Privacy Policy — 77sh Casino

1.Introduction

77sh Casino is committed to protecting the privacy and personal data of all players who use our online gaming platform. This Privacy Policy has been prepared in accordance with the requirements of Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission of the Philippines ("NPC").

This Privacy Policy applies to all personal data collected by 77sh through its website at 77sh.asia, mobile browser interface, customer support channels (including live chat, Facebook Messenger, Viber, and email), and any other services or features offered by 77sh. It covers all registered account holders as well as unregistered visitors who browse the 77sh platform.

77sh processes personal data only for the purposes described in this Privacy Policy and in accordance with the principles of transparency, legitimate purpose, and proportionality as required by the DPA. We do not process personal data in ways that are incompatible with the stated purposes of collection without the prior knowledge and consent of the data subject, except as otherwise permitted by applicable law.

2.Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for your personal information processed through the 77sh platform is 77sh Casino, operating the 77sh.asia platform. Our designated Data Protection Officer ("DPO") can be reached via the contact details set out in Section 15 of this Privacy Policy.

As data controller, 77sh is responsible for determining the purposes and means of processing your personal data, implementing appropriate technical and organisational security measures, and ensuring that processing activities are conducted in compliance with the DPA and all applicable supplementary regulations and NPC issuances.

3.Personal Data We Collect

77sh collects the following categories of personal data in connection with the provision of our gaming services:

77sh does not intentionally collect sensitive personal information as defined under Section 3(l) of the DPA (e.g., racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) except where such information is voluntarily provided by a player in the context of a responsible gaming referral or identity verification process and only to the minimum extent necessary.

4.How We Collect Personal Data

4.1 Direct Collection

77sh collects personal data directly from you when you: register for a 77sh account; complete identity verification (KYC) procedures; make a deposit or request a withdrawal; contact 77sh customer support; participate in promotions or surveys; or update your account settings or responsible gaming preferences.

4.2 Automated Collection

When you access the 77sh platform, we automatically collect certain technical data through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, device identifier, browser configuration, and session activity data. This data is collected to ensure platform security, detect fraud, maintain session integrity, and improve platform performance for Filipino players on Philippine network conditions.

4.3 Collection from Third Parties

In certain circumstances, 77sh may receive personal data about you from third parties, including: payment service providers (e.g., GCash, Maya, BPI) for the purpose of verifying deposit and withdrawal transactions; identity verification service providers used to perform KYC checks; and fraud prevention and anti-money laundering screening services. All such third-party data recipients are required to handle data in accordance with applicable Philippine data privacy requirements.

5.Purposes of Processing

77sh processes your personal data for the following purposes:

• Account Management: Creating, maintaining, and administering your 77sh player account, including authentication and access control;
• Payment Processing: Processing deposits and withdrawals through GCash, Maya, bank transfers, and other accepted payment methods in Philippine Peso;
• Identity Verification (KYC): Verifying your identity and age (21+ requirement) in compliance with applicable Philippine gaming regulations and anti-money laundering obligations;
• Service Delivery: Providing access to 77sh's game catalog, promotional offers, bonus programs, and all other platform features;
• Customer Support: Responding to inquiries, resolving disputes, and providing technical assistance through live chat, Messenger, Viber, and email;
• Security and Fraud Prevention: Detecting, investigating, and preventing fraudulent activity, money laundering, collusion, and other prohibited conduct on the platform;
• Regulatory Compliance: Meeting 77sh's obligations under applicable Philippine gaming regulations, the Data Privacy Act, anti-money laundering laws, and other applicable legislation;
• Responsible Gaming: Monitoring gaming activity to identify potential problem gambling indicators and administering responsible gaming tools including deposit limits, loss limits, and self-exclusion;
• Platform Improvement: Analysing aggregated and anonymised usage data to improve platform performance, game selection, and user experience for Filipino players;
• Marketing Communications: Sending promotional offers, bonus notifications, and product updates to players who have not opted out of marketing communications.

6.Legal Bases for Processing

77sh processes your personal data on the following legal bases as provided under the Data Privacy Act of 2012:

• Performance of Contract: Processing that is necessary to provide the 77sh gaming services you have subscribed to, including account management, payment processing, and game access;
• Compliance with Legal Obligation: Processing required by applicable Philippine law, including KYC obligations, anti-money laundering requirements, gaming regulatory obligations, and data breach notification duties;
• Legitimate Interests: Processing necessary for 77sh's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your fundamental rights and freedoms;
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of marketing communications. You may withdraw your consent at any time by contacting 77sh support or updating your account notification preferences.

7.Data Sharing and Disclosure

77sh does not sell, rent, or trade your personal information. We share personal data only in the following circumstances and only to the extent necessary for the stated purpose:

7.1 Service Providers

77sh engages third-party service providers who process personal data on our behalf as data processors, including payment gateway operators (GCash / GXI, Maya / Voyager Innovations), identity verification and KYC service providers, cloud infrastructure and hosting providers, fraud detection and anti-money laundering screening services, and customer support platform operators. All such processors are bound by data processing agreements requiring them to process data only on 77sh's documented instructions and to implement appropriate security measures.

7.2 Game Providers

To facilitate gameplay, 77sh shares limited technical session data (e.g., session token, currency, wager amounts) with certified game providers including JILI, Pragmatic Play, PG Soft, and Evolution. Game providers do not receive your identity data, financial account details, or contact information beyond what is technically required to maintain a game session.

7.3 Legal and Regulatory Disclosure

77sh may disclose personal data to Philippine government authorities, law enforcement agencies, or regulatory bodies where required or permitted by law, including the National Privacy Commission, PAGCOR or applicable gaming regulatory authority, the Anti-Money Laundering Council (AMLC), and courts of competent jurisdiction pursuant to a valid legal order.

7.4 Business Transfers

In the event of a merger, acquisition, reorganisation, or sale of substantially all of 77sh's assets, personal data held by 77sh may be transferred to the successor entity, subject to the same data protection obligations as set out in this Privacy Policy. You will be notified of any such transfer that materially affects your data rights.

8.Data Retention

77sh retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law. The following retention periods apply as a general guide:

• Active Account Data: Retained for the duration of your 77sh account plus five (5) years following account closure;
• KYC and Identity Verification Documents: Retained for a minimum of five (5) years from account closure, in accordance with anti-money laundering regulatory requirements;
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction;
• Customer Support Communications: Retained for two (2) years from the date of the last communication;
• Marketing Consent Records: Retained for as long as you hold an active 77sh account or until consent is withdrawn, plus one (1) year;
• Technical and Log Data: Retained for twelve (12) months from the date of collection, unless extended for fraud investigation purposes.

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

9.Cookies & Tracking Technologies

77sh uses cookies and similar tracking technologies to operate the platform, maintain session integrity, and collect analytics data. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function correctly, including session management, login state, and security tokens. These cannot be disabled without impairing platform functionality.
• Performance Cookies: Used to collect anonymised analytics data about how players navigate the 77sh platform, enabling us to identify performance bottlenecks and improve the user experience.
• Functional Cookies: Used to remember your preferences such as language settings, responsible gaming preferences, and display configurations.

77sh does not use third-party advertising cookies or permit third-party advertisers to place tracking pixels on the 77sh platform. You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent certain platform features from functioning correctly.

10.Your Data Rights

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

• Right to Be Informed: The right to be informed of the collection, use, and processing of your personal data, as fulfilled by this Privacy Policy;
• Right of Access: The right to obtain a copy of the personal data that 77sh holds about you, subject to verification of your identity;
• Right to Correction: The right to request correction of inaccurate, incomplete, or outdated personal data held in your 77sh account;
• Right to Erasure or Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the stated purposes, subject to 77sh's legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes at any time, effective immediately upon receipt of your objection;
• Right to Data Portability: The right to receive a copy of the personal data you have provided to 77sh in a structured, commonly used, and machine-readable format;
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that your data rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details in Section 15. 77sh will respond to verified data rights requests within fifteen (15) calendar days of receipt, or within any shorter period prescribed by applicable NPC regulations.

11.Security Measures

77sh implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and 77sh servers;
• AES-256 encryption for sensitive data at rest, including financial account details and authentication credentials;
• Secure, salted hashing of all account passwords — 77sh never stores passwords in plain text;
• Two-factor authentication (2FA) via SMS OTP, available to all account holders;
• Access controls restricting personal data access to 77sh personnel on a strict need-to-know basis;
• Regular security assessments and penetration testing of platform infrastructure;
• Audit logging of all access to systems containing personal data, with logs retained for security investigation purposes.

Notwithstanding the above measures, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. You are responsible for maintaining the confidentiality of your own 77sh login credentials and for notifying 77sh immediately if you suspect unauthorised access to your account.

12.Children's Privacy and Age Restriction

77sh Casino services are strictly intended for individuals who are at least twenty-one (21) years of age. 77sh does not knowingly collect personal data from persons under the age of 21. All 77sh accounts are subject to identity verification to confirm that the account holder meets the minimum age requirement.

If 77sh determines that personal data has been collected from a person who is under 21 years of age, that account will be immediately suspended, any real-money balance will be returned to the original deposit source, and all personal data associated with the account will be deleted in accordance with our data disposal procedures. If you believe that a person under 21 has registered a 77sh account, please contact our support team immediately.

13.Cross-Border Data Transfers

Certain 77sh service providers and game content partners operate infrastructure or support functions outside of the Philippines. Where personal data is transferred to recipients in other countries, 77sh takes steps to ensure that appropriate safeguards are in place to protect your data to a standard equivalent to that provided under Philippine law, including the use of contractual data protection clauses in agreements with overseas data processors.

By registering for a 77sh account and accepting this Privacy Policy, you consent to the transfer of your personal data to overseas recipients as described in this section, subject always to the safeguards described above and the protections afforded by the Data Privacy Act of 2012.

14.Amendments to This Privacy Policy

77sh reserves the right to update or amend this Privacy Policy from time to time to reflect changes in applicable law, NPC guidance, our data processing practices, or the services we offer. When material changes are made to this Privacy Policy, 77sh will notify registered players by SMS or email to their registered contact details not less than seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Privacy Policy indicates when the most recent revision was made. Your continued use of the 77sh platform following the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with any amendment, you should cease using the platform and may request account closure in accordance with our Terms & Conditions.

15.Contact & Data Protection Officer

For questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 77sh, please contact our Data Protection Officer using the following details:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines (NPC) if you believe that your rights under the Data Privacy Act of 2012 have not been respected. Information on how to file a complaint with the NPC is available on the official NPC website.