top 77 Privacy Policy

top 77, accessible at top77.lat, is a PAGCOR-licensed online casino and sports betting platform operated for Filipino players. top 77 recognizes that your personal data is yours, and that how we handle it is a matter of trust, not just legal compliance.

This Privacy Policy ("Policy") describes how top 77 ("top 77", "we", "us", "our") collects, processes, stores, shares, and protects the personal information of registered players, visitors, and all individuals who interact with the top 77 platform, whether through the website at top77.lat, customer support channels, or payment processing interfaces.

This Policy is prepared in compliance with the Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC) of the Philippines. It also reflects the data handling requirements applicable to PAGCOR-licensed gaming operators.

For the purposes of the Philippine Data Privacy Act of 2012 and applicable PAGCOR regulations, top 77 is the personal information controller with respect to all personal data collected through the top 77 platform.

top 77 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy, responding to data subject access requests, and serving as the point of contact for the National Privacy Commission. The DPO may be contacted at the details provided in Section 15 of this Policy.

Where third-party service providers process personal data on behalf of top 77 — for example, payment processors, game providers, or identity verification services — those parties act as personal information processors under the DPA and are bound by data processing agreements that require them to handle your data in accordance with this Policy and applicable Philippine law.

top 77 collects personal data through several channels: account registration, identity verification (KYC), payment transactions, gameplay activity, platform navigation, and communications with our support team. The following table summarizes the categories of personal data we collect and the primary context in which each is collected.

Under the Philippine Data Privacy Act of 2012, top 77 processes your personal data under one or more of the following lawful bases:

• Contractual Necessity: Processing is necessary for the performance of the contract between top 77 and the player — specifically, the account agreement established upon registration. This includes account management, payment processing, and game result recording.
• Legal Obligation: Processing is required to comply with applicable Philippine law, including PAGCOR licensing requirements, Anti-Money Laundering Act obligations (Republic Act No. 9160, as amended), and National Privacy Commission reporting requirements.
• Legitimate Interests: Processing is necessary for the legitimate interests of top 77, including fraud detection and prevention, platform security, responsible gaming monitoring, and improving platform functionality — provided such interests are not overridden by the privacy rights of the data subject.
• Consent: Where top 77 processes personal data for marketing or optional communications purposes, we rely on the player's freely given, specific, and informed consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

top 77 uses the personal data described in Section 3 for the following purposes:

To create, maintain, and administer your top 77 account, including processing registration, managing account settings, applying tier upgrades, and facilitating account closures. Your identity data and contact data are central to this purpose.

To process deposits made via GCash, PayMaya, BPI, BDO, Metrobank, InstaPay, Visa, and Mastercard, and to execute withdrawal payments to verified accounts. Financial data is used exclusively for payment processing and must match the identity established through KYC verification.

To verify that you are who you say you are and that you meet the 21+ age requirement mandated by PAGCOR. KYC is also required under the Anti-Money Laundering Act to prevent the use of the platform for financial crimes. Identity documents submitted during KYC are processed securely and retained only as required by applicable law and PAGCOR regulations.

Technical data, including IP addresses, device identifiers, and login patterns, are analyzed to detect unauthorized account access, identify fraudulent behavior, and prevent the abuse of bonuses or promotional offers.

Gameplay data is monitored to support top 77's responsible gaming obligations under PAGCOR licensing. This includes detecting potential problem gambling patterns and, where appropriate, proactively contacting players or applying protective account measures.

Communications data is used to respond to support enquiries, resolve disputes, and maintain records of interactions for quality assurance purposes.

Where you have provided consent, contact data and marketing preferences are used to send promotional offers, bonus notifications, and platform updates. You may opt out of marketing communications at any time by contacting support.

top 77 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. Your data may be shared in the following limited circumstances:

• PAGCOR: As a PAGCOR-licensed operator, top 77 is required to provide regulatory reports and player data to PAGCOR upon request or as mandated by our licensing conditions. This includes age verification outcomes, responsible gaming incidents, and financial transaction data.
• Payment Processors: Financial data is shared with certified payment processors — including GCash, PayMaya, BPI, BDO, and Metrobank — solely to the extent necessary to process your deposit and withdrawal transactions. These providers are bound by their own data privacy obligations under Philippine law.
• Game Providers: Gameplay data may be shared with certified game providers (such as Evolution Gaming, Pragmatic Play, and others whose titles are available on the platform) to the extent required to operate the relevant games, resolve disputes, and comply with provider audit requirements.
• Identity Verification Services: Identity document images and biometric data submitted for KYC may be processed by certified third-party identity verification service providers engaged by top 77. These providers operate under strict data processing agreements.
• Law Enforcement & Regulatory Authorities: top 77 may disclose personal data to the National Bureau of Investigation (NBI), Philippine National Police (PNP), Anti-Money Laundering Council (AMLC), or other competent Philippine authorities where required by law, court order, or regulatory direction.
• Legal Proceedings: Personal data may be disclosed to legal counsel and courts in connection with the establishment, exercise, or defense of legal claims.

top 77 retains personal data only for as long as is necessary to fulfill the purpose for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Account Data: Retained for the duration of the account relationship and for a period of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and applicable Philippine statute of limitations for civil claims.
• KYC and Identity Documents: Retained for a minimum of five (5) years following the completion of the identity verification process, as required by the Anti-Money Laundering Act and PAGCOR AML compliance guidelines.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLC and applicable BSP regulations.
• Gameplay Records: Retained for a period of three (3) years from the date of the gameplay session, for the purpose of dispute resolution and responsible gaming analysis.
• Marketing Data: Retained until you withdraw your marketing consent or for a period of two (2) years following your last interaction with a marketing communication, whichever is earlier.
• Communications and Support Data: Retained for a period of two (2) years from the date of the last communication, for quality assurance and dispute resolution purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in a manner that prevents reconstruction of the original data.

top 77 implements technical, organizational, and administrative security measures designed to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption in Transit: All data transmitted between your browser or device and the top 77 platform is encrypted using 256-bit SSL/TLS technology. This applies to login credentials, payment data, and all personal information submitted through the platform.
• Encryption at Rest: Personal data stored in top 77 databases is encrypted at rest. Sensitive fields, including passwords and financial data, are stored using industry-standard cryptographic hashing or encryption methods.
• Access Controls: Access to personal data within top 77's systems is restricted on a role-based, need-to-know basis. Staff members are granted the minimum level of data access necessary to perform their job functions. All access is logged and subject to regular review.
• Two-Factor Authentication: Player accounts are protected by SMS-based two-factor authentication on new device logins, reducing the risk of unauthorized account access even where credentials are compromised.
• Security Audits: top 77 conducts regular internal and third-party security assessments of its platform infrastructure, data storage systems, and access controls.
• Incident Response: top 77 maintains a documented data breach response plan. In the event of a personal data breach that poses a risk to player rights, top 77 will notify the National Privacy Commission and affected data subjects in accordance with the requirements of the DPA and NPC Circular No. 16-03.

The top 77 platform uses cookies and similar tracking technologies to support platform functionality, maintain session security, and analyze aggregate usage patterns. top 77 does not use third-party behavioral advertising cookies or sell browsing data to advertising networks.

• Essential Cookies: Required for core platform functionality, including maintaining your login session, managing your cart/wallet state, and enabling security features such as two-factor authentication. These cookies cannot be disabled without affecting platform functionality.
• Analytics Cookies: Used to collect aggregate, anonymized data about how players navigate the top 77 platform — which pages are visited most frequently, how long sessions last, and where technical errors occur. This data is used solely to improve platform performance and user experience.
• Fraud Detection Cookies: Used to identify unusual browsing patterns, detect multiple account registrations from the same device, and flag potentially fraudulent activity for security review.
• Preference Cookies: Used to remember your language preferences and other platform settings between sessions.

You may manage cookie preferences through your browser settings. Disabling essential cookies will affect platform functionality, including the ability to remain logged in to your top 77 account.

Under the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, top 77 players have the following data subject rights with respect to their personal data:

To exercise any of these rights, please submit a written request to the top 77 Data Protection Officer at the contact details provided in Section 15. We will respond to all valid requests within fifteen (15) business days. We may require you to verify your identity before processing certain requests.

top 77 may send promotional communications — including bonus offers, reload promotions, tournament notifications, and platform updates — to players who have provided consent to receive such communications during or after the account registration process.

• Marketing communications are sent via email and SMS to the contact details registered on your account.
• You may withdraw your consent to receive marketing communications at any time by contacting top 77 support or by following the unsubscribe instructions included in email communications.
• Withdrawal of marketing consent will not affect the delivery of transactional communications — such as deposit confirmations, withdrawal notifications, and security alerts — which are sent as a necessary part of platform operation regardless of marketing consent status.
• top 77 does not engage in unsolicited cold outreach or share player contact details with third-party marketers for their independent use.

Age verification is conducted as part of the KYC process required before a player's first withdrawal. Where top 77 discovers that personal data has been collected from an individual who is under 21 years of age, we will immediately suspend the relevant account, void any gameplay activity, and delete the personal data of the minor in accordance with the DPA, subject to any overriding legal obligation to retain records for regulatory purposes.

Parents and guardians who believe a minor under their care has registered for a top 77 account should contact our support team immediately. top 77 takes underage gaming seriously and will take all available steps to address such situations promptly.

top 77's primary data processing infrastructure is located within the Philippines. Certain personal data may be processed by certified third-party service providers whose servers are located outside the Philippines — for example, game providers or cloud infrastructure providers operating regional data centers in Southeast Asia.

Where personal data is transferred outside the Philippines, top 77 ensures that appropriate safeguards are in place to protect the data to a standard equivalent to that required under the Philippine Data Privacy Act. Such safeguards may include contractual data processing agreements incorporating the NPC's standard contractual clauses, or a determination that the recipient country offers an adequate level of data protection recognized by the NPC.

top 77 reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, new legal or regulatory requirements, or improvements to our platform. Any material changes to this Policy will be communicated to registered players via email or platform notification prior to the changes taking effect.

The updated Policy will be published on this page with a revised effective date. Continued use of the top 77 platform following the publication of an updated Policy constitutes your acceptance of the revised terms. If you do not agree to any material change in the Policy, you should cease using the platform and request account closure by contacting support.

We encourage players to review this Policy periodically to stay informed of how their personal data is handled.

If you have any questions about this Privacy Policy, wish to exercise any of your data subject rights, or wish to raise a concern about the handling of your personal data, please contact top 77 as follows:

For complaints not satisfactorily resolved through top 77's internal process, you may escalate your concern to the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official government website.