Privacy Policy

1. Overview

1.1 This Privacy Policy ("Policy") describes the privacy practices of n77 app ("we", "us", "our", "n77 app") with respect to personal data collected from users ("you", "Player", "User") of the online gaming platform accessible at n77app.app ("Platform").

1.2 n77 app is committed to compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) ("DPA"), its Implementing Rules and Regulations, and all issuances of the National Privacy Commission ("NPC"). Where applicable, n77 app also observes internationally recognised data protection standards consistent with the purpose of the DPA.

1.3 This Policy applies to all personal data processed by n77 app in connection with your use of the Platform, including account registration, financial transactions, gameplay, customer support interactions, and marketing communications.

1.4 This Policy should be read in conjunction with the n77 app Terms & Conditions, which govern your overall use of the Platform.

2. Personal Data We Collect

n77 app collects the following categories of personal data:

We do not collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and legal compliance purposes.

3. How We Collect Personal Data

3.1 Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a promotion.

3.2 Automatically — when you visit or interact with the Platform, we collect technical data via cookies, web beacons, server logs, and similar tracking technologies. See Section 10 for details on cookie use.

3.3 From third parties — we may receive data from payment processors (GCash, Maya, BPI), identity verification providers, fraud detection services, and regulatory authorities as part of our legal compliance and KYC obligations.

4. How We Use Your Personal Data

n77 app processes your personal data for the following purposes:

• Account Creation & Management — to register, authenticate, and maintain your n77 app account;
• Identity Verification (KYC) — to verify your identity, confirm your age (21+), and comply with AML obligations;
• Transaction Processing — to process PHP deposits and withdrawals via GCash, Maya, and supported Philippine banks;
• Gameplay & Gaming Services — to deliver, personalise, and record your gaming activity across all n77 app products;
• Customer Support — to respond to your enquiries, resolve disputes, and improve service quality;
• Fraud Prevention & Security — to detect, prevent, and investigate fraudulent activity, money laundering, and Terms violations;
• Responsible Gaming — to monitor for problem gambling indicators and enforce player-requested limits, cooling-off periods, and self-exclusion;
• Legal Compliance — to comply with obligations under the DPA, AMLA, and applicable PAGCOR regulatory requirements;
• Marketing Communications — to send you promotional offers, bonus notifications, and platform updates, where you have provided consent or where legitimate interest applies;
• Platform Improvement — to analyse usage patterns and improve the performance, features, and user experience of the n77 app Platform.

5. Legal Basis for Processing

5.1 n77 app processes your personal data on the following legal bases under the DPA:

• Contractual Necessity — processing required to perform our obligations under the Terms & Conditions, including account management and transaction processing;
• Legal Obligation — processing required to comply with applicable Philippine law, including KYC/AML obligations and regulatory reporting;
• Legitimate Interests — processing for fraud prevention, platform security, and service improvement, where our interests are not overridden by your data protection rights;
• Consent — processing for direct marketing communications, where we rely on your freely given, specific, informed, and unambiguous consent, which you may withdraw at any time.

6. Data Sharing & Disclosure

6.1 n77 app does not sell your personal data to third parties. We share data only as follows:

• Payment Processors — GCash, Maya, BPI, BDO, Metrobank, and other payment partners receive financial data necessary to process your transactions;
• Identity Verification Providers — third-party KYC and AML screening services receive identity data to verify your eligibility;
• Game Providers — game studios receive anonymised or pseudonymised session data necessary to deliver their games through the n77 app Platform;
• Regulatory & Law Enforcement Authorities — we disclose data as required by law, including to the NPC, PAGCOR, the Anti-Money Laundering Council (AMLC), and Philippine law enforcement agencies;
• IT & Infrastructure Providers — cloud hosting, cybersecurity, and technical support providers who process data on our behalf under contractual data processing agreements;
• Business Transfers — in the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity, subject to the same data protection commitments in this Policy.

