un77 Privacy Policy

01 Introduction

This Privacy Policy ("Policy") describes how un77 ("the Platform", "we", "us", "our") collects, processes, stores, and protects personal data relating to individuals ("Players", "you", "your") who access or use the un77 online gaming platform at un77.biz ("the Platform").

This Policy is issued in compliance with applicable data protection laws and regulations, including the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. By registering an account on un77 or otherwise 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.

This Policy should be read in conjunction with the un77 Terms and Conditions. Capitalised terms not defined in this Policy have the meanings given to them in the Terms and Conditions.

02 Data Controller

For the purposes of applicable data protection law, un77 is the data controller responsible for the personal data of Players on the Platform. As data controller, un77 determines the purposes and means of processing your personal data.

un77's designated Data Protection Officer ("DPO") is responsible for overseeing compliance with this Policy and applicable data protection law. You may contact the DPO directly with any data protection queries or complaints at the contact details provided in Section 14 of this Policy.

03 Personal Data We Collect

un77 collects personal data from Players through a number of channels, including account registration forms, KYC verification submissions, payment transactions, customer support interactions, and automated technical collection methods. The categories of personal data we collect are described in the table below:

un77 does not intentionally collect special categories of personal data (such as health data, political opinions, or biometric data used for identification) unless explicitly required for regulatory compliance and with your express consent.

04 How We Use Your Personal Data

un77 processes your personal data for the following purposes:

• Account Management: To create, maintain, and administer your un77 account, including processing your registration, verifying your login credentials, and managing your account settings;
• Identity Verification (KYC): To verify that you are who you claim to be, that you meet the minimum age requirement of 21 years, and that your account is not being used for fraudulent or illegal purposes;
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods, and to maintain accurate transaction records;
• Game Delivery: To deliver the games and services you request, maintain your game session continuity, and resolve disputes regarding game outcomes;
• Regulatory Compliance: To comply with PAGCOR guidelines, the Philippine Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable laws and regulations, including retaining records as required by law;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, money laundering, account abuse, and other prohibited activities on the Platform;
• Responsible Gaming: To monitor gaming patterns for signs of problem gambling and to apply responsible gaming tools (deposit limits, session limits, self-exclusion) as configured by you or as required by our responsible gaming obligations;
• Customer Support: To respond to your queries, complaints, and support requests;
• Platform Improvement: To analyse aggregated, anonymised usage data to improve the performance, security, and user experience of the un77 Platform;
• Communications: To send you account-related notifications (transaction confirmations, security alerts, policy updates) via SMS or email to your registered contact details.

05 Legal Basis for Processing

un77 processes your personal data on the following legal bases under applicable data protection law:

• Contractual Necessity: Processing that is necessary to perform the contract between you and un77 (i.e., the Terms and Conditions), including account management, payment processing, and game delivery;
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC/AML obligations under PAGCOR guidelines and the Philippine AMLA;
• Legitimate Interests: Processing for the legitimate interests of un77, including fraud prevention, platform security, and improving the quality of the Platform, provided these interests are not overridden by your fundamental rights and freedoms;
• Consent: Processing based on your freely given, specific, and informed consent — in particular, for marketing communications and the collection of certain optional data categories. You may withdraw your consent at any time without affecting the lawfulness of processing prior to withdrawal.

06 Data Sharing & Third-Party Disclosure

un77 does not sell, rent, or trade your personal data to unaffiliated third parties for their own marketing purposes. un77 shares your personal data only in the following limited circumstances:

• Game Providers: un77 shares session and account identifiers (but not full identity documents) with licensed third-party game providers to deliver games on the Platform. These providers are contractually bound to use such data only for the purpose of game delivery;
• Payment Processors: Financial data is shared with GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers solely for the purpose of processing your deposits and withdrawals. These providers are subject to their own data protection obligations;
• Regulatory and Law Enforcement Authorities: un77 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Philippine National Police (PNP), or other competent authorities when required to do so by law, court order, or regulatory instruction;
• Fraud Prevention Services: un77 may share technical data (IP addresses, device fingerprints) with fraud detection and cybersecurity service providers to protect the integrity of the Platform;
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or part of un77's business, your personal data may be transferred to the successor entity, subject to equivalent data protection standards.

Where un77 engages third-party data processors, we require them to implement appropriate technical and organisational security measures and to process your data only for the specified purpose and in accordance with our instructions.

