ll777ph Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") describes how ll777ph ("ll777ph," "we," "us," or "our") collects, uses, stores, discloses, and otherwise processes personal data in connection with your use of the ll777ph online gaming platform available at ll777ph.org (the "Platform").

ll777ph is committed to protecting the privacy and personal data of all users of the Platform, including registered players, visitors, and prospective players. This Policy applies to all personal data processed by ll777ph in connection with the Platform, regardless of the device or method used to access it.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC"). It should be read together with our Terms & Conditions and Responsible Gaming Policy.

By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, please do not use the Platform.

2. Data Controller Information

ll777ph acts as the personal information controller ("PIC") in respect of the personal data collected through the Platform. As PIC, ll777ph determines the purposes and means of processing your personal data.

ll777ph operates under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to applicable Philippine data protection and anti-money laundering laws.

For all data privacy enquiries, requests, and complaints, you may contact our designated Data Protection Officer (DPO) using the contact details set out in Section 14 of this Policy.

3. Personal Data We Collect

ll777ph collects the following categories of personal data from players and Platform users:

ll777ph does not collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect information relating to your health, political opinions, religious beliefs, or sexual orientation.

4. How We Collect Your Data

ll777ph collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated collection: Technical and usage data collected automatically through cookies, log files, and similar tracking technologies when you access and use the Platform (see Section 6);
• Third-party sources: Identity verification data from accredited KYC service providers; fraud and AML screening data from compliance databases; payment data from GCash, Maya, and banking partners in connection with your transactions.

ll777ph will always inform you at the point of collection if providing certain personal data is mandatory (e.g., for KYC compliance) or optional. Failure to provide mandatory data may prevent ll777ph from providing certain services, including processing withdrawals.

5. Purposes and Legal Bases for Processing

ll777ph processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Performance of a contract: Processing necessary to register your account, operate your ll777ph player account, process deposits and withdrawals, and provide the gaming services you have requested;
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, Anti-Money Laundering Act (AMLA) obligations, Bureau of Internal Revenue (BIR) reporting requirements, and other applicable Philippine laws and regulations;
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving the ll777ph Platform — where such interests are not overridden by your rights and freedoms;
• Consent: Processing for direct marketing communications and non-essential cookies, where you have given your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

ll777ph will not process your personal data for purposes incompatible with those stated in this Policy without first obtaining your consent or establishing another lawful basis for processing.

6. Cookies and Tracking Technologies

6.1 What Are Cookies. Cookies are small text files placed on your device when you visit the ll777ph Platform. They allow the Platform to recognise your device, remember your preferences, and collect information about how you use the Platform.

6.2 Types of Cookies We Use. ll777ph uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and login details to improve your experience on ll777ph.
• Analytics cookies: Collect anonymised information about how players use the Platform, helping ll777ph understand which features are most popular and where improvements can be made.
• Marketing cookies: Used to deliver relevant promotional content about ll777ph. These are only placed with your consent.

6.3 Managing Cookies. You can control and manage cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the ll777ph Platform. Strictly necessary cookies cannot be disabled as they are essential for the Platform to operate securely.

7. Sharing and Disclosure of Personal Data

ll777ph does not sell, rent, or trade your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and other Philippine government agencies where required by law;
• Payment service providers: GCash, PayMaya / Maya, and partner banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) solely for the purpose of processing your deposits and withdrawals;
• KYC and compliance providers: Accredited identity verification and AML screening service providers engaged by ll777ph to fulfil its regulatory obligations;
• Technology service providers: Cloud hosting, platform infrastructure, and cybersecurity providers who process data on behalf of ll777ph under strict data processing agreements;
• Game software providers: Licensed game studios and aggregators whose games are available on the ll777ph Platform, to the extent necessary for game operation and dispute resolution;
• Professional advisers: Lawyers, auditors, and accountants where necessary for legal, compliance, or financial purposes, subject to professional confidentiality obligations.

All third parties with whom ll777ph shares personal data are required to process such data in accordance with applicable Philippine data protection law and are prohibited from using your data for their own independent purposes.

