PRIVACY POLICY

1. INFORMATION WE COLLECT

1.1 Personal Information Provided by You

When you register an account with 777ny, we collect personal information that you voluntarily provide to us, including but not limited to:

• Identity Information: Full legal name as it appears on government-issued identification, date of birth, nationality, and government-issued ID numbers when required for verification purposes.
• Contact Information: Residential address in the Philippines, email address, mobile phone number, and any alternative contact details you provide.
• Account Credentials: Username, password (stored in encrypted form), security questions and answers, and two-factor authentication settings.
• Financial Information: Payment method details including GCash mobile number, PayMaya account information, bank account numbers (BPI, BDO, UnionBank, Metrobank), cryptocurrency wallet addresses, and transaction history.
• Verification Documents: Copies of government-issued photo identification (passport, driver's license, Philippine national ID), proof of address documents (utility bills, bank statements), and proof of payment method ownership as required for Know Your Customer (KYC) compliance.
• Communication Records: Content of messages exchanged with our customer support team via live chat, email, Viber, Facebook Messenger, or other communication channels.

1.2 Information Automatically Collected

When you access or use the 777ny Platform, we automatically collect certain technical and usage information, including:

• Device Information: Device type, model, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), and mobile network information (Globe, Smart, DITO).
• Connection Information: IP address, geographic location data, internet service provider, connection speed, and network type (WiFi, mobile data).
• Usage Data: Pages visited, time spent on each page, games played, bets placed, deposit and withdrawal transactions, login timestamps, clickstream data, and navigation patterns within the Platform.
• Technical Data: Browser cookies, pixel tags, web beacons, local storage data, cache information, and similar tracking technologies used to enhance user experience and Platform functionality.

1.3 Information from Third-Party Sources

We may receive additional information about you from third-party sources to verify your identity, prevent fraud, and comply with regulatory obligations, including data from payment processors (GCash, PayMaya, banks), identity verification services, credit reference agencies where legally permitted, publicly available databases, and regulatory authorities in the Philippines.

2. HOW WE USE YOUR INFORMATION

777ny collects and processes your personal information for the following legitimate purposes:

3. LEGAL BASIS FOR PROCESSING

777ny processes your personal data based on the following legal grounds under Philippine data protection law and international privacy standards:

• Contractual Necessity: Processing is necessary to perform our contract with you, including account creation, game provision, transaction processing, and service delivery.
• Legal Obligations: Processing is required to comply with Philippine laws, gaming regulations, anti-money laundering requirements, tax reporting, and other regulatory mandates.
• Legitimate Interests: Processing serves our legitimate business interests in fraud prevention, security maintenance, platform improvement, and business analytics, balanced against your privacy rights.
• Consent: For marketing communications and certain data uses, we rely on your explicit consent, which you may withdraw at any time through account settings or by contacting customer support.

4. INFORMATION SHARING AND DISCLOSURE

777ny does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with the following categories of recipients under strict confidentiality obligations:

• Payment Processors: GCash, PayMaya, banks (BPI, BDO, UnionBank, Metrobank), cryptocurrency payment providers, and other financial institutions necessary to process your deposits and withdrawals.
• Identity Verification Services: Third-party KYC providers that verify your identity, age, and address to ensure compliance with Philippine regulations and prevent underage gambling.
• Game Providers: Software developers and game studios (JILI, Pragmatic Play, Evolution Gaming, etc.) whose games you access through our Platform, receiving only necessary technical data.
• Technology Service Providers: Cloud hosting providers, data storage facilities, cybersecurity firms, analytics platforms, and technical support services that help operate and maintain the 777ny Platform.
• Customer Support Tools: Live chat software providers, ticketing systems, and communication platforms used to deliver customer service.
• Regulatory Authorities: Philippine gaming regulators, anti-money laundering authorities, tax agencies, law enforcement, and courts when legally required or compelled by valid legal process.
• Professional Advisors: Lawyers, accountants, auditors, and consultants who provide professional services to 777ny under strict confidentiality agreements.
• Business Transfers: In the event of merger, acquisition, sale of assets, or bankruptcy, your information may be transferred to the acquiring entity or successor company.

All third-party service providers are contractually obligated to maintain the confidentiality and security of your personal information and may only use it for the specific purposes for which it was disclosed. We conduct due diligence on all partners to ensure they meet our data protection standards.

5. DATA SECURITY MEASURES

777ny implements comprehensive technical, administrative, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security framework includes:

• Encryption: All data transmission between your device and our servers is protected by 256-bit SSL/TLS encryption—the same standard used by Philippine banks. Passwords are stored using industry-standard hashing algorithms with salting.
• Access Controls: Employee access to personal data is restricted on a need-to-know basis. Our staff undergoes mandatory background checks, confidentiality agreements, and regular data security training.
• Firewalls and Intrusion Detection: Multi-layered firewalls, intrusion detection systems, and continuous network monitoring protect our infrastructure from unauthorized access and cyber attacks.
• Regular Security Audits: We conduct quarterly penetration testing, annual third-party security audits, and continuous vulnerability scanning to identify and address potential security gaps.
• Secure Servers: Data is stored on secure, dedicated servers with redundant backups, disaster recovery protocols, and 24/7 physical and digital surveillance.
• Payment Security: Financial transactions comply with PCI DSS (Payment Card Industry Data Security Standard) requirements and are processed through certified payment gateways.
• Incident Response: We maintain a documented incident response plan to quickly detect, investigate, and remediate any security breaches or data incidents, with notification procedures where legally required.