07 Cookies & Tracking Technologies

un77 uses cookies and similar tracking technologies on the Platform to maintain session continuity, prevent fraud, and improve the user experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies, security tokens, and load-balancing cookies. They cannot be disabled without breaking Platform functionality;
• Functional Cookies: Used to remember your preferences (e.g., language settings, remembered login, game lobby layout) so you don't have to re-configure them on every visit;
• Analytics Cookies: Used to collect aggregated, anonymised data about how Players navigate and use the Platform, which helps un77 identify usability issues and improve the service. No individually identifiable data is shared with analytics providers;
• Security Cookies: Used to detect and prevent fraudulent login attempts, account takeovers, and bot activity.

Most modern browsers allow you to control cookie behaviour through browser settings. Disabling certain cookies may affect the functionality of the un77 Platform, including the ability to stay logged in across page navigations.

08 Data Retention

un77 retains personal data for no longer than is 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 your account and for a minimum of five (5) years following account closure, as required by PAGCOR's record-keeping guidelines and Philippine AMLA obligations;
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA and tax record-keeping requirements;
• Gaming Session Data: Retained for a minimum of three (3) years from the date of each session for dispute resolution and regulatory audit purposes;
• Customer Support Communications: Retained for two (2) years from the date of last interaction;
• Technical and Device Data: Retained for twelve (12) months from collection for security and fraud analysis purposes.

Following the expiry of the applicable retention period, un77 will securely delete or anonymise your personal data.

09 Data Security

Specific security measures implemented by un77 include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and un77's servers;
• Encryption of sensitive data (including passwords and KYC documents) at rest using AES-256 encryption;
• Role-based access controls limiting access to personal data to un77 personnel with a legitimate need;
• Multi-factor authentication requirements for all un77 staff accessing systems containing personal data;
• Regular penetration testing and security audits conducted by independent third-party security firms;
• Automated intrusion detection and anomaly monitoring systems operating continuously;
• A documented data breach response procedure, including notification to the National Privacy Commission (NPC) within seventy-two (72) hours of discovery of a reportable breach, and notification to affected Players without undue delay.

While un77 takes all reasonable steps to protect your personal data, no internet-based platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your un77 account credentials.

10 Your Data Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by un77:

• Right to be Informed: The right to be informed that your personal data is being collected and how it will be used — satisfied by this Privacy Policy;
• Right to Access: The right to request a copy of the personal data un77 holds about you, together with information about how it is being processed;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most of your account information directly through Account Settings; for changes requiring document verification (e.g., legal name or date of birth), contact support;
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to un77's legal obligations to retain certain records;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. To opt out of marketing communications, update your preferences in Account Settings;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format and to have it transmitted directly to another controller where technically feasible;
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of the above rights, contact un77's Data Protection Officer using the details in Section 14. un77 will respond to valid data rights requests within thirty (30) calendar days. Complex or high-volume requests may require additional time, in which case you will be notified of the expected response timeline.

11 Children's Privacy

12 International Data Transfers

Some of un77's service providers (including game providers, fraud detection systems, and cloud infrastructure providers) may be located outside of the Philippines. Where personal data is transferred outside the Philippines, un77 takes steps to ensure that equivalent data protection standards apply, including:

• Entering into data processing agreements with recipient service providers that incorporate data protection obligations equivalent to those under Philippine law;
• Transferring data only to service providers located in jurisdictions with adequate data protection frameworks;
• Applying additional technical safeguards (such as encryption) to data transferred internationally.

13 Amendments to This Policy

un77 reserves the right to update or amend this Privacy Policy at any time. Material changes — such as new categories of data being collected, new purposes of processing, or changes to data sharing practices — will be communicated to registered Players via SMS or email to the contact details on file at least fourteen (14) days before the changes take effect.

Non-material changes (such as formatting improvements or clarification of existing practices that do not alter their substance) may be made without prior notice. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Continued use of the un77 Platform after the effective date of any amendment constitutes acceptance of the updated Policy.

14 Contact, DPO & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by un77, please contact us through the following channels:

• Data Protection Officer (DPO): Reachable via the un77 support live chat, referencing "Data Protection / DPO Request" in your message;
• Live Chat: Available 24/7 on the un77 Platform. Average first response time: 3–5 minutes;
• Email (plain text — not a link): [email protected] — for formal data rights requests, include "DATA RIGHTS REQUEST" in your subject line;
• Support Hours: 24 hours a day, 7 days a week, Philippines Standard Time (PHT).

If you are not satisfied with un77's response to a data rights request or data protection complaint, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory authority responsible for enforcing the Data Privacy Act of 2012 in the Philippines.