top77 Privacy Policy

The data controller responsible for your personal information processed through the top77 platform is the legal entity holding the PAGCOR online gaming license under which top77.vu is operated (hereinafter "top77," "the Operator," "we," or "us"). As Data Controller, top77 determines the purposes and means of processing personal data collected through the platform, in accordance with the Republic Act No. 10173 (Data Privacy Act of 2012), its Implementing Rules and Regulations, and applicable PAGCOR data governance directives.

top77 has designated a Data Protection Officer (DPO) as required under Philippine law. The DPO is responsible for ensuring compliance with RA 10173, handling data subject requests, managing data breach protocols, and liaising with the National Privacy Commission (NPC) where required. Contact details for the DPO are provided in Section 14 of this Policy.

top77 collects the following categories of personal data in connection with the registration, operation, and maintenance of your account:

top77 collects personal data through the following means:

• Direct Submission: Information you provide when registering an account, completing KYC identity verification, submitting a deposit or withdrawal request, or contacting customer support;
• Automated Collection: Technical data collected automatically when you access the platform, including IP address, device identifiers, browser type, operating system, and session activity logs generated by platform cookies and analytics tools;
• Payment Providers: Transaction confirmation data received from GCash, Maya, and Philippine bank payment APIs when you fund or withdraw from your account — limited to transaction reference numbers, amounts, and timestamps;
• Third-Party Verification Services: Identity verification data returned by KYC processing services engaged by top77 to validate government ID documents against authoritative databases, in compliance with PAGCOR AML requirements;
• Responsible Gaming Interactions: Self-reported information submitted when setting deposit limits, requesting cooling-off periods, or initiating self-exclusion through the account dashboard.

top77 processes personal data on the following legal bases as recognised under the Data Privacy Act of 2012 (RA 10173):

• Contractual Necessity: Processing of identity, contact, financial, and gameplay data is necessary for the performance of the user agreement between top77 and the registered Player, including account management, game provision, and payment processing;
• Legal Obligation: top77 is subject to mandatory data processing obligations under PAGCOR's licensing conditions, the Anti-Money Laundering Act (AMLA), and RA 10173 itself, including KYC retention requirements and suspicious transaction reporting;
• Legitimate Interests: Technical data collection for platform security, fraud prevention, and responsible gaming monitoring constitutes a legitimate interest of the Operator, balanced against Player privacy rights;
• Consent: Marketing communications and promotional notifications are sent only to Players who have explicitly opted in to receiving such communications. Consent may be withdrawn at any time through account settings.

top77 uses collected personal data for the following specific purposes:

• Creating, managing, and maintaining your top77 Account and verifying your identity during registration and KYC processes;
• Processing deposits, withdrawals, and internal account balance adjustments through Philippine payment channels including GCash and Maya;
• Detecting and preventing fraud, money laundering, account takeovers, and bonus abuse through transaction monitoring and behavioral analysis;
• Monitoring gameplay patterns to identify responsible gaming concerns and to enforce self-imposed limits set by the Player;
• Providing customer support, including responding to account queries, resolving disputes, and processing responsible gaming requests;
• Meeting PAGCOR reporting obligations, including suspicious transaction reporting to the Anti-Money Laundering Council (AMLC);
• Sending account-related security alerts, transaction confirmations, and system notifications — these communications are not optional;
• Sending promotional communications, bonus offers, and VIP program updates to Players who have provided explicit opt-in consent;
• Improving platform performance, game lobby experience, and mobile optimisation through anonymised usage analytics.

top77 does not sell, rent, or trade personal data to third parties for commercial or marketing purposes. Data is shared only in the limited circumstances described below:

6.1 Service Providers

top77 engages third-party service providers who process data on our behalf under contractual data processing agreements that impose equivalent privacy obligations. These include KYC verification providers, payment gateway operators, game software providers (such as JILI Games and PG Soft), cloud infrastructure providers, and customer support platform operators. Service providers are permitted to use personal data solely for the purposes of delivering their contracted services to top77.

6.2 Regulatory and Legal Disclosure

top77 is legally obligated to disclose personal and transaction data to PAGCOR and the Anti-Money Laundering Council (AMLC) as required under its gaming license and AMLA obligations. top77 will also disclose data in response to valid court orders, warrants, or other lawful requests from Philippine law enforcement authorities, and in connection with the prevention, investigation, or prosecution of fraud or financial crime.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of the Operator's business assets, Player personal data may be transferred to the successor entity. Players will be notified of any such transfer that materially affects the processing of their personal data, and the successor entity will be bound by the privacy obligations in this Policy.

top77 retains personal data for the minimum period necessary to fulfil the purposes described in this Policy, subject to mandatory retention obligations under Philippine law:

Upon expiry of the applicable retention period, personal data is permanently deleted or anonymised so that it can no longer be associated with an identifiable individual.

top77 implements technical and organisational security measures designed to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS Encryption: All data transmitted between your browser and top77's servers is encrypted using industry-standard TLS protocols — the same standard applied by Philippine banks including BPI and BDO;
• Password Hashing: Passwords are never stored in plaintext. top77 uses cryptographic hashing with salting to store credentials, so even internal personnel cannot access your raw password;
• Two-Factor Authentication (2FA): Optional but available to all account holders. Enabling 2FA adds a second layer of protection against unauthorized access;
• Access Controls: Personal data is accessible only to top77 personnel and authorised service providers on a strict need-to-know basis, enforced through role-based access controls;
• Intrusion Detection: Automated systems monitor for unusual login patterns, failed authentication attempts, and suspicious transaction sequences in real time;
• Regular Security Audits: top77 conducts periodic security assessments to identify and remediate vulnerabilities in its platform infrastructure and data handling processes.

Notwithstanding these measures, no online platform can guarantee absolute security. In the event of a personal data breach that affects your rights and freedoms, top77 will notify affected individuals and the National Privacy Commission (NPC) within seventy-two (72) hours of discovery, in accordance with RA 10173 breach notification requirements.

top77 uses cookies and similar tracking technologies to operate the platform, maintain your session, and improve your experience. Cookies are small text files stored in your browser when you visit top77.vu.

9.1 Types of Cookies Used

• Essential Cookies: Required for core platform functionality including session authentication and security token management. These cannot be disabled without preventing access to the platform;
• Functional Cookies: Store your preferences such as language settings, game lobby display options, and responsible gaming reminder frequencies;
• Analytics Cookies: Collect anonymised data about platform usage patterns — including most-visited game categories and session durations — to improve platform performance. These do not identify individual users;
• Security Cookies: Support fraud prevention and login anomaly detection by recognising trusted devices and flagging new access points for verification.

9.2 Cookie Control

Non-essential cookies may be declined or cleared through your browser settings. Most modern browsers — including Chrome on Android (widely used by Filipino mobile users) and Safari on iPhone — provide granular cookie controls under Settings > Privacy. Disabling non-essential cookies will not affect your ability to access your account or play games on top77.

Under the Data Privacy Act of 2012 (RA 10173), Philippine residents hold the following rights with respect to their personal data processed by top77:

top77 is strictly prohibited from collecting personal data from or providing services to individuals under the age of 21 years, in compliance with PAGCOR's online gaming regulations. This age threshold is enforced through mandatory age declaration during registration and identity verification through KYC.

top77 does not knowingly collect or process personal data relating to individuals under 21. In the event that top77 discovers an account was registered by a person under 21, the account will be closed immediately, all balances forfeited, and the personal data of the minor deleted to the extent not required for regulatory reporting or law enforcement purposes.

Parents or guardians who believe their child under 21 has registered on top77 should contact our Data Protection Officer immediately at the contact details provided in Section 14. We will investigate and act within 24 hours of a credible report.

top77's primary data processing infrastructure is operated within and for the Philippine market. However, certain service providers engaged by top77 — including game software providers, cloud infrastructure operators, and KYC verification services — may process data on servers located outside the Philippines.

Where personal data is transferred outside the Philippines, top77 ensures that such transfers are conducted in accordance with Section 21 of RA 10173, which requires that the recipient country or organisation provides an adequate level of data protection comparable to Philippine standards, or that appropriate contractual safeguards are in place through data processing agreements. top77 will not transfer personal data to jurisdictions lacking adequate data protection frameworks without implementing appropriate safeguards.

top77 reserves the right to update this Privacy Policy from time to time to reflect changes in law, regulatory requirements, or platform operations. Material changes will be communicated to registered Players via a prominent notice on the platform at least fourteen (14) days before the amended Policy takes effect.

Continued use of the top77 platform following the effective date of a revised Privacy Policy constitutes acceptance of the updated terms. The date at the top of this document reflects the most recent version. Players who do not accept the revised Policy should cease using the platform and contact support to initiate account closure and data deletion requests.

For all privacy-related enquiries, data subject rights requests, or to report a potential privacy concern, contact top77's Data Protection Officer through the following channels. Note that the email address is provided as plain text in accordance with platform policy — it is not a clickable link.

• Data Protection Officer: Designated DPO, top77 Casino
• Email: [email protected] — Please include "Privacy Request" in the subject line
• Live Chat: Available 24/7 via your account dashboard — select "Privacy & Data" from the support menu
• Response Time: Acknowledgement within 72 hours; resolution within 15 business days

If you are not satisfied with top77's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) through their official complaint process. The NPC is the independent government body responsible for administering and enforcing RA 10173.