8. International Data Transfers

8.1 Cross-Border Transfers. Some of ll777ph's service providers and game software partners may be located outside the Philippines. Where personal data is transferred to recipients in other countries, ll777ph ensures that appropriate safeguards are in place to protect your data in accordance with the DPA and NPC regulations on cross-border data flows.

8.2 Safeguards. Safeguards for international transfers may include:

• Contractual clauses approved by the NPC or equivalent data protection authority;
• Transfers to countries recognised as providing an adequate level of data protection;
• Binding corporate rules where applicable within corporate groups.

8.3 Your Rights. You may request information about the safeguards in place for any specific international transfer of your personal data by contacting our Data Protection Officer.

9. Data Retention

9.1 Retention Periods. ll777ph retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

9.2 Specific Retention Periods. As a general guide:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with PAGCOR licensing conditions and AMLA requirements;
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA and BIR regulations;
• Communications and support data: Retained for three (3) years from the date of the communication;
• Technical and usage data: Retained for up to twelve (12) months from collection, unless required for longer periods for security or legal purposes;
• Marketing consent records: Retained for the duration of your consent and for three (3) years thereafter as evidence of consent.

9.3 Secure Deletion. When personal data is no longer required, ll777ph will securely delete or anonymise it in accordance with industry best practices and NPC guidelines.

10. Security Measures

ll777ph implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption: AES-256 encryption for data at rest; TLS 1.2 or higher for data in transit between your device and the ll777ph Platform;
• Access controls: Role-based access controls ensuring that only authorised ll777ph personnel can access personal data, on a strict need-to-know basis;
• Two-factor authentication: Available for all player accounts and mandatory for ll777ph administrative systems;
• Penetration testing: Regular third-party security assessments and penetration tests of the ll777ph Platform infrastructure;
• Incident response: A documented data breach response plan with defined escalation procedures and NPC notification protocols;
• Staff training: Regular data privacy and security training for all ll777ph personnel who handle personal data.

While ll777ph takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for maintaining the security of your ll777ph account credentials. If you suspect that your account has been compromised, contact ll777ph support immediately via live chat.

11. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ll777ph. To exercise any of these rights, contact our Data Protection Officer using the details in Section 14.

ll777ph will respond to all data subject requests within fifteen (15) business days of receipt. In complex cases, this period may be extended by a further fifteen (15) business days, with prior notice to you. ll777ph reserves the right to verify your identity before processing any data subject request.

12. Children and Minors

The ll777ph Platform is strictly intended for persons aged 21 years and above, in compliance with PAGCOR regulations and Philippine gaming law. ll777ph does not knowingly collect personal data from persons under the age of 21.

If ll777ph becomes aware that personal data has been collected from a person under the age of 21, it will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered on the ll777ph Platform, please notify us immediately via live chat or by contacting our Data Protection Officer.

ll777ph employs age verification procedures during the registration and KYC process to prevent underage access to the Platform. These procedures include verification of government-issued identification documents confirming date of birth.

13. Changes to This Privacy Policy

13.1 Right to Amend. ll777ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. The date of the most recent revision is indicated at the top of this page.

13.2 Notification of Changes. Where changes to this Policy are material, ll777ph will notify registered players by posting a prominent notice on the Platform and, where practicable, by sending a notification to your registered email address. We encourage you to review this Policy periodically.

13.3 Continued Use. Your continued use of the ll777ph Platform following the effective date of any amendment to this Policy constitutes your acknowledgement of the updated Policy. If you do not agree with the amended Policy, you should cease using the Platform and contact our Data Protection Officer to close your account.

14. Contact and Data Protection Officer

For all data privacy enquiries, requests to exercise your data subject rights, or complaints regarding ll777ph's handling of your personal data, please contact our designated Data Protection Officer:

ll777ph aims to acknowledge all data privacy requests within three (3) business days and to resolve them within fifteen (15) business days. If you are not satisfied with ll777ph's response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.

For general support enquiries unrelated to data privacy, please contact: [email protected]