top77fn Privacy Policy

1. Introduction

1.1 This Privacy Policy ("Policy") is issued by top77fn ("we", "us", "our", or "the Platform") and applies to all personal data collected from individuals who register, visit, or use the top77fn website and online gaming services at top77fn.club.

1.2 top77fn is a PAGCOR-regulated online casino and sports betting platform serving Filipino players across the Philippines, including Metro Manila, Cebu, Davao, Cagayan de Oro, Iloilo, and all other regions. Our commitment to data privacy is embedded in the operational standards required by PAGCOR and by Philippine national law.

1.3 By registering on or using the top77fn platform, you acknowledge that you have read and understood this Policy and that you consent to the collection, use, and processing of your personal data as described herein. If you do not consent, please do not register or continue to use the platform.

1.4 This Policy should be read alongside our Terms and Conditions. In the event of any conflict between this Policy and the Terms, the Terms shall prevail to the extent of the inconsistency.

2. Data Controller

2.1 For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, top77fn acts as the personal information controller ("PIC") with respect to personal data collected from registered players and platform visitors.

2.2 top77fn has appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with applicable data privacy laws. Players may contact the DPO directly for privacy-related queries, access requests, or complaints at the contact details provided in Section 13 of this Policy.

3. Categories of Personal Data We Collect

3.1 top77fn collects the following categories of personal data in connection with the operation of its regulated gaming platform:

3.2 top77fn does not collect sensitive personal information as defined under the Data Privacy Act (e.g., health records, political affiliations, or religious beliefs) unless specifically required for regulatory compliance purposes and with explicit consent.

4. How We Collect Your Personal Data

4.1 top77fn collects personal data through the following means:

• Registration: When you create a top77fn account, you provide identity, contact, and age verification data directly.
• Account Usage: Gaming activity, transaction history, and responsible gaming tool interactions are recorded automatically as you use the platform.
• Identity Verification: When you submit government-issued ID documents for KYC (Know Your Customer) verification, we collect and process the data contained therein.
• Payment Processing: When you deposit or withdraw via GCash, PayMaya, BPI, BDO, Metrobank, or cryptocurrency, financial data is collected as part of the transaction process.
• Customer Support: When you contact our support team via live chat or email, we collect the content of your communications and any personal data you include.
• Cookies and Tracking: Technical data is collected automatically via cookies and similar tracking technologies as described in Section 8.
• Third-Party Sources: In some cases, we may receive data from payment providers, identity verification services, or regulatory databases in connection with our compliance obligations.

5. Purpose and Legal Basis for Processing

5.1 top77fn processes personal data for the following purposes and on the following legal bases:

• Account Management: To create, maintain, verify, and manage your top77fn player account. Legal basis: performance of contract.
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency. Legal basis: performance of contract; compliance with financial regulations.
• Regulatory Compliance: To fulfil obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws. Legal basis: legal obligation.
• Age and Identity Verification: To confirm that all players are at least 21 years of age and are who they claim to be. Legal basis: legal obligation; legitimate interest.
• Fraud Prevention and Platform Security: To detect and prevent fraudulent activity, multi-accounting, bonus abuse, and money laundering. Legal basis: legitimate interest; legal obligation.
• Responsible Gaming: To monitor gaming behaviour, enforce player-set limits, and identify players who may be at risk of problem gambling. Legal basis: legal obligation; legitimate interest.
• Customer Support: To respond to your queries, resolve disputes, and improve service quality. Legal basis: performance of contract; legitimate interest.
• Platform Improvement: To analyse usage patterns and improve the top77fn platform, game offering, and user experience. Legal basis: legitimate interest.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates, where you have opted in to such communications. Legal basis: consent.

