Privacy Policy — top7777

top7777 ("top7777," "we," "us," or "the Company") is committed to protecting the personal data of all individuals who use the top7777 online gaming platform ("Platform"), accessible at top7777.co. This Privacy Policy ("Policy") explains how top7777 collects, processes, stores, and protects the personal information of registered players and visitors to the Platform.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC") of the Philippines. It also takes into account the data-related obligations imposed by the Philippine Amusement and Gaming Corporation ("PAGCOR") on licensed online gaming operators.

This Policy applies to all personal data collected through the top7777 Platform, including data collected during account registration, KYC verification, deposit and withdrawal transactions, game play, customer support interactions, marketing communications, and general Platform use.

For the purposes of the Data Privacy Act of 2012, the data controller responsible for your personal information is top7777, operating the online gaming platform at top7777.co under the applicable PAGCOR licensing framework.

top7777 has designated a Data Privacy Officer ("DPO") responsible for overseeing compliance with this Policy and the DPA. The DPO can be contacted through the customer support channels described in Section 14 of this Policy. Any privacy-related request, complaint, or inquiry should be directed to the DPO in the first instance.

Where top7777 engages third-party service providers that process personal data on its behalf (such as game providers or payment processors), those parties act as data processors and are contractually bound to process personal data only on top7777's documented instructions and in compliance with applicable privacy law.

top7777 collects the following categories of personal data from players and Platform visitors:

top7777 does not intentionally collect or process sensitive personal information beyond what is strictly required for KYC compliance and responsible gaming obligations (such as self-exclusion records). Where sensitive data is processed, this is done under a valid lawful basis as described in Section 5 of this Policy.

top7777 collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or responding to surveys and promotions;
• Automated collection: Technical data collected automatically when you access the Platform, including IP addresses, device identifiers, browser information, and session data via cookies and similar tracking technologies (see Section 8);
• Third-party sources: Identity verification data from KYC service providers; fraud screening information from risk management partners; payment confirmation data from GCash, PayMaya, and banking institutions.

top7777 does not purchase personal data from data brokers or marketing list providers. All personal data processed by top7777 is collected either directly from you or from service providers engaged specifically to support the operation of your top7777 account.

top7777 processes personal data only where a valid lawful basis exists under the Data Privacy Act of 2012. The lawful bases relied upon are as follows:

• Contractual necessity: Processing necessary to perform the contract represented by these Terms and Conditions — for example, operating your account, processing deposits and withdrawals, and providing access to games;
• Legal obligation: Processing required to comply with applicable Philippine law, including the Anti-Money Laundering Act (Republic Act No. 9160, as amended), PAGCOR regulations, and NPC requirements;
• Legitimate interests: Processing for fraud prevention, Platform security, responsible gaming monitoring, and service improvement, where these interests do not override your rights and freedoms;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

top7777 uses the personal data it collects for the following specific purposes:

• Creating, verifying, and managing your top7777 player account;
• Conducting KYC identity and age verification as required by PAGCOR and Philippine AML law;
• Processing deposits from GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank;
• Processing and verifying withdrawal requests to ensure funds are returned to the verified account holder;
• Providing and personalising the gaming experience, including game recommendations and lobby display preferences;
• Detecting, investigating, and preventing fraudulent activity, money laundering, and other prohibited conduct;
• Operating responsible gaming tools, including deposit limits, session timers, cooling-off periods, and self-exclusion management;
• Providing customer support via live chat, email, and other communication channels;
• Sending transactional communications such as deposit confirmations, withdrawal notifications, account security alerts, and KYC status updates;
• Sending promotional communications about top7777 bonuses and offers, where you have consented or where top7777 has a legitimate interest in doing so;
• Complying with requests or orders from PAGCOR, the Anti-Money Laundering Council (AMLC), the NPC, or other competent Philippine regulatory authorities;
• Improving the Platform through analysis of aggregated, anonymised usage data.

top7777 does not use your personal data to make fully automated decisions that produce significant legal effects without human oversight, except where this is permitted or required by applicable law.

top7777 does not sell, rent, or trade your personal data to any third party for commercial purposes. Personal data is shared only in the following circumstances and only to the extent necessary:

• Game providers: JILI Gaming, PG Soft, Pragmatic Play, Evolution Gaming, and other licensed game studios receive limited player data (such as player session tokens and currency) necessary to operate games and display game history. These providers are contractually obligated to process this data only for game delivery purposes;
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and UnionBank receive transaction data necessary to process deposits and withdrawals. These institutions are independently regulated under Philippine financial law;
• KYC and identity verification providers: Third-party KYC service providers may receive copies of government ID documents and selfie images for the purpose of identity verification. These providers operate under data processing agreements with top7777;
• Regulatory authorities: PAGCOR, the AMLC, the NPC, and law enforcement agencies may receive personal data where top7777 is legally required to disclose it, including in response to lawful orders, AML reporting obligations, or regulatory investigations;
• Professional advisers: Lawyers, auditors, and accountants engaged by top7777 may receive limited personal data where necessary to provide their professional services, subject to confidentiality obligations;
• Business transfers: In the event of a merger, acquisition, or transfer of top7777's business or assets, player personal data may be transferred to the acquiring entity, which will be required to honour this Privacy Policy.

top7777 uses cookies and similar tracking technologies to operate the Platform, maintain session continuity, enhance security, and improve the user experience. The following types of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and cookies that remember your login state. These cannot be disabled without breaking Platform functionality;
• Functional cookies: Used to remember your preferences, such as language settings and display preferences, to personalise your experience across sessions;
• Analytical cookies: Collect aggregated, anonymised data about how players use the Platform — pages visited, game categories accessed, session duration — to help top7777 understand usage patterns and improve the Platform;
• Security cookies: Used to detect and mitigate fraud, bot activity, and account takeover attempts.

Where cookies are not strictly necessary for Platform operation, top7777 will seek your consent via the cookie notice displayed on your first visit to the Platform. You may modify your cookie preferences at any time through your browser settings. Note that disabling certain cookies may affect Platform functionality, including the ability to remain logged in.

top7777 does not use third-party advertising cookies or share cookie data with advertising networks.

top7777 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the top7777 Platform;
• AES-256 encryption for sensitive personal data stored in top7777's databases;
• Role-based access controls ensuring that only authorised top7777 personnel can access personal data, and only to the extent required for their specific function;
• Multi-factor authentication requirements for all internal top7777 systems that handle personal data;
• Regular security audits, penetration testing, and vulnerability assessments conducted by qualified third-party security specialists;
• A formal incident response plan covering detection, containment, notification, and remediation of personal data breaches.

In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, top7777 will notify affected players and the National Privacy Commission as required by the Data Privacy Act and NPC rules on data breach notification.

top7777 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by law. The key retention periods are as follows:

• Account and KYC data: Retained for a minimum of 5 years after the date of account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act;
• Financial transaction data: Retained for a minimum of 5 years from the date of each transaction, and potentially longer where required by AMLC reporting obligations or ongoing investigation;
• Gaming session data: Retained for a minimum of 2 years from the date of each session for dispute resolution purposes;
• Customer support communications: Retained for 3 years from the date of the last communication, for quality assurance and dispute resolution purposes;
• Marketing consent records: Retained for the duration of your account and for 2 years after account closure, to evidence consent given or withdrawn;
• Cookie and technical data: Session cookies expire at the end of each session. Persistent cookies expire in accordance with their individual settings, typically between 30 days and 12 months.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with top7777's data disposal procedures, unless retention is required by an ongoing legal, regulatory, or dispute resolution process.

Under the Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to the personal data held about you by top7777. To exercise any of these rights, please contact top7777's Data Privacy Officer through the channels described in Section 14:

• Right to be Informed: The right to know whether top7777 processes your personal data and, if so, the details of that processing — as set out in this Policy;
• Right of Access: The right to obtain confirmation of what personal data top7777 holds about you and to receive a copy of that data in a structured format;
• Right to Correction: The right to have inaccurate, incomplete, or outdated personal data corrected or updated;
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected and no legal obligation requires its continued retention;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to Block: The right to suspend or block the processing of your personal data pending investigation of a correction or erasure request;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to request its transmission to another data controller where technically feasible;
• Right to Damages: The right to claim compensation for damages suffered as a result of top7777's failure to comply with the Data Privacy Act.

top7777 will respond to all verified data subject rights requests within 15 business days of receipt. We may request proof of identity before processing certain requests to prevent fraudulent access to another person's data.

Please note that certain rights are subject to limitations under applicable law — for example, erasure requests may be declined where retention is required by AML or PAGCOR record-keeping obligations.

The top7777 Platform is strictly restricted to persons aged 21 years or older, as required by Philippine gaming regulations. top7777 does not knowingly collect personal data from persons under the age of 21.

If top7777 discovers or is notified that personal data has been collected from a person under the age of 21, it will immediately suspend the associated account, erase the personal data collected from that person to the extent permitted by law, and take appropriate steps under PAGCOR regulations.

Age is verified as part of the mandatory KYC process. Providing false age information during registration constitutes fraud and may result in referral to the relevant authorities in addition to permanent account suspension.

Parents or guardians who believe that a minor may have registered an account with top7777 should contact customer support immediately with the relevant account details.

top7777 reserves the right to update or revise this Privacy Policy at any time in response to changes in applicable Philippine law, NPC guidance, PAGCOR regulatory requirements, or top7777's data processing practices.

Material changes to this Policy — for example, changes to the categories of data collected, the purposes for which data is processed, or the third parties with whom data is shared — will be communicated to registered players via their registered email address or through a prominent in-Platform notification. Non-material changes, such as typographical corrections or clarifications, will be reflected in the updated Policy without specific notification.

The "Last Updated" date at the top of this Policy indicates the date of the most recent revision. Your continued use of the top7777 Platform after any revision constitutes acceptance of the updated Policy. If you do not agree to any change, you should contact customer support to close your account.

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a complaint about the way top7777 processes your personal data, please contact top7777's Data Privacy Officer through the following channels:

• Live Chat: Available 24/7 through the top7777 Platform — this is the fastest channel for all support and privacy queries;
• Email: The top7777 support email displayed in the Platform footer (plain text — not a clickable link).

Privacy-related requests and complaints will be acknowledged within 3 business days and fully addressed within 15 business days. If your complaint relates to a data breach or urgent security matter, please clearly mark it as urgent and top7777 will prioritise the response.

If you are not satisfied with top7777's response to your privacy complaint, you have the right to lodge a complaint with the National Privacy Commission of the Philippines, which is the independent regulatory authority responsible for overseeing compliance with the Data Privacy Act of 2012. Information about how to file a complaint with the NPC is publicly available from the NPC.