🔒 top 77 Casino – Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how top 77 Casino ("top 77", "we", "us", "our"), operator of the online gaming platform available at top77.biz, collects, uses, discloses, stores, and protects the personal information of individuals ("you", "your", "player") who access or use the top 77 platform.

top 77 Casino is committed to protecting the privacy of all players, with particular attention to the rights of Filipino users under applicable Philippine data protection laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, as administered by the National Privacy Commission (NPC) of the Philippines.

This Policy applies to all personal data collected through the top 77 website at top77.biz, any mobile web version of the platform, customer support communications, and any other interaction between you and top 77 Casino. By registering an account or using the top 77 platform, you acknowledge that you have read and understood this Policy and consent to the collection and use of your personal data as described herein.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, top 77 Casino is the Personal Information Controller responsible for the personal data of registered players and platform visitors.

top 77 Casino processes personal data for the operation of its online gaming platform in the Philippines. All data-related inquiries, requests, and complaints may be directed to the top 77 Data Protection Officer at [email protected].

3. Personal Data We Collect

top 77 Casino collects the following categories of personal data from players and platform users:

3.1 Registration & Identity Data

• Full legal name (first name, middle name, last name);
• Date of birth (for age verification — 21+ requirement);
• Philippine mobile number used as the primary login identifier;
• Username and encrypted password;
• Email address (if provided during registration or support contact).

3.2 Identity Verification (KYC) Data

• Government-issued Philippine identification document (e.g., PhilSys National ID, UMID, SSS ID, driver's license, passport);
• Selfie or live photograph where required for identity matching;
• Proof of address (utility bill, bank statement, etc.) where required.

3.3 Financial Data

• GCash mobile number and/or account reference;
• Maya (PayMaya) account reference;
• Bank account details (BPI, BDO, UnionBank) where applicable;
• Transaction history: deposit amounts, dates, payment methods, and withdrawal records.

3.4 Gaming Activity Data

• Game session records: games played, wager amounts, outcomes, session duration;
• Bonus activation and wagering history;
• Account wallet balance history.

3.5 Technical & Usage Data

• IP address and approximate geographic location;
• Device type, operating system, and browser type;
• Pages visited, features accessed, and time spent on the top 77 platform;
• Cookie data and session identifiers (see Section 8).

3.6 Communications Data

• Customer support chat transcripts;
• SMS messages sent from top 77 to your registered mobile number;
• Any correspondence you initiate with top 77 Casino.

4. How We Collect Your Data

top 77 Casino 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 responding to surveys;
• Automated collection: Technical data collected automatically when you access the top 77 platform, including IP addresses, device identifiers, and usage logs via cookies and similar technologies;
• Payment processors: Financial data shared by payment service providers (GCash, Maya, BPI, BDO, UnionBank, etc.) in connection with transaction processing;
• Game providers: Gaming activity data shared by certified game providers (JILI, PG Soft, Pragmatic Play, and others) in connection with the games you play on top 77.

5. How We Use Your Personal Data

top 77 Casino uses collected personal data for the following purposes:

• Account creation and management: To register, verify, and maintain your top 77 account;
• Age and identity verification: To verify that you meet the 21+ age requirement mandated by PAGCOR and to confirm your identity for KYC compliance;
• Payment processing: To process deposits, withdrawals, and refunds through your chosen Philippine payment methods;
• Gaming services: To provide access to the games, promotions, and features available on the top 77 platform;
• Regulatory compliance: To satisfy PAGCOR reporting requirements, anti-money laundering (AML) obligations, and other applicable legal obligations;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and breaches of our Terms & Conditions;
• Customer support: To respond to and resolve player inquiries and complaints;
• Communications: To send account notifications, security alerts, and promotional messages (where you have not opted out);
• Platform improvement: To analyze usage patterns and improve the top 77 platform's features, performance, and player experience;
• Responsible gaming: To monitor gaming patterns and, where necessary, apply responsible gaming interventions in accordance with our Responsible Gaming Policy.

6. Legal Basis for Processing

top 77 Casino processes personal data under the following legal bases as recognized by the Data Privacy Act of 2012:

• Consent: Where you have given explicit, informed consent for specific processing activities (e.g., receiving marketing communications);
• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you agreed to when registering your top 77 account;
• Legal obligation: Processing required to comply with PAGCOR regulations, AML laws, tax obligations, and other applicable Philippine laws;
• Legitimate interests: Processing carried out for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data protection rights.

7. Data Sharing & Disclosure

top 77 Casino does not sell, rent, or trade your personal data to unaffiliated third parties for their own marketing or commercial purposes. We may share personal data with the following categories of recipients strictly as necessary:

• Payment service providers: GCash (Globe Fintech Innovations), Maya (Voyager Innovations), BPI, BDO, UnionBank, and other payment processors, solely to process transactions;
• Game providers: Certified game studios (JILI, PG Soft, Pragmatic Play, Spadegaming, etc.) to the extent necessary to provide the relevant game services;
• KYC and identity verification services: Third-party verification providers engaged to assist with the identity verification process;
• Regulatory authorities: PAGCOR and other Philippine government agencies, courts, or law enforcement where required by law or regulatory obligation;
• Technology and hosting providers: Cloud infrastructure, cybersecurity, and IT service providers operating under data processing agreements that require them to protect your data to the same standard as top 77;
• Professional advisors: Legal, accounting, or audit professionals where necessary and subject to professional confidentiality obligations.