6. Data Sharing and Disclosure

6.1 top77fn may share your personal data with the following categories of third parties:

• PAGCOR and Philippine Regulatory Authorities: We are obligated to report certain data to PAGCOR and, where required by law, to the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other government bodies.
• Payment Providers: GCash, PayMaya, BPI, BDO, Metrobank, and cryptocurrency processors receive the financial data necessary to process your deposits and withdrawals. These providers are bound by their own privacy and security obligations.
• Game Providers: JILI Games, Pragmatic Play, PG Soft, and other licensed game providers may receive anonymised session data for game integrity and RNG audit purposes.
• Identity Verification Services: Third-party KYC service providers may process identity document data on behalf of top77fn to fulfil our age and identity verification obligations.
• IT and Platform Service Providers: Hosting providers, cloud services, and technical support vendors may have access to personal data in the course of providing services to top77fn. All such providers are bound by data processing agreements consistent with Philippine data privacy law.
• Legal Proceedings: top77fn may disclose personal data when required to do so by a valid court order, subpoena, or other legal process under Philippine law.

7. Data Retention

7.1 top77fn retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and Identity Data: Retained for the duration of the active account relationship and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLA record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years following each transaction, as required under the AMLA and PAGCOR regulations.
• Communications and Support Records: Retained for a minimum of two (2) years from the date of the communication.
• Gaming Activity Logs: Retained for a minimum of five (5) years following the date of the session, for audit and dispute resolution purposes.

7.2 Once the applicable retention period has expired and there is no legal basis for continued retention, top77fn will securely destroy or anonymise the personal data concerned.

8. Cookies and Tracking Technologies

8.1 top77fn uses cookies and similar tracking technologies to enhance your platform experience, maintain session continuity, analyse usage patterns, and support platform security functions.

8.2 Types of Cookies Used

• Strictly Necessary Cookies: Required for the platform to function. These cannot be disabled and do not require your consent.
• Functional Cookies: Remember your preferences (e.g., language settings, game display preferences) to improve your experience.
• Analytics Cookies: Collect anonymised data about how players use the platform to help us improve functionality and game selection.
• Security Cookies: Used to detect fraudulent activity and protect account integrity.

8.3 You may adjust your browser settings to refuse or delete non-essential cookies. Note that disabling certain cookies may affect platform functionality, including session management and game loading.

9. Data Security

9.1 top77fn implements industry-standard technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption for all data in transit between your browser and the top77fn platform;
• Encrypted storage of passwords and sensitive authentication credentials;
• Access controls restricting personal data access to authorised personnel only, on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for staff access to systems holding personal data;
• Incident response procedures for the detection, reporting, and management of personal data breaches.

9.2 In the event of a personal data breach that poses a risk to player rights and freedoms, top77fn will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the Data Privacy Act.

9.3 While top77fn employs robust security measures, no online platform can guarantee absolute security. Players are responsible for maintaining the confidentiality of their own account credentials and for notifying top77fn immediately of any suspected unauthorized access.

10. Your Data Privacy Rights

10.1 Under the Philippine Data Privacy Act of 2012, all top77fn players have the following rights with respect to their personal data:

10.2 To exercise any of the above rights, please contact top77fn's Data Protection Officer at the details in Section 13. We will respond to all verified requests within fifteen (15) business days of receipt. We may need to verify your identity before processing your request.

10.3 If you believe top77fn has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11. Minors

11.1 By registering on top77fn, you represent and warrant that you are at least 21 years of age. If you are aware that a minor has registered on or is using the platform, please notify us immediately at the contact details in Section 13.

12. Changes to This Privacy Policy

12.1 top77fn reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or platform practices. The revised Policy will be published on the platform with an updated effective date.

12.2 Where changes are material, top77fn will notify registered players via email or an on-platform notification at least seven (7) days before the revised Policy takes effect. Your continued use of the platform after the effective date constitutes acceptance of the updated Policy.

12.3 We encourage all players to review this Policy periodically to stay informed about how top77fn protects your personal data.

13. Contact Our Data Protection Officer

13.1 For any queries, access requests, rectification requests, or complaints related to your personal data and this Privacy Policy, please contact top77fn's Data Protection Officer:

This Privacy Policy was last updated in June 2026 and is governed by the laws of the Republic of the Philippines, including Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations.