77color Privacy Policy

This Privacy Policy applies to all personal data processed by 77color in connection with your use of the 77color online gaming platform accessible at 77color.club, including all associated services, features, mobile access, and customer support channels (collectively, the "Platform").

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, 77color is the Personal Information Controller with respect to the personal data of players and users of the Platform. As Personal Information Controller, 77color determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable data protection laws.

This Policy covers personal data collected directly from you, personal data generated through your use of the Platform (such as gameplay and transaction records), and personal data received from third parties in connection with account verification and payment processing.

77color collects the following categories of personal data in connection with operating the Platform and providing services to players:

2.1 Registration & Identity Data

• Full legal name (as it appears on your Philippine government-issued ID)
• Date of birth (for age verification — 21+ requirement)
• Philippine mobile number
• Email address (where provided)
• Username chosen at registration
• Residential address (where required for KYC or regulatory compliance)

2.2 Identity Verification (KYC) Data

• Government-issued Philippine ID documents (PhilSys ID, passport, driver's license, UMID, SSS ID, PRC ID, voter's ID)
• Selfie photographs submitted for facial verification, where required
• Proof of address documents (utility bills or bank statements)
• Source of funds documentation, where requested for compliance purposes

2.3 Financial & Transaction Data

• Payment method details (GCash registered mobile number, PayMaya account reference, bank account details where applicable — full payment credentials are not stored by 77color and are handled by certified payment processors)
• Deposit and withdrawal history
• Transaction amounts, dates, and references
• Bonus and promotional credit history

2.4 Gameplay & Platform Usage Data

• Game session records, bet amounts, outcomes, and balance changes
• Login timestamps, session durations, and logout records
• Pages visited, features accessed, and navigation patterns within the Platform
• Responsible gaming tool usage (deposit limits set, cool-off periods activated)

2.5 Technical & Device Data

• IP address at time of access
• Device type, operating system, and browser or app version
• Mobile network information (carrier, connection type)
• Cookie and session identifier data (see Section 5)
• Geographic location data derived from IP address (country and approximate region)

2.6 Communications Data

• Records of communications between you and the 77color support team, including live chat transcripts, email correspondence, and support ticket content
• Complaint and dispute records

77color processes your personal data on one or more of the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

77color uses your personal data for the following specific purposes:

• Account Registration and Management: Creating and maintaining your 77color account, authenticating your login sessions, and managing account settings and preferences.
• Age and Identity Verification: Confirming that you meet the 21+ age requirement for access to 77color gaming services, in compliance with Philippine gaming regulations.
• Payment Processing: Facilitating deposits into your 77color account and processing withdrawal requests to your nominated Philippine payment method (GCash, PayMaya, or bank account).
• Regulatory and AML Compliance: Meeting obligations under Philippine Anti-Money Laundering laws, including transaction monitoring, suspicious activity reporting to the Anti-Money Laundering Council (AMLC), and maintenance of required records.
• Game Provision and Record-Keeping: Delivering gaming services, maintaining accurate bet and outcome records, and resolving game disputes using server-side logs.
• Bonus and Promotion Administration: Tracking wagering requirements, calculating cashback amounts, and determining eligibility for promotional offers.
• Responsible Gaming: Monitoring gameplay patterns to identify potential problem gambling behavior, administering player-set deposit and session limits, and processing self-exclusion requests.
• Customer Support: Responding to account queries, resolving complaints, investigating disputes, and communicating material account information.
• Platform Security and Fraud Prevention: Detecting and preventing unauthorized account access, collusion, bonus abuse, automated bot activity, and other fraudulent or prohibited conduct.
• Platform Analytics and Improvement: Analyzing aggregate usage data to improve platform performance, game library curation, and user experience — using anonymized or pseudonymized data where possible.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to players who have consented to receive such communications.

77color uses cookies and similar tracking technologies on the Platform for purposes of session management, security, analytics, and — where consent has been obtained — personalization and marketing. The following types of cookies are used:

5.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function and cannot be disabled. They include session authentication cookies that keep you logged in during a 77color session, security tokens that protect against cross-site request forgery, and cookies that store your account preferences such as language settings. No consent is required for strictly necessary cookies.

5.2 Analytics Cookies

77color uses analytics tools to collect aggregated, anonymized data about how players navigate the Platform — which pages are visited most frequently, session duration, and where players encounter errors. This data is used to improve Platform performance and user experience. Analytics cookies require your consent where mandated by applicable law.

5.3 Functional Cookies

Functional cookies remember your preferences — such as display settings, recently played games, and responsible gaming tool configurations — so you do not need to reset them at every visit. These cookies enhance your 77color experience but are not strictly required for the Platform to operate.

5.4 Marketing Cookies

Where you have provided consent, 77color may use cookies to deliver personalized promotional content within the Platform based on your gameplay history and preferences. You may withdraw consent for marketing cookies at any time through your Account Settings or by contacting support.

77color does not sell your personal data to third parties for their independent marketing or commercial purposes. Personal data may be shared with the following categories of third parties solely to the extent necessary for the purposes described in this Policy:

6.1 Payment Service Providers

Financial transaction data is shared with GCash (G-Xchange, Inc.), PayMaya Philippines, Inc., and Philippine banking partners (BPI, BDO, Metrobank, UnionBank) as necessary to process your deposits and withdrawals. These providers process your data as independent data controllers under their own privacy policies and Philippine BSP regulations.

6.2 Game Content Providers

To deliver gaming services, 77color shares necessary session and account data with licensed game providers and live casino operators whose games are featured on the Platform. This data is limited to what is technically required for game delivery and result recording. Game providers process this data under contractual data processing agreements with 77color.

6.3 Identity Verification Services

KYC document review may be conducted with the assistance of certified identity verification service providers. These providers process your ID documents solely for the purpose of verifying your identity and age on behalf of 77color and are contractually prohibited from using your data for any other purpose.

6.4 Regulatory Authorities

77color is legally required to share certain data with Philippine regulatory authorities, including the Anti-Money Laundering Council (AMLC) in connection with suspicious transaction reports, and relevant gaming regulators in connection with compliance reporting. Such sharing is mandatory and does not require your consent.

6.5 Law Enforcement

77color will disclose personal data to law enforcement agencies, courts, or other governmental bodies when required to do so by law, court order, or legally binding governmental authority, or where necessary to protect the safety of persons or to prevent or investigate suspected fraud or criminal activity.

Some of the third-party service providers used by 77color may process personal data outside the Philippines, including in jurisdictions where live casino studio operations are based. Where personal data is transferred internationally, 77color ensures that appropriate safeguards are in place to protect your data, including:

• Contractual data processing agreements incorporating standard data protection clauses consistent with the requirements of the Philippine Data Privacy Act
• Transfer only to jurisdictions with adequacy determinations or equivalent data protection standards recognized by the National Privacy Commission of the Philippines
• Transfer to certified processors that have implemented binding corporate rules or equivalent compliance frameworks

You may request information about specific cross-border transfer safeguards applicable to your personal data by contacting the 77color Data Protection Officer at the contact details in Section 15.

77color implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Encryption in Transit: All data exchanged between your device and the 77color Platform is encrypted using TLS 1.2 or higher (256-bit SSL), including login credentials, payment information, and KYC documents.
• Encryption at Rest: Sensitive personal data stored in 77color's systems — including identity documents and financial records — is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data is restricted to authorized 77color personnel and contractors who require such access to perform their job functions. All access is governed by role-based access controls and is logged for audit purposes.
• Two-Factor Authentication: 77color systems use two-factor authentication for administrative access. Players are strongly encouraged to enable 2FA on their accounts for additional protection.
• Network Security: The 77color Platform is protected by firewalls, intrusion detection systems, and regular vulnerability scanning and penetration testing conducted by qualified security professionals.
• Incident Response: 77color maintains a documented security incident response plan and regularly tests its effectiveness through simulated incident exercises.
• Staff Training: All 77color personnel with access to personal data receive regular data protection training covering their obligations under the Philippine Data Privacy Act and internal security policies.

77color retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulations. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted from 77color's systems or irreversibly anonymized such that it can no longer be attributed to an identifiable individual. Anonymized aggregate data may be retained indefinitely for statistical and analytical purposes.

The 77color Platform is strictly for individuals who are 21 years of age or older, as required by Philippine gaming regulations. 77color does not knowingly collect personal data from individuals under 21 years of age.

If 77color becomes aware that personal data has been collected from an individual who does not meet the minimum age requirement, the following actions will be taken immediately:

• The associated account will be permanently suspended and closed
• All balances in the account, including any winnings, will be forfeited
• All personal data associated with the account will be deleted to the extent permissible under applicable law, or retained only to the extent required for regulatory reporting
• The incident may be reported to relevant Philippine authorities

To exercise any of your rights under the Philippine Data Privacy Act of 2012 — including the rights to access, correction, erasure, portability, objection, or blocking — please submit a written request to the 77color Data Protection Officer using the contact details in Section 15.

Your request should include:

• Your full name as registered on your 77color account
• Your registered mobile number or email address
• A clear description of the right you wish to exercise and the data to which your request relates
• A copy of a valid Philippine government-issued ID (to verify your identity before processing the request)

77color will acknowledge your request within five (5) business days of receipt and provide a substantive response within fifteen (15) business days, consistent with the timeframes specified under the Data Privacy Act. Complex requests may require additional time, in which case you will be notified of the expected resolution timeline.

Limitations on Erasure Requests

The right to erasure is not absolute. 77color may be required to retain certain personal data notwithstanding an erasure request where retention is necessary to comply with a legal obligation — particularly AML and tax record-keeping requirements — or where the data is needed for the establishment, exercise, or defense of legal claims. Where erasure is partially available, 77color will delete all data that is not subject to a mandatory retention obligation and inform you of what has been retained and why.

Where you have consented to receive marketing communications from 77color, we may contact you via SMS, email, or in-platform notifications to inform you about promotional offers, new games, bonus opportunities, and platform updates relevant to Filipino players.

You may withdraw your consent to marketing communications at any time by:

• Updating your communication preferences in the Account Settings section of your 77color account
• Replying "STOP" to any marketing SMS received from 77color
• Contacting the 77color support team directly via live chat or at [email protected]

Withdrawal of marketing consent will be processed within five (5) business days. Please note that withdrawal of marketing consent does not affect transactional and service communications, such as deposit confirmations, withdrawal processing notifications, security alerts, and mandatory responsible gaming notifications — these are sent on the basis of contractual necessity or legal obligation and are not subject to opt-out.

In the event of a personal data breach that is likely to result in a real risk of serious harm to one or more data subjects, 77color will comply with the mandatory breach notification obligations under the Philippine Data Privacy Act of 2012 and the National Privacy Commission's (NPC) breach notification guidelines. Specifically:

• NPC Notification: 77color will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of a qualifying personal data breach, to the extent feasible, providing all information required under NPC regulations.
• Affected Player Notification: Where a breach is likely to adversely affect your rights and freedoms, 77color will notify affected players without undue delay, providing a description of the breach, the categories of data affected, the likely consequences, and the measures taken or proposed to address the breach.
• Incident Documentation: All personal data breaches, whether qualifying for mandatory notification or not, are documented in 77color's internal breach register and reviewed by the Data Protection Officer.

If you believe your 77color account or personal data has been compromised, please contact the 77color support team immediately via live chat or at [email protected].

77color reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable Philippine data protection law, or recommendations from the National Privacy Commission. When material changes are made to this Policy, 77color will provide notice by one or more of the following means:

• A prominent notice on the 77color homepage or in the Platform interface
• A notification sent to your registered mobile number or email address
• An in-account notification visible upon your next login

The effective date at the top of this Privacy Policy indicates when the current version took effect. Continued use of the 77color Platform following notification of material changes constitutes your acceptance of the updated Policy. If you do not agree to the revised Policy, you should cease using the Platform and may request account closure.

We encourage you to review this Privacy Policy periodically. The current version is always accessible at 77color.club/privacy-policy.

77color has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act of 2012 and this Privacy Policy. The DPO monitors data processing activities, handles data subject rights requests, manages the breach notification process, and serves as the primary point of contact with the National Privacy Commission.

To exercise your data subject rights, raise a data privacy concern, or submit any inquiry related to this Privacy Policy, please contact 77color through the following channels:

• Live Chat: Available 24/7 within the 77color Platform after login — the fastest route for urgent account-related matters
• Support Email: [email protected] — include "Privacy Request" or "Data Subject Rights" in the subject line for prioritized handling
• FAQ: Visit our FAQ page for answers to common questions about accounts, payments, and platform policies

For matters not resolved to your satisfaction through 77color's internal process, you have the right to file a complaint with the National Privacy Commission of the Philippines (privacy.gov.ph). The NPC is the regulatory body responsible for overseeing compliance with the Data Privacy Act of 2012 in the Philippines.