations, AML laws, and other applicable Philippine legislation.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring.
• Consent: Processing for direct marketing communications, where you have explicitly opted in. You may withdraw consent at any time.

5. Disclosure of Your Information

77kbs.com does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your information with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers to facilitate deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML compliance services engaged to verify player identities.
• Game software providers: Licensed game studios whose software powers the games available on 77kbs.com, to the extent necessary for game operation and fairness auditing.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine government bodies, where required by law.
• IT and security service providers: Cloud hosting, cybersecurity, and fraud detection vendors operating under strict data processing agreements.
• Legal and professional advisors: Lawyers, auditors, and consultants bound by professional confidentiality obligations.

All third parties with whom 77kbs.com shares personal data are required to implement appropriate technical and organizational security measures and to process data only for the specified purpose.

6. Data Retention

77kbs.com retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account and KYC records are retained for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC requirements.
• Transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Marketing consent records are retained until you withdraw consent and for a reasonable period thereafter as evidence of compliance.
• Technical logs are retained for up to twelve (12) months for security and fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.

7. Data Security

77kbs.com implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 77kbs.com Platform.
• AES-256 encryption for sensitive data stored in our databases, including passwords and payment details.
• Multi-factor authentication options for player accounts.
• Regular penetration testing and security audits conducted by independent cybersecurity firms.
• Strict access controls limiting employee access to personal data on a need-to-know basis.
• 24/7 monitoring of our systems for suspicious activity and potential data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 77kbs.com will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular 16-03.

8. Cookies & Tracking Technologies

77kbs.com uses cookies and similar tracking technologies to enhance your experience on the Platform. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function, including session management and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and login status to provide a more personalized experience.
• Analytics cookies: Collect anonymized data about how players use the Platform to help us improve performance and content.
• Marketing cookies: Used to deliver relevant promotional content based on your activity on the Platform. These are only set with your consent.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 77kbs.com Platform.

9. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 77kbs.com:

• Right to be informed: You have the right to know how your personal data is being collected and processed.
• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the details provided in Section 13 of this Policy. We will respond to all verified requests within thirty (30) days in accordance with NPC guidelines.

10. Children's Privacy

77kbs.com strictly prohibits the use of its Platform by persons under the age of twenty-one (21) years. We do not knowingly collect personal data from individuals below this age. If we become aware that personal data has been collected from a person under 21 years of age, we will immediately close the associated account, delete the data, and return any funds in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that your child has registered on 77kbs.com, please contact our support team immediately at [email protected] so we can take prompt action.

11. Cross-Border Data Transfers

In certain circumstances, your personal data may be transferred to and processed in countries outside the Philippines – for example, where our game software providers or cloud infrastructure partners are based. When such transfers occur, 77kbs.com ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that meet the standards required by the Data Privacy Act of 2012 and NPC guidelines. We will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without your explicit consent or a lawful basis for doing so.

12. Changes to This Policy

77kbs.com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. Material changes will be communicated to registered players via email or a prominent notice on the Platform at least fourteen (14) days before the changes take effect. The "Last Updated" date at the top of this Policy will always reflect the most recent revision. Your continued use of the 77kbs.com Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy.

13. Contact & Data Protection Officer

77kbs.com has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our DPO:

We aim to respond to all data privacy inquiries within thirty (30) days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.