While we implement robust security measures, no system is 100% secure. We cannot guarantee absolute security of your information transmitted over the internet. You acknowledge the inherent risks and agree to hold 777ny harmless for unauthorized access despite our reasonable security efforts.

6. DATA RETENTION AND STORAGE

777ny retains your personal information for the duration necessary to fulfill the purposes for which it was collected and to comply with legal obligations. Retention periods vary by data type:

• Account Information: Retained for the entire duration of your account and for 3 years after account closure for regulatory and audit purposes.
• Transaction Records: Financial records and transaction history are retained for 5 years in accordance with Philippine tax and banking regulations.
• Identity Verification Documents: KYC and identity verification data are retained for 5 years after final transaction or account closure, as required by anti-money laundering regulations.
• Communications: Customer support communications are retained for 2 years after final interaction for dispute resolution and service quality purposes.
• Marketing Data: Email and phone numbers for marketing purposes are retained until you unsubscribe or withdraw consent.
• Technical/Usage Data: Log files and technical usage data are retained for 6-12 months for security monitoring and system optimization.
• Promotional Data: Information about promotional offers and bonuses is retained for 2 years to calculate return customer bonuses and prevent bonus abuse.

After the retention period expires, your information is securely deleted or anonymized unless further retention is required by law. You may request deletion of personal information not subject to legal retention requirements by contacting our support team.

7. YOUR PRIVACY RIGHTS

Under Philippine data protection law and international privacy standards, you have the following rights regarding your personal information:

• Right to Access: You have the right to request a copy of all personal information we hold about you. We will provide this information in a readable format within 30 days of your request.
• Right to Correction: You may request correction of inaccurate, incomplete, or outdated personal information. We will update your records within 10 business days where practical.
• Right to Erasure (Right to be Forgotten): You may request deletion of your personal information, except where retention is required for legal, regulatory, or contractual purposes. We will respond within 30 days of your request.
• Right to Restrict Processing: You may request that we limit our use of your personal information for specific purposes or in certain circumstances. We will honor reasonable requests while maintaining service functionality.
• Right to Data Portability: You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit it to another service provider.
• Right to Object: You may object to processing of your personal information for direct marketing, profiling, or other non-essential purposes. We will respect your objection within 30 days.
• Right to Withdraw Consent: For processing based on your consent (such as marketing communications), you may withdraw consent at any time. This does not affect processing done prior to withdrawal.
• Right to Lodge a Complaint: If you believe we have violated your privacy rights, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC).

To exercise any of these rights, contact our Privacy Officer at [email protected] with details of your request. We will verify your identity and respond within 30 days. Some requests may incur reasonable administrative costs which we will disclose in advance.

8. COOKIES AND TRACKING TECHNOLOGIES

777ny uses cookies, web beacons, pixel tags, and similar technologies to enhance your user experience, track Platform performance, and analyze user behavior. Types of cookies we use include:

• Essential Cookies: Required for Platform functionality including session management, security, load balancing, and form validation. Cannot be disabled without compromising service functionality.
• Performance Cookies: Collect anonymous data on how users interact with the Platform, including pages visited, features used, and technical performance metrics. Used to optimize Platform speed and usability.
• Functional Cookies: Enable personalization features such as language preferences, account login state, favorite games, and customized user interface settings.
• Marketing Cookies: Used to deliver targeted promotional content and track the effectiveness of marketing campaigns. Only set with your explicit consent.

Most browsers allow you to control or disable cookies through settings. However, disabling cookies may affect Platform functionality. For detailed information on cookie management and your choices, visit www.allaboutcookies.org or your browser's help section. You can withdraw cookie consent at any time through account privacy settings.

9. THIRD-PARTY SERVICES

777ny integrates with third-party services including game providers, payment processors, analytics tools, and customer support platforms. When you use these integrated services through our Platform, you may be subject to their privacy policies. We are not responsible for the privacy practices of third-party services. Review their privacy policies before providing additional personal information directly to them. Third-party services may place their own cookies and tracking technologies on your device as permitted by their privacy policies.

10. CHILDREN'S PRIVACY

The 777ny Platform is not intended for users under 21 years of age. We strictly prohibit account creation, access, and use by minors. We do not knowingly collect personal information from individuals under 21. If we become aware that we have collected information from someone under 21, we will immediately delete such information and close any associated accounts. If you have concerns about a minor accessing our Platform, contact us immediately at [email protected].

11. INTERNATIONAL DATA TRANSFERS

777ny operates primarily in the Philippines and stores most user data on servers located in the Philippines or Southeast Asia. However, we may transfer personal information to other countries for payment processing, customer support, or data backup purposes. Such transfers are made only to countries with adequate data protection standards or under appropriate safeguards including standard contractual clauses and adequacy decisions. By using our Platform, you consent to such international transfers as necessary for service delivery.

12. POLICY UPDATES

777ny may update this Privacy Policy periodically to reflect changes in our data practices, technology improvements, legal developments, or regulatory requirements. Material changes will be notified to you through email, prominent Platform notification, or both at least 30 days before the changes become effective. Your continued use of our Platform following the effective date of updated terms constitutes acceptance of the revised Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your information.

13. CONTACT INFORMATION

For questions about this Privacy Policy, to exercise your privacy rights, or to report a privacy concern, please contact 777ny's Privacy Officer:

• Email: [email protected]
• Support Email: [email protected]
• Live Chat: Available 24/7 on Platform
• Viber/Messenger: @777ny
• Mailing Address: 777ny Casino Philippines, Manila, Philippines

Response to privacy inquiries is typically provided within 5-7 business days. For unresolved privacy concerns, you may escalate your complaint to the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.