ff77 Privacy Policy

1 Who We Are

ff77 ("ff77," "we," "us," "our") is the operator of the online gaming platform accessible at ff77.lat. ff77 is licensed by the Philippine Amusement and Gaming Corporation ("PAGCOR") to provide electronic gaming services to eligible players in the Philippines. As a PAGCOR-licensed entity, ff77 is designated as a "covered person" under the Anti-Money Laundering Act of 2001 (Republic Act No. 9160, as amended) and is subject to corresponding data processing and reporting obligations.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations ("IRR"), ff77 is the Personal Information Controller ("PIC") in respect of the personal data of registered players and Platform visitors.

Inquiries regarding this Privacy Policy or data subject rights requests may be directed to our Data Protection Officer at [email protected].

2 Personal Data We Collect

ff77 collects personal data in the categories described in the table below. Data collection is limited to what is necessary for the specified purposes and our legal obligations as a PAGCOR-licensed operator.

3 How We Collect Your Data

3.1 Directly From You

The majority of personal data ff77 holds is provided directly by you during the account registration process, the KYC verification process, when making deposits or withdrawals, when contacting our support team, or when updating your account profile. You choose what information to provide, subject to the mandatory data requirements for account creation and KYC compliance.

3.2 Automatically Through Platform Use

When you access and use the ff77 Platform, we automatically collect technical and gaming activity data through server logs, session tracking systems, and first-party cookies. This includes your IP address, device identifiers, login and logout timestamps, pages visited, games played, bet records, and session duration. This data is collected for security monitoring, fraud prevention, regulatory compliance, and service improvement purposes.

3.3 From Third Parties

ff77 may receive personal data from third parties in limited circumstances, including: identity verification service providers used to validate KYC documents; payment processors (GCash, PayMaya, banking partners) for transaction verification; fraud detection and AML screening providers; and, where applicable, PAGCOR's player exclusion registry for responsible gaming compliance.

4 Why We Process Your Personal Data

ff77 processes your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your ff77 player account, including authentication, password recovery, and session management.
• KYC and identity verification: Verifying your age (minimum 21 years), identity, and eligibility to use the Platform in compliance with PAGCOR's KYC requirements.
• Transaction processing: Processing deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers; reconciling balances; issuing transaction receipts.
• Regulatory and AML compliance: Meeting ff77's obligations as a PAGCOR-licensed covered person under the Anti-Money Laundering Act, including transaction monitoring, suspicious activity reporting, and record-keeping obligations.
• Responsible gaming: Monitoring gaming activity to enforce self-imposed limits, detect potential problem gambling patterns, and comply with PAGCOR's responsible gaming standards.
• Platform security and fraud prevention: Detecting, investigating, and preventing unauthorized account access, fraud, bonus abuse, and other security incidents.
• Customer support: Responding to your inquiries, resolving complaints, and providing account assistance through our 24/7 support channels.
• Service improvement: Analyzing aggregated and anonymized usage data to improve game selection, platform performance, and user experience.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates where you have provided consent or where we have a legitimate interest, subject to your opt-out rights.

5 Legal Bases for Processing

Under the Philippine Data Privacy Act of 2012, ff77 processes your personal data on the following legal bases:

• Contractual necessity: Processing necessary to perform our obligations under the ff77 Terms and Conditions — including account operation, transaction processing, and game provision — is processed on the basis that it is necessary to fulfill the contract between ff77 and you.
• Legal obligation: Data processed to comply with PAGCOR regulatory requirements, AML obligations under Republic Act No. 9160, tax reporting obligations, and other applicable Philippine laws is processed on the basis of legal obligation.
• Legitimate interests: Data processed for fraud prevention, platform security, and service improvement is processed on the basis of ff77's legitimate interest in operating a secure, compliant, and functional platform, balanced against your rights and interests.
• Consent: Marketing communications and optional preference data are processed on the basis of your consent, which may be withdrawn at any time by contacting [email protected] or adjusting your account notification preferences.

6 Sharing Your Personal Data

ff77 does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We share your data only in the following circumstances and only to the extent necessary for the stated purpose:

6.1 Service Providers

ff77 engages third-party service providers who process personal data on our behalf, including: identity verification and KYC providers; payment processors (GCash, PayMaya, and banking partners); game content providers (JILI, Pragmatic Play, PG Soft, Evolution Gaming, and others); cloud infrastructure providers; fraud detection and AML screening services; and customer support platform providers. All such processors are bound by data processing agreements that restrict them from using your data for any purpose other than providing services to ff77.

6.2 Regulatory and Legal Disclosures

ff77 is required by law to share data with PAGCOR as our licensing authority, the Anti-Money Laundering Council (AMLC) where transaction reporting obligations arise, and with Philippine law enforcement or judicial authorities where we receive a lawful order, warrant, or subpoena compelling disclosure. ff77 will notify you of such disclosures where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of ff77's business or assets, your personal data may be transferred to the successor entity as part of the transaction. We will notify affected players through the Platform or by email prior to any such transfer where practicable.

7 Data Retention

ff77 retains your personal data only for as long as necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following retention periods apply:

• Account and KYC data: Retained for the duration of your account's existence plus five (5) years following account closure, as required by PAGCOR and AML regulations.
• Transaction records: Retained for ten (10) years from the date of the transaction in compliance with AML record-keeping obligations under Republic Act No. 9160.
• Gaming activity logs: Retained for five (5) years from the date of the session, for regulatory audit purposes.
• Support communications: Retained for three (3) years from the date of the last communication, or longer where required to resolve an ongoing dispute or complaint.
• Technical and security logs: Retained for twelve (12) months, or longer where required for an active security investigation.

Following expiry of the applicable retention period, ff77 will securely delete or anonymize your personal data such that it can no longer be associated with your identity.

8 Security Measures

ff77 implements and maintains appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Key security controls include:

• TLS 1.3 encryption for all data in transit between your device and ff77 servers;
• AES-256 encryption for sensitive data at rest, including payment method details and government ID references;
• Bcrypt hashing with salt for stored account passwords — ff77 never stores passwords in plain text;
• Two-factor authentication available for all accounts and recommended for all players;
• Role-based access controls limiting internal staff access to personal data on a strict need-to-know basis;
• Regular third-party security audits and penetration testing of the ff77 Platform;
• Automated suspicious login detection with email alerts and session termination capabilities;
• Segregated production environments with access logging and anomaly detection.

9 Cookies & Tracking Technologies

ff77 uses first-party cookies and similar tracking technologies to operate the Platform. These include:

• Strictly necessary cookies: Session management cookies that maintain your login state and security token across pages. These cannot be disabled without preventing Platform access.
• Functional cookies: Cookