Privacy Policy —
How top77fn Handles Your Data

This Privacy Policy ("Policy") is issued by top77fn ("top77fn," "we," "us," or "our") and applies to all personal data collected through the top77fn platform, accessible at https://top77fn.org, including all associated pages, features, games, and services (collectively, the "Platform").

This Policy is intended to inform you — as a registered player, prospective player, or general visitor in the Philippines — of your rights and our obligations with respect to your personal data. It has been prepared in accordance with the requirements of Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, as administered by the National Privacy Commission of the Philippines.

By accessing the Platform or registering a top77fn account, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. This Policy is incorporated by reference into the top77fn Terms & Conditions and should be read alongside them.

For the purposes of the Data Privacy Act of 2012, the data controller responsible for your personal information is top77fn, operator of the online gaming platform at https://top77fn.org. As data controller, top77fn determines the purposes and means by which personal data collected through the Platform is processed.

top77fn has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the DPA and this Policy. The DPO may be contacted through the contact details provided in Section 16 of this Policy. Requests relating to your personal data rights, data breach notifications, and privacy complaints should be directed to the DPO.

top77fn collects personal data that is necessary to provide the Platform's services, comply with legal and regulatory obligations, and maintain the security and integrity of the gaming environment. The following table summarises the categories of personal data we collect:

top77fn collects personal data through a range of direct and indirect means, all of which are described below:

You provide data directly to top77fn when you: register a new account; complete KYC verification by submitting identity documents; make a deposit or request a withdrawal; contact our support team via live chat or email; respond to surveys or promotional campaigns; or update your account profile or responsible gaming settings.

When you access or use the Platform, top77fn automatically collects technical and behavioural data using standard web and application technologies. This includes server logs that record your IP address and access times; session tokens that maintain your login state; and gameplay event data generated by game servers as you play.

top77fn may receive supplementary data from licensed third-party service providers engaged to support platform operations, including: identity verification services that confirm the authenticity of submitted KYC documents; payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank that confirm transaction status; and fraud detection services that provide risk signals based on network-level indicators. All third-party data providers are bound by contractual data protection obligations.

top77fn processes personal data only where a lawful basis for processing exists under the Data Privacy Act of 2012. The applicable legal bases for top77fn's processing activities are:

1. Contractual Necessity. Processing required to perform the contract between you and top77fn — i.e., to operate your account, process transactions, and provide access to games and services.
2. Legal Obligation. Processing required to comply with applicable laws and regulatory requirements, including anti-money laundering (AML) obligations, KYC requirements, and data retention mandates imposed by Philippine regulatory authorities.
3. Legitimate Interests. Processing for purposes that serve top77fn's legitimate business interests — including fraud detection, platform security, responsible gaming monitoring, and service improvement — where those interests do not override your fundamental rights and freedoms.
4. Consent. Processing for purposes beyond those above — principally, marketing communications — where you have given clear, affirmative consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

top77fn uses the personal data we collect for the following specific and documented purposes:

• Account Creation and Management. To register, maintain, and administer your top77fn account, including authentication, balance management, and account preferences.
• Identity Verification (KYC). To verify your identity, confirm your age (21 years minimum), and confirm that your payment methods are registered in your own name, in compliance with regulatory requirements.
• Payment Processing. To process deposits from and withdrawals to your registered GCash, PayMaya, or bank account, and to maintain complete records of all financial transactions.
• Game Provision. To deliver slot, live casino, bingo, sports betting, and other gaming services and to maintain accurate records of game participation and results.
• Responsible Gaming. To monitor gameplay patterns for indicators of problem gambling, to enforce voluntary limits set by players, and to administer self-exclusion arrangements.
• Fraud and Security. To detect, investigate, and prevent fraudulent activity, money laundering, account compromise, and other security threats to the Platform and its users.
• Customer Support. To provide assistance through live chat and email, investigate and resolve disputes, and maintain a record of communications for quality assurance.
• Regulatory Compliance. To meet obligations under Philippine law, including anti-money laundering regulations, data protection legislation, and any directions from regulatory authorities.
• Marketing Communications (consent-based). To send you promotional offers, news, and updates about top77fn where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement. To analyse aggregate usage data, identify technical issues, and improve the performance, design, and content of the Platform.

top77fn does not sell, rent, or trade your personal data to any third party. We share personal data only in the following strictly defined circumstances:

top77fn engages licensed third-party service providers who process personal data on our behalf under strict written data processing agreements. These providers include: game providers (Pragmatic Play, PG Soft, and others) who receive minimal technical session data to enable game functionality; payment processors (GCash/Maya, BPI, BDO, Metrobank) who receive payment details to process transactions; identity verification services who receive KYC document images to confirm authenticity; and customer support platform providers who process communication data to enable live chat functionality. All processors are contractually prohibited from using your data for any purpose beyond the specific service they provide to top77fn.

top77fn may be required by applicable law, court order, or regulatory direction to disclose personal data to government agencies, law enforcement bodies, or regulatory authorities in the Philippines. Such disclosures are made only to the extent required by the applicable legal obligation and will be communicated to you where permitted by law.