6.2 All third-party recipients are required to implement appropriate technical and organisational measures to protect your personal data and to process it solely for the purposes specified by n77 app.

7. Data Retention

7.1 n77 app retains personal data for as long as necessary to fulfil the purposes described in this Policy, subject to the following minimum retention periods:

• Account & Transaction Records — retained for a minimum of five (5) years from account closure, in compliance with Philippine AML regulations;
• KYC & Identity Documents — retained for a minimum of five (5) years from the date of submission;
• Gaming & Bet Logs — retained for a minimum of three (3) years from the date of each transaction;
• Customer Support Records — retained for two (2) years from the date of resolution;
• Marketing Preferences — retained until you withdraw consent or request deletion.

7.2 Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised unless further retention is required by law or regulatory order.

8. Data Security

8.1 n77 app implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and the Platform;
• Encryption at rest for sensitive personal and financial data stored on n77 app servers;
• Access controls and role-based permissions limiting internal data access to authorised personnel only;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication requirements for internal system access;
• Incident response procedures in compliance with NPC breach notification requirements.

8.2 In the event of a personal data breach that poses a real risk to your rights and freedoms, n77 app will notify the NPC and affected users within the timeframe prescribed by the DPA and NPC regulations.

9. Your Data Subject Rights

9.1 Under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by n77 app:

• Right to be Informed — the right to know that your personal data is being collected and how it is being processed;
• Right of Access — the right to obtain a copy of the personal data we hold about you;
• Right to Rectification — the right to correct inaccurate, incomplete, or outdated personal data;
• Right to Erasure — the right to request deletion of your personal data where processing is no longer necessary, except where retention is required by law;
• Right to Restriction — the right to request limitation of processing in certain circumstances;
• Right to Object — the right to object to processing based on legitimate interests, including direct marketing;
• Right to Data Portability — the right to receive your personal data in a structured, commonly used format;
• Right to Withdraw Consent — where processing is based on consent, the right to withdraw it at any time without affecting the lawfulness of prior processing;
• Right to Lodge a Complaint — the right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

9.2 To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within fifteen (15) business days, subject to identity verification.

10. Cookies & Tracking Technologies

10.1 n77 app uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly Necessary Cookies — essential for Platform functionality, including session authentication and security. Cannot be disabled.
• Functional Cookies — remember your preferences (language, game settings) to personalise your experience.
• Analytical Cookies — collect anonymised data on how users interact with the Platform to improve performance and content.
• Marketing Cookies — used to deliver relevant promotional content based on your interaction history. Subject to your consent.

10.2 You can control cookie preferences through your browser settings. Note that disabling certain cookies may affect Platform functionality. Strictly necessary cookies cannot be declined without impairing your ability to use the Platform.

11. Minors

11.1 n77 app does not knowingly collect or process personal data from individuals under the age of 21. If we discover that personal data has been collected from a person under 21, we will immediately suspend the associated account, void all transactions, and securely delete the data.

11.2 If you are a parent or guardian and believe that a minor has created an account on n77 app, please contact us immediately at [email protected] so we can take prompt remedial action.

12. Cross-Border Data Transfers

12.1 n77 app primarily processes and stores personal data within the Philippines. Where data is transferred to processors or service providers located outside the Philippines, n77 app ensures that such transfers are subject to appropriate safeguards consistent with the requirements of the DPA, including contractual data processing agreements that impose obligations equivalent to Philippine data protection standards.

12.2 n77 app will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without implementing appropriate protective measures and, where required, notifying the NPC.

13. Changes to This Privacy Policy

13.1 n77 app reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or operational requirements. The date of the most recent revision is displayed at the top of this document.

13.2 For material changes that significantly affect how we handle your personal data, we will make reasonable efforts to notify you via email or an in-platform notification prior to the change taking effect.

13.3 Continued use of the n77 app Platform following any update to this Policy constitutes your acknowledgement of the revised terms.

14. Contact & Data Protection Officer

If you have questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by n77 app, please contact our Data Protection Officer: