PA777 Privacy Policy

1 Introduction

PA777 ("PA777," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses our online casino and sports betting platform. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in connection with the PA777 platform accessible at pa777.app.

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC) of the Philippines. It also reflects our obligations under the regulations of the Philippine Amusement and Gaming Corporation (PAGCOR) as they relate to player data and responsible gaming.

This Privacy Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, which together govern your use of the PA777 platform.

2 Data Controller

PA777 acts as the personal information controller (PIC) in respect of all personal data collected through the PA777 platform. As PIC, PA777 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with the Data Privacy Act of 2012 and all applicable Philippine privacy regulations.

PA777 has appointed a Data Protection Officer (DPO) who is responsible for overseeing our data protection practices, handling data subject requests, and serving as the point of contact with the National Privacy Commission. You may contact our DPO through the PA777 support team using the contact details provided in Section 14 of this Policy.

3 Personal Data We Collect

PA777 collects the following categories of personal data from players and prospective players:

PA777 does not collect sensitive personal information as defined under Section 3(l) of the Data Privacy Act — such as racial or ethnic origin, political opinions, religious beliefs, or health data — unless specifically required by law or regulatory obligation (for example, responsible gaming assessments).

4 How We Collect Personal Data

PA777 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing identity verification (KYC), making deposits or withdrawals, contacting support, or participating in promotions;
• Automated collection: Technical and gaming data collected automatically when you access and use the PA777 platform, including through cookies, log files, and analytics tools;
• Third-party sources: Identity verification data from accredited KYC service providers; fraud and AML screening data from compliance service providers; payment verification data from our payment processing partners (GCash, PayMaya, BPI, BDO, Metrobank);
• Regulatory sources: Information received from PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine regulatory authorities in connection with our legal obligations.

5 Purpose & Legal Basis for Processing

PA777 processes your personal data only for specific, legitimate purposes and on a valid legal basis under the Data Privacy Act of 2012. The following table summarizes our processing activities:

Where PA777 relies on your consent as the legal basis for processing (for example, for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Data Sharing & Disclosure

PA777 does not sell your personal data. 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 safeguards:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and other licensed payment processors, solely to facilitate deposits and withdrawals;
• Identity verification providers: Accredited KYC and AML screening service providers engaged to verify your identity and comply with Philippine AML regulations;
• Game software providers: Licensed game developers and platform providers whose games are offered on PA777, to the extent necessary to deliver game services;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or regulatory direction;
• Law enforcement: Philippine law enforcement agencies, where required by a valid legal order or where disclosure is necessary to prevent or investigate fraud, money laundering, or other criminal activity;
• Professional advisors: Legal counsel, auditors, and compliance consultants engaged by PA777, subject to professional confidentiality obligations.

All third parties with whom PA777 shares personal data are required to process that data in accordance with the Data Privacy Act of 2012 and are bound by appropriate data processing agreements or contractual clauses.

7 Data Retention

PA777 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulation. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required under the Anti-Money Laundering Act;
• Gaming and betting records: Retained for a minimum of three (3) years from the date of the gaming session or bet;
• Support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for dispute resolution;
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with PA777's data disposal procedures.

8 Security Measures

PA777 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• TLS encryption for all data transmitted between your device and the PA777 platform;
• AES-256 encryption for sensitive data stored at rest;
• Multi-factor authentication (MFA) options for player accounts;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular penetration testing and vulnerability assessments conducted by independent security specialists;
• 24/7 security monitoring and intrusion detection systems;
• Secure data centers with physical access controls.

In the event of a personal data breach that is likely to result in harm to affected data subjects, PA777 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act of 2012 and NPC Circular 16-03.

9 Cookies & Tracking Technologies

PA777 uses cookies and similar technologies (such as web beacons and local storage) on the pa777.app website and mobile application. The following types of cookies are used:

• Strictly necessary cookies: Essential for the operation of the PA777 platform, including maintaining your login session and security tokens. These cannot be disabled;
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming limits you have set;
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the PA777 platform, helping us improve performance and user experience. PA777 uses only first-party analytics tools and does not share analytics data with third-party advertising networks;
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats.

PA777 does not use third-party advertising or retargeting cookies. You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the PA777 platform.

10 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 PA777:

1. 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;
2. Right of access: You have the right to request a copy of the personal data PA777 holds about you;
3. Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data;
4. 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 PA777's legal retention obligations;
5. Right to object: You have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interest;
6. Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format;
7. 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 these rights, please contact PA777's Data Protection Officer through the support team. PA777 will respond to all data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11 Minors & Age Policy

PA777 is strictly an adult platform. In accordance with PAGCOR regulations, the minimum age to register and use PA777 is 21 years old. PA777 does not knowingly collect personal data from individuals under the age of 21.

If PA777 becomes aware that personal data has been collected from a person under the age of 21, we will immediately suspend the relevant account, delete the personal data in question, and report the matter to the relevant regulatory authority where required.

If you believe that a minor has registered on PA777, please contact our support team immediately so that we can take appropriate action.

12 Cross-Border Data Transfers

In certain circumstances, PA777 may transfer personal data to service providers or partners located outside the Philippines — for example, to cloud infrastructure providers or game software developers operating in other jurisdictions. Any such cross-border transfer of personal data will only be carried out where:

• The recipient country provides an adequate level of data protection as recognized by the National Privacy Commission; or
• Appropriate safeguards are in place, such as standard contractual clauses approved by the NPC or binding corporate rules; or
• The transfer is necessary for the performance of a contract with you (for example, to process a payment through an international payment network).

PA777 will not transfer personal data to jurisdictions that do not provide adequate data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

13 Changes to This Privacy Policy

PA777 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When material changes are made, PA777 will notify registered players by email or through a prominent notice on the PA777 platform at least seven (7) days before the changes take effect.

The effective date at the top of this Privacy Policy indicates when the current version was last updated. Your continued use of PA777 following the effective date of any revised Privacy Policy constitutes your acknowledgment of the changes. We encourage you to review this Privacy Policy periodically.

The most current version of this Privacy Policy will always be available at pa777.app/privacy-policy.

14 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by PA777, please contact our Data Protection Officer through the PA777 support team. Our support team is available 24 hours a day, 7 days a week.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have not been adequately addressed by PA777.