top77fn Privacy
& Data Policy

1 Introduction

top77fn ("we," "us," "our," or the "Company") is committed to protecting the privacy and personal data of all users ("you," "your," or the "User") who access and use the top77fn website and services (collectively, the "Platform"). This Privacy Policy explains how we collect, use, store, share, and protect your personal information in connection with your use of the Platform.

This Privacy Policy is governed by and construed in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission (NPC). By registering an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

2 Information We Collect

top77fn collects personal data that is necessary to provide you with a safe, secure, and personalized gaming experience. The categories of personal data we collect include:

2.1 Registration and Account Data

• Full legal name, date of birth, and gender
• Email address, mobile number, and residential address (including city, province, and postal code)
• Username and encrypted password
• Government-issued identification documents (for KYC verification)
• Selfie or photo verification (where required for identity confirmation)

2.2 Financial and Transaction Data

• GCash or PayMaya account details (mobile number only; we do not store PINs or passwords)
• Bank account details for BPI, BDO, Metrobank, UnionBank, and other Philippine banks
• Deposit and withdrawal transaction history
• Betting history, game activity, and wagering records
• Bonus and promotion usage records

2.3 Technical and Usage Data

• IP address, device type, operating system, and browser type
• Session duration, pages visited, and features used
• Cookies and similar tracking technologies (see Section 8)
• Geolocation data (to verify you are accessing from the Philippines)
• Login timestamps and access logs

2.4 Communications Data

• Customer support chat logs and email correspondence
• Survey responses and feedback submissions
• Promotional opt-in preferences

3 How We Use Your Information

top77fn processes your personal data only for legitimate purposes directly related to the provision of our services. The specific purposes for which we use your data include:

• Account Management: To create, maintain, and manage your top77fn account, including identity verification and KYC compliance.
• Service Delivery: To process deposits, withdrawals, bets, and game transactions on the Platform.
• Legal Compliance: To comply with Philippine anti-money laundering (AML) laws, PAGCOR regulations, and other applicable legal obligations.
• Fraud Prevention: To detect, investigate, and prevent fraudulent activity, cheating, and unauthorized account access.
• Responsible Gaming: To monitor gaming behavior and enforce responsible gaming tools such as deposit limits and self-exclusion.
• Customer Support: To respond to your inquiries, complaints, and support requests in a timely and effective manner.
• Platform Improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the Platform.
• Marketing Communications: To send you promotional offers, bonuses, and updates — only if you have opted in to receive such communications.

4 Data Sharing and Disclosure

top77fn does not sell, rent, or trade your personal data to third parties for commercial purposes. We may, however, share your data with trusted third parties in the following limited circumstances:

• Payment Processors: GCash, PayMaya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank) to process financial transactions. These providers are bound by their own privacy policies and applicable Philippine financial regulations.
• Identity Verification Providers: Third-party KYC and identity verification services used to confirm your identity and comply with AML regulations.
• Game Software Providers: Licensed game developers and software providers who supply the games available on the Platform. These providers may receive anonymized gameplay data for technical purposes.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or court order.
• Fraud Prevention Services: Third-party fraud detection and cybersecurity providers who assist us in protecting the Platform and its users.
• Professional Advisors: Legal counsel, auditors, and accountants, subject to strict confidentiality obligations.

5 Data Security

top77fn implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security infrastructure includes:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers
• AES-256 encryption for sensitive data stored in our databases
• Multi-factor authentication (MFA) options for account access
• Regular security audits and penetration testing by independent cybersecurity firms
• Strict access controls limiting employee access to personal data on a need-to-know basis
• 24/7 intrusion detection and monitoring systems
• Secure data centers with physical access controls

While we take every reasonable precaution to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect any unauthorized access to your account.

6 Data Retention

top77fn retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine laws and regulations. Our general data retention periods are as follows:

• Account Data: Retained for the duration of your account and for a period of five (5) years after account closure, as required by Philippine AML regulations.
• Transaction Records: Retained for a minimum of five (5) years in compliance with the Anti-Money Laundering Act (AMLA) and PAGCOR requirements.
• KYC Documents: Retained for five (5) years after the end of the business relationship, or longer if required by law.
• Customer Support Records: Retained for two (2) years from the date of the last interaction.
• Marketing Preferences: Retained until you withdraw your consent or request deletion.
• Technical Logs: Retained for up to twelve (12) months for security and fraud prevention purposes.

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

7 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by top77fn:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed.
• Right of Access: You may request a copy of the personal data we hold about you at any time.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: You may request deletion of your personal data, subject to our legal retention obligations.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time.
• Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

8 Cookies and Tracking Technologies

top77fn uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The types of cookies we use include:

• Essential Cookies: Required for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that prevent fraudulent use of your account. These cannot be disabled.
• Analytics Cookies: Used to collect anonymized data about how users interact with the Platform, helping us improve performance and user experience.
• Preference Cookies: Used to remember your settings and preferences, such as language and display options.
• Security Cookies: Used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. By continuing to use the Platform, you consent to our use of cookies as described in this section.

9 Children's Privacy

The top77fn Platform is strictly intended for users who are 21 years of age or older, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21.

10 Changes to This Privacy Policy

top77fn reserves the right to update or modify this Privacy Policy at any time. Any changes will be effective immediately upon posting the revised policy to the Platform. We will notify registered users of material changes via email or a prominent notice on the Platform.

Your continued use of the Platform after the posting of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this policy periodically to stay informed about how we protect your personal data.

11 Contact Us and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our Data Protection Officer (DPO):

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated. The NPC can be reached through their official government channels.