77color Privacy Policy

1 Introduction

77color ("we," "us," "our") is committed to protecting the privacy and personal data of every player who uses the 77color online gaming platform at https://77color.app. This Privacy Policy describes how we collect, use, store, share, and protect your personal information in connection with your use of the 77color platform and all associated services.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations as administered by the National Privacy Commission (NPC). By registering an account or using the 77color platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

This Privacy Policy should be read together with our Terms & Conditions, which govern your use of the 77color platform.

2 Data Controller

For the purposes of the Data Privacy Act of 2012, the data controller responsible for your personal information is:

Our designated Data Protection Officer (DPO) oversees all matters relating to data privacy and can be contacted directly at the email address above for any privacy-related enquiries, requests, or complaints.

3 Personal Data We Collect

77color collects the following categories of personal data in connection with your use of the platform:

• Identity data: Full legal name, date of birth, nationality, and government-issued ID number (e.g., PhilSys National ID, driver's licence, or passport number).
• Contact data: Email address, mobile number, and residential address (city, province, and postal code within the Philippines – e.g., Metro Manila, Cebu, Davao, Quezon City, Makati).
• Account data: Username, encrypted password, account registration date, account status, and player preferences.
• Financial data: Deposit and withdrawal transaction records, payment method details (e.g., GCash account name, BPI or BDO account reference), and transaction amounts in Philippine Peso (PHP).
• KYC verification data: Copies of government-issued photo ID, proof of address documents, and proof of payment method ownership submitted during identity verification.
• Gaming activity data: Game history, wager amounts, win/loss records, session duration, and bonus usage.
• Technical data: IP address, device type, operating system, browser type and version, screen resolution, and time zone.
• Usage data: Pages visited, features used, click-through patterns, and session timestamps on the 77color platform.
• Communications data: Records of your correspondence with 77color customer support, including live chat transcripts and email exchanges.
• Responsible gaming data: Self-exclusion requests, deposit limit settings, cooling-off period records, and any problem gambling disclosures you voluntarily provide.

We do not collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. We do not collect biometric data, political opinions, religious beliefs, or health information unless you voluntarily disclose such information in a support communication.

4 How We Collect Your Data

77color 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 customer support, or participating in a promotion.
• Automated collection: Technical and usage data collected automatically when you access the 77color platform, including through cookies, server logs, and similar tracking technologies (see Section 8).
• Third-party sources: Identity verification data received from KYC service providers; transaction data received from payment processors such as GCash, PayMaya/Maya, and Philippine banks; fraud prevention data from anti-money-laundering screening services.
• Regulatory sources: Information received from PAGCOR or other Philippine regulatory authorities in connection with licensing compliance or investigations.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012, 77color processes your personal data on the following legal bases:

• Contractual necessity: Processing required to create and manage your account, process deposits and withdrawals, and provide gaming services under our Terms & Conditions.
• Legal obligation: Processing required to comply with PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming enforcement, and improvement of our services, where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 How We Use Your Personal Data

77color uses your personal data for the following purposes:

• Creating, verifying, and managing your 77color player account.
• Processing deposits and withdrawals via GCash, PayMaya/Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, and debit card.
• Conducting KYC identity verification as required by PAGCOR and Philippine anti-money-laundering regulations.
• Detecting, investigating, and preventing fraud, money laundering, and other illegal activity on the platform.
• Enforcing our Terms & Conditions, including the 21+ age restriction and responsible gaming policies.
• Providing customer support and responding to your enquiries and complaints.
• Sending transactional communications, including account confirmations, deposit receipts, withdrawal notifications, and security alerts.
• Sending promotional communications about 77color bonuses and offers, where you have consented to receive such communications.
• Analysing platform usage to improve the 77color user experience, game selection, and service quality.
• Complying with reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), and the National Privacy Commission (NPC).

77color will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a separate legal basis for the new processing activity.

7 Data Sharing & Disclosure

77color does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent strictly necessary:

• Payment processors: GCash, PayMaya/Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your financial transactions.
• KYC and identity verification providers: Third-party services engaged to verify your identity documents and screen against sanctions and politically exposed persons (PEP) lists, as required by AMLA.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory order.
• IT and security service providers: Cloud hosting, cybersecurity, and platform infrastructure providers engaged under strict data processing agreements that prohibit independent use of your data.
• Professional advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third-party service providers engaged by 77color are required to implement appropriate technical and organisational security measures and to process your personal data only in accordance with our documented instructions.

8 Cookies & Tracking Technologies

77color uses cookies and similar technologies on the platform for the following purposes:

• Essential cookies: Required for the platform to function correctly, including session management, login authentication, and security token validation. These cookies cannot be disabled without impairing platform functionality.
• Performance cookies: Used to collect anonymised data about how players use the 77color platform, such as which pages are visited most frequently and where errors occur. This data helps us improve platform performance and reliability.
• Preference cookies: Used to remember your platform settings and preferences, such as language selection and display options.

77color does not use third-party advertising cookies, social media tracking pixels, or cross-site behavioural tracking technologies. You may manage cookie preferences through your browser settings. Please note that disabling essential cookies may prevent you from accessing certain features of the 77color platform.

9 Data Retention

77color retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, as required by the Anti-Money Laundering Act.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA and PAGCOR reporting requirements.
• Customer support communications: Retained for three (3) years from the date of the last communication.
• Gaming activity logs: Retained for three (3) years from the date of each gaming session.
• Marketing consent records: Retained for the duration of your account and for two (2) years following account closure or withdrawal of consent.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymised in accordance with NPC-approved data disposal procedures.

10 Data Security

77color implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• Encryption: All data in transit is protected by 256-bit SSL/TLS encryption. Sensitive data at rest, including passwords and financial records, is encrypted using AES-256.
• Access controls: Access to personal data is restricted to authorised 77color personnel on a strict need-to-know basis. All staff with access to personal data undergo regular data privacy training.
• Firewalls and intrusion detection: The 77color platform is protected by enterprise-grade firewalls and real-time intrusion detection and prevention systems.
• Penetration testing: Regular third-party security audits and penetration tests are conducted to identify and remediate vulnerabilities.
• Incident response: 77color maintains a documented data breach response plan. In the event of a breach affecting your personal data, we will notify you and the NPC within 72 hours of discovery.

While 77color takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

11 Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 77color:

To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified data subject requests within fifteen (15) business days.

12 Children's Privacy – 21+ Only

The 77color platform is strictly intended for adults aged 21 years and above, in compliance with Philippine gambling regulations. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under the age of 21, we will immediately suspend the associated account, delete the personal data, and return any deposited funds in accordance with applicable regulations. If you believe a minor has registered on the 77color platform, please contact us immediately at [email protected].

13 Third-Party Links

The 77color platform does not contain links to third-party websites or services. All navigation links on the platform direct you to pages within the 77color domain (https://77color.app). This Privacy Policy applies solely to data collected and processed by 77color in connection with your use of the 77color platform.

14 Amendments to This Policy

77color reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. When material changes are made, we will notify registered players via email or a prominent notice on the platform at least seven (7) days before the changes take effect.

The effective date at the top of this document indicates when the current version came into force. The most current version of this Privacy Policy is always available at https://77color.app/privacy-policy. Your continued use of the 77color platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

15 Contact & Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way 77color handles your personal data, please contact our Data Protection Officer:

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent regulatory body responsible for administering and enforcing the Data Privacy Act of 2012.

For responsible gaming concerns, deposit limit requests, or self-exclusion, please visit our Responsible Gaming page or contact our support team via live chat, available 24/7 on the 77color platform.