ll77 Privacy Policy

This Privacy Policy ("Policy") describes how ll77 ("ll77," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "Player") who access or use the ll77 online gaming platform, website, and all associated services (collectively, the "Platform").

ll77 is committed to protecting the privacy and personal data of all Filipino players in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. Where applicable, ll77 also observes internationally recognised data protection principles.

By registering an account on ll77, accessing the Platform, or otherwise providing your personal information to ll77, you acknowledge that you have read and understood this Policy and consent to the collection, use, and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the ll77 Platform.

This Policy should be read together with ll77's Terms & Conditions and Responsible Gaming Policy, both of which form part of your overall agreement with ll77.

For the purposes of the Data Privacy Act of 2012 and this Policy, ll77 is the personal information controller in respect of all personal data collected through the Platform. ll77 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

ll77 has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. If you have any questions or concerns about how ll77 handles your personal data, you may contact the DPO using the details provided in Section 14 of this Policy.

ll77 collects the following categories of personal data from players and Platform visitors. We collect only what is necessary for the purposes described in this Policy.

3.1 Identity & Contact Data

3.2 Financial Data

3.3 Gaming & Behavioural Data

ll77 collects data about your activity on the Platform, including games played, wagers placed, wins and losses, session durations, responsible gaming tool usage, and bonus redemption history. This data is used to operate the Platform, detect fraud, and support responsible gaming obligations.

3.4 Technical Data

When you access the ll77 Platform, we automatically collect certain technical information, including your IP address, device type and operating system, browser type and version, referring URLs, and session timestamps. This data is used for security monitoring, fraud prevention, and Platform optimisation.

3.5 Communications Data

ll77 retains records of communications between you and ll77 support staff, including live chat transcripts, email correspondence, and any documents you submit in connection with a support request or complaint.

ll77 collects your personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in a promotion.
• Automated collection: Technical and behavioural data collected automatically as you use the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment confirmation data from payment processors such as GCash and PayMaya.
• Publicly available sources: In limited circumstances, ll77 may supplement your data with information from publicly available sources for the purposes of identity verification or fraud prevention.

ll77 uses your personal data for the following purposes:

Under the Data Privacy Act of 2012, ll77 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and ll77, including account management, transaction processing, and game operation.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, AML obligations, and tax reporting duties.
• Legitimate interests: Processing carried out for ll77's legitimate business interests, including fraud prevention, Platform security, and responsible gaming monitoring, where such interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, including the sending of direct marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

ll77 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. ll77 may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• KYC and identity verification providers: Third-party service providers engaged to verify your identity and age in compliance with regulatory requirements.
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other approved payment service providers, for the purpose of processing your deposits and withdrawals.
• AML and fraud screening providers: Compliance technology providers engaged to screen transactions and player activity for money laundering and fraud indicators.
• Game software providers: Third-party game developers and live casino operators whose games are available on the ll77 Platform, to the extent necessary to operate those games.
• Regulatory and law enforcement authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities, where disclosure is required by law or regulatory obligation.
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by ll77, subject to professional confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of all or part of ll77's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

ll77 retains your 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:

Upon expiry of the applicable retention period, ll77 will securely delete or anonymise your personal data in accordance with its data disposal procedures.

ll77 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS encryption: All data transmitted between your device and the ll77 Platform is encrypted using industry-standard SSL/TLS protocols.
• Data encryption at rest: Sensitive personal data stored on ll77 servers is encrypted using AES-256 or equivalent encryption standards.
• Access controls: Access to personal data is restricted to ll77 personnel and authorised third parties who have a legitimate need to access it, and is governed by role-based access control policies.
• Two-factor authentication: ll77 supports and encourages the use of two-factor authentication (2FA) for player accounts to reduce the risk of unauthorised access.
• Regular security audits: ll77 conducts regular security assessments, penetration testing, and vulnerability scans to identify and remediate potential security weaknesses.
• Incident response: ll77 maintains a data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, ll77 will notify the National Privacy Commission and affected players in accordance with the Data Privacy Act of 2012.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ll77. To exercise any of these rights, please contact ll77's Data Protection Officer using the details in Section 14.

ll77 will respond to all data rights requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty days, in which case ll77 will notify you of the extension and the reasons for it. ll77 will not charge a fee for handling data rights requests unless they are manifestly unfounded or excessive.

ll77 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit the ll77 website. The following categories of cookies are used:

You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the ll77 Platform. ll77 does not use cookies to serve third-party advertising.

The ll77 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. ll77 does not knowingly collect personal data from individuals under the age of 21. If ll77 becomes aware that personal data has been collected from a person under 21, it will immediately delete that data and close the associated account.

If you are a parent or guardian and believe that your child has provided personal data to ll77, please contact ll77's Data Protection Officer immediately using the contact details in Section 14 so that appropriate action can be taken without delay.

ll77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or ll77's data processing practices. The date of the most recent revision is always displayed at the top of this page.

Where changes to this Policy are material, ll77 will notify registered players by email or through a prominent notice on the Platform prior to the changes taking effect. Your continued use of the ll77 Platform following notification of any changes constitutes your acceptance of the revised Policy. If you do not agree with the revised Policy, you must cease using the Platform and may request account closure in accordance with ll77's Terms & Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or ll77's handling of your personal data, please contact ll77's Data Protection Officer. You may reach the DPO by email at: [email protected]

ll77 will acknowledge all privacy-related enquiries within five (5) business days and will endeavour to resolve them within thirty (30) calendar days. For complex matters, ll77 will keep you informed of progress throughout the resolution process.

If you are not satisfied with ll77's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012. Information about how to file a complaint with the NPC is available on the NPC's official website.