In the event of a merger, acquisition, or sale of all or a substantial part of top77fn's assets, personal data held about registered players may be transferred to the successor entity as part of that transaction. Where such a transfer occurs, affected players will be notified in advance and provided with information about the successor entity's privacy practices.

top77fn uses cookies and similar tracking technologies to enable the Platform to function correctly and to improve your experience. The categories of cookies used are:

• Strictly Necessary Cookies. Essential to the operation of the Platform. These cookies enable you to remain logged in, maintain your session state, and complete transactions. They cannot be disabled without affecting core functionality.
• Functional Cookies. Allow the Platform to remember your preferences, such as language settings, responsible gaming limits, and game lobby filters. These persist between sessions for your convenience.
• Analytics Cookies. Help us understand how players interact with the Platform — which pages are visited, which features are used, and where errors occur. Analytics data is aggregated and does not identify individual users.
• Security Cookies. Used for fraud detection and account security, including identification of unusual login patterns or suspicious activity.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair or prevent access to the Platform. top77fn does not use cookies to serve third-party advertising on the Platform.

top77fn implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and top77fn servers.
• Encryption of sensitive data at rest, including identity documents and financial information stored on our systems.
• Role-based access controls ensuring that only authorised personnel with a documented business need may access personal data.
• Two-factor authentication for internal system access by top77fn staff.
• Regular internal and third-party security audits and penetration testing.
• Incident response procedures enabling rapid containment and notification in the event of a data security breach.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, top77fn will notify the National Privacy Commission and affected individuals within the timeframes prescribed by the Data Privacy Act of 2012 and its implementing rules.

top77fn retains personal data only for as long as is necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory, and contractual obligations. The following retention periods apply:

• Account and Identity Data. Retained for the duration of your active account plus a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements under Philippine law.
• Transaction Records. Retained for a minimum of five (5) years following the date of each transaction, consistent with financial record-keeping obligations.
• KYC Documents. Retained for the duration of the account relationship plus five (5) years following account closure.
• Gameplay History. Retained for a minimum of two (2) years for dispute resolution purposes; aggregate anonymised data may be retained indefinitely for statistical purposes.
• Support Communications. Retained for a minimum of two (2) years following the resolution of each matter.
• Technical and Log Data. Retained for up to twelve (12) months for security and operational purposes.
• Marketing Preferences. Retained until you withdraw consent or close your account, whichever is earlier.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in a manner that prevents re-identification. Where data is subject to an ongoing legal investigation or dispute, retention may be extended until the matter is resolved.

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by top77fn. You may exercise any of these rights at any time by contacting us through the channels set out in Section 16:

top77fn will respond to all data rights requests within thirty (30) calendar days of receipt. Where a request requires additional time due to complexity or volume, we will notify you within the initial 30-day period and provide a revised response timeline. Where we are unable to fulfil a request — for example, due to legal retention obligations — we will explain our reasons in writing.

top77fn is an adult online gaming platform strictly intended for individuals aged 21 years and older, in accordance with Philippine law governing casino-style gaming. top77fn does not knowingly collect personal data from individuals under the age of 21.

Age verification is conducted as part of the account registration process and is confirmed through KYC identity document checks prior to first withdrawal. Where top77fn becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be suspended immediately, any deposited funds returned to the source payment method, and all personal data associated with the account deleted without undue delay.

If you believe that a minor has registered an account on top77fn, please contact our support team immediately so that we may investigate and take appropriate action.

Some of top77fn's service providers — including certain game providers and technology infrastructure operators — may be located or operate servers in countries outside the Philippines. Where personal data is transferred to such providers, top77fn ensures that appropriate safeguards are in place to protect your data to the standard required by the Data Privacy Act of 2012, including contractual clauses that bind recipients to data protection obligations equivalent to those applicable in the Philippines.

top77fn does not transfer personal data to countries that do not offer an adequate level of data protection without first implementing appropriate contractual or technical safeguards. Details of specific international transfers and the safeguards in place are available upon request from our Data Protection Officer.

The top77fn Platform may contain links to game providers' information pages or other third-party content. top77fn does not control the privacy practices of third-party websites or services and is not responsible for their content or privacy policies. We encourage you to review the privacy policy of any third party whose services you access through or in connection with the Platform.

Game provider links embedded within the game lobby (such as links to game rules or provider information pages) are provided for informational purposes. Your interactions with those pages are governed by the respective provider's privacy policy, not this one.

top77fn may update this Privacy Policy from time to time to reflect changes in the Platform's data processing practices, applicable law, or regulatory guidance. The current version of this Policy is always available at https://top77fn.org/privacy-policy, with the effective date displayed at the top of the page.

Where changes to this Policy are material — meaning they significantly affect your rights or our obligations — top77fn will notify registered players by email to the address on file and/or by a notice displayed upon login. Non-material changes, such as clarifications or formatting updates, will take effect immediately without individual notification.

Continued use of the Platform after the effective date of any updated Policy constitutes your acknowledgement of the changes. If you do not accept a material change, you may close your account by contacting our support team.

If you have questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a concern about how top77fn has handled your personal data, please contact us through the following channels:

If you are not satisfied with top77fn's response to a privacy concern or data rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines, the supervisory authority responsible for overseeing compliance with the Data Privacy Act of 2012. Information about how to file a complaint with the National Privacy Commission is available through official Philippine government channels.

top77fn is committed to resolving all privacy concerns internally in the first instance and will make every reasonable effort to address your concern before a formal regulatory complaint becomes necessary.