top77fn
Privacy Policy

1. Introduction

top77fn ("we", "us", "our", "the Platform") is committed to protecting and respecting the privacy of every person who uses its services. This Privacy Policy ("Policy") applies to all personal data collected, processed, and stored by top77fn in connection with the operation of the top77fn.vip website and all associated gaming, betting, and account services (collectively, the "Services").

This Policy is intended to inform you — our players and site visitors — about what personal data we collect, why we collect it, how we use it, who we may share it with, and what rights you have in relation to it. It complements, and should be read alongside, our Terms & Conditions and Responsible Gaming Policy.

By accessing or using top77fn, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree, you should discontinue use of the Platform immediately.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for personal data processed through top77fn is the legal entity that operates the top77fn.vip platform under the PAGCOR-regulated Philippine online gaming framework.

All data subject requests, privacy inquiries, and formal complaints regarding top77fn's data practices should be directed to the Platform's designated Data Protection Officer (DPO) using the contact information set out in Section 16 of this Policy.

Where top77fn engages third-party service providers who process personal data on our behalf, such providers act as data processors and are contractually bound to process personal data only on top77fn's documented instructions and in compliance with applicable data protection law.

3. What Personal Data We Collect

top77fn collects personal data that is necessary and proportionate to the purposes described in this Policy. The categories of personal data we collect include:

4. How We Collect Your Data

top77fn collects personal data through the following methods:

• Directly from you: When you register an account, complete KYC verification, make deposits or withdrawals, contact support, or participate in promotions.
• Automatically: Through cookies, session tracking technology, and server log files as you interact with the top77fn Platform. See Section 8 for full details on cookies.
• From payment providers: When you transact using GCash, Maya, BPI, BDO, UnionBank, or other linked payment methods, relevant transaction confirmation data is received by top77fn from those providers.
• From identity verification services: Where top77fn engages third-party KYC verification providers to validate identification documents submitted during account verification.
• From regulatory sources: In certain circumstances, top77fn may receive data from PAGCOR, the Anti-Money Laundering Council (AMLC), or other regulatory bodies in connection with compliance obligations.

5. Purposes of Processing

top77fn processes personal data for the following specific, legitimate purposes:

• Account management: Creating, maintaining, verifying, and securing player accounts on the top77fn platform.
• Age and identity verification: Confirming that all players meet the 21+ minimum age requirement mandated by PAGCOR regulations before permitting access to real-money gaming.
• Payment processing: Facilitating GCash, Maya, bank transfers, and other payment transactions associated with deposits and withdrawals.
• Anti-money laundering compliance: Monitoring transactions and account activity as required by the Anti-Money Laundering Act (RA 9160) and PAGCOR anti-financial crime directives.
• Customer support: Responding to inquiries, resolving disputes, and providing assistance across live chat and email channels.
• Platform security: Detecting and preventing fraud, account takeovers, collusion, bot activity, and other prohibited conduct.
• Responsible gaming: Monitoring gameplay patterns to identify potential problem gambling indicators and administering player-requested limits, cooling-off periods, and self-exclusions.
• Promotions and marketing: Where you have consented to receive marketing communications, sending offers, promotions, and platform updates relevant to your account. See Section 14 for opt-out information.
• Legal and regulatory compliance: Meeting obligations imposed by PAGCOR, the NPC, the AMLC, and other applicable Philippine regulatory bodies.
• Platform improvement: Using aggregated, anonymised usage data to improve game selection, interface design, and overall platform performance.

6. Legal Bases for Processing

Under the Philippine Data Privacy Act, top77fn's processing of your personal data is based on one or more of the following lawful bases:

7. Data Sharing & Disclosure

top77fn does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly as necessary for the purposes described in this Policy:

• Payment service providers: GCash (Mynt), Maya, BPI, BDO, UnionBank, and other payment processors, for the purpose of executing deposits and withdrawal transactions. These providers act as independent data controllers for their own KYC and AML obligations.
• KYC and identity verification providers: Specialist third-party services contracted to verify the authenticity of identification documents submitted by players. These providers process data solely on top77fn's instructions.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council, the National Privacy Commission, the National Bureau of Investigation, and other competent Philippine government bodies, where disclosure is required by law or court order.
• Game software providers: Game studios and platform providers whose certified games are integrated into top77fn. These providers may receive session-level data (e.g., game round IDs) for technical operation and audit purposes. They do not receive full player identity data.
• Fraud prevention services: Third-party tools used to detect bot activity, collusion, and account fraud. Data shared is limited to what is necessary for fraud signal analysis.
• Professional advisers: Legal counsel, auditors, and compliance consultants, under binding confidentiality obligations.

8. Cookies & Tracking Technologies

top77fn uses cookies and similar tracking technologies to operate the Platform, remember your preferences, maintain session security, and analyse site usage. A cookie is a small text file stored on your device by your browser when you access the Platform.