All third-party service providers engaged by top 77 Casino are required to process personal data only on our documented instructions and are prohibited from using your data for any purpose other than providing the contracted service.

8. Cookies & Tracking Technologies

The top 77 platform uses cookies and similar tracking technologies to operate effectively and to improve your experience. The following types of cookies may be used:

• Essential cookies: Required for the platform to function, including maintaining your login session and security state. These cannot be disabled without affecting platform functionality;
• Performance cookies: Collect anonymized data about how the top 77 platform is used (e.g., pages visited, error messages) to help us improve platform performance;
• Functionality cookies: Remember your preferences (e.g., language settings, preferred game categories) to provide a more personalized experience;
• Analytics cookies: Used to understand aggregate user behavior patterns on the top 77 platform.

You may control non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of the top 77 platform. top 77 does not use third-party advertising cookies to serve ads on behalf of external companies.

9. Data Retention

top 77 Casino retains personal data for as long as necessary to fulfill the purposes described in this Policy, unless a longer retention period is required or permitted by applicable law.

Specifically:

• Account and KYC data is retained for a minimum of five (5) years after account closure, in compliance with PAGCOR regulatory requirements and Philippine AML laws;
• Transaction and financial records are retained for a minimum of five (5) years from the date of each transaction;
• Customer support communications are retained for two (2) years after the resolution of the relevant inquiry;
• Technical and usage data may be retained in anonymized or aggregated form for analytical purposes without time limitation.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with top 77's data disposal procedures.

10. Your Rights Under the Data Privacy Act

As a data subject, you have the following rights with respect to your personal data processed by top 77 Casino:

• Right to be Informed: The right to be informed of how your personal data is being or will be processed by top 77;
• Right of Access: The right to request a copy of the personal data top 77 holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of personal data that is no longer necessary for the purposes for which it was collected, subject to legal retention requirements;
• Right to Object: The right to object to specific processing activities, including processing based on legitimate interests or processing for direct marketing purposes;
• Right to Data Portability: The right to request your personal data in a structured, commonly used format where technically feasible;
• Right to File a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data protection rights have been violated.

To exercise any of the above rights, please contact top 77 Casino's Data Protection Officer at [email protected]. We will respond to all data rights requests within thirty (30) days of receipt.

11. Data Security

top 77 Casino implements technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the top 77 platform;
• Encrypted storage of passwords and sensitive account credentials — passwords are hashed using industry-standard algorithms and are never stored in plaintext;
• Access controls limiting internal access to personal data to authorized personnel on a need-to-know basis;
• Regular security audits and vulnerability assessments of the top 77 platform;
• Multi-factor authentication options for player accounts to reduce the risk of unauthorized access.

While top 77 employs robust security measures, no internet-based system can guarantee absolute security. You are responsible for maintaining the confidentiality of your login credentials. If you suspect unauthorized access to your top 77 account, contact our support team immediately.

12. Children's Privacy

The top 77 Casino platform is strictly intended for adults aged 21 years and above. top 77 does not knowingly collect or process personal data from individuals under the age of 21. This age restriction is a mandatory requirement under PAGCOR regulations governing online gambling in the Philippines.

If top 77 Casino becomes aware that personal data has been collected from a person under the age of 21, such data will be deleted immediately and the associated account will be permanently closed. If you believe a minor has registered on the top 77 platform, please contact us at [email protected] immediately.

13. Cross-Border Data Transfers

top 77 Casino may transfer personal data to service providers or technology infrastructure located outside the Philippines in connection with hosting, cloud storage, or certain third-party services. All such transfers are conducted in compliance with Section 21 of the Data Privacy Act of 2012, which requires that data transferred outside the Philippines receives an equivalent level of protection.

Where personal data is transferred internationally, top 77 ensures appropriate safeguards are in place, such as data processing agreements incorporating standard contractual clauses or reliance on service providers located in jurisdictions with adequate data protection laws.

14. Links to Third-Party Sites

The top 77 platform may contain references to payment providers and game providers. Any interaction you have with third-party platforms (such as accessing your GCash or Maya account to complete a deposit) is governed by the privacy policies of those third parties, not this Policy. top 77 Casino is not responsible for the data practices of third-party payment processors or game providers accessed outside the top 77 platform.

15. Changes to This Privacy Policy

top 77 Casino reserves the right to update or amend this Privacy Policy at any time. When material changes are made, top 77 will notify registered players via SMS to their registered Philippine mobile number and/or by displaying a prominent notice on the top 77 platform.

The "Last Updated" date at the top of this Policy reflects when it was most recently revised. Material changes will take effect no less than seven (7) days after notification. Your continued use of the top 77 platform after the effective date of any updated Policy constitutes acceptance of the revised terms.

16. Contact Us

For any questions, requests, or concerns regarding this Privacy Policy or the processing of your personal data by top 77 Casino, please contact our Data Protection Officer:

top 77 Casino will acknowledge all data rights requests within five (5) business days and provide a substantive response within thirty (30) days of receipt.