You may manage cookie preferences through your browser settings. Disabling cookies beyond essential cookies may affect the functionality and security of the top77fn Platform. top77fn does not use third-party advertising network cookies for behavioural advertising purposes without your consent.

9. Data Retention

top77fn retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for a minimum of five (5) years following permanent account closure, as required by PAGCOR regulatory requirements and anti-money laundering legislation.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in accordance with AMLC record-keeping requirements.
• KYC verification documents: Retained for the duration of the account's existence plus five (5) years post-closure.
• Customer support communications: Retained for three (3) years from the date of the communication, or longer where relevant to an unresolved dispute or regulatory inquiry.
• Technical and usage logs: Retained for up to twelve (12) months for security and fraud monitoring purposes, after which they are anonymised or deleted.
• Marketing consent records: Retained for as long as your consent remains active and for one (1) year following withdrawal of consent, to demonstrate compliance with consent obligations.

Upon expiry of the applicable retention period, top77fn will securely destroy or anonymise personal data in accordance with its data disposal procedures.

10. Data Security

top77fn implements appropriate technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Industry-standard 256-bit SSL/TLS encryption for all data transmitted between your device and top77fn servers.
• Segregated storage of player financial data and identity documents in secured, access-controlled environments.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Multi-factor authentication requirements for all internal system access by top77fn personnel.
• Regular security audits and vulnerability assessments conducted by qualified information security professionals.
• Incident response procedures aligned with NPC breach notification requirements under the Data Privacy Act.

In the event of a personal data breach that poses a real risk of serious harm to affected data subjects, top77fn 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, as required by NPC regulations.

11. Your Data Subject Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by top77fn:

To exercise any of the rights above, please contact top77fn's Data Protection Officer using the contact details in Section 16. We may require you to verify your identity before processing any request.

12. Children's Privacy

top77fn's Services are strictly for persons who are 21 years of age or older, in compliance with PAGCOR's minimum age requirement for online gaming in the Philippines. top77fn does not knowingly collect, process, or retain personal data from individuals below this age.

If top77fn becomes aware that an account has been registered by a person under 21 years of age, the account will be immediately suspended, all associated personal data will be reviewed, and the account will be permanently closed. Any data collected from an underage individual that is not required to be retained for legal or regulatory purposes will be securely deleted.

If you believe a minor under 21 has registered a top77fn account, please contact our support team or DPO immediately at the email address in Section 16.

13. International Data Transfers

Some of top77fn's third-party service providers — including game software providers, certain KYC verification services, and cloud infrastructure providers — may process personal data outside of the Philippines. Where personal data is transferred internationally, top77fn ensures that appropriate safeguards are in place, including:

• Contractual clauses that impose data protection obligations on the recipient consistent with Philippine DPA standards.
• Transfers only to jurisdictions that the NPC has determined offer an adequate level of data protection, where applicable.
• Case-by-case assessment of data transfer risks and implementation of supplementary safeguards where required.

Information about specific international transfers may be requested from top77fn's DPO. top77fn will not transfer personal data internationally where doing so would violate applicable Philippine data protection law or NPC guidance.

14. Marketing Communications

Where you have consented to receive marketing communications from top77fn, we may contact you via SMS to your registered Philippine mobile number, email, or in-Platform notifications to inform you of promotions, bonuses, new games, and platform updates relevant to your account.

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

• Clicking the "unsubscribe" link included in all marketing emails sent by top77fn.
• Updating your notification and communication preferences in the top77fn account settings panel.
• Contacting top77fn support with a written request to opt out of all marketing communications.

Withdrawal of marketing consent will be processed within 10 business days. Note that withdrawing marketing consent does not affect service communications — top77fn will continue to send transactional notifications (e.g., deposit confirmations, withdrawal processing notifications, security alerts) that are necessary for the operation of your account, regardless of marketing preferences.

15. Changes to This Policy

top77fn reserves the right to update or modify this Privacy Policy at any time. Material changes — those that significantly affect how we collect, use, or share your personal data — will be communicated to registered players via email to the address on file and/or via a prominent notice on the top77fn Platform prior to the change taking effect.

The date of the most recent revision is displayed at the top of this Policy ("Last Updated"). Continued use of the top77fn Platform following the effective date of any updated Policy constitutes acceptance of the revised terms. If you do not accept the revised Policy, you must cease using the Platform and may request account closure in accordance with the process described in the Terms & Conditions.

We encourage players to review this Privacy Policy periodically to stay informed about how top77fn is protecting their personal data.

16. Contact & Data Protection Officer

For all privacy-related inquiries, data subject rights requests, concerns about this Policy, or to reach top77fn's designated Data Protection Officer, please use the following contact:

top77fn takes all privacy inquiries seriously. If you are not satisfied with our response to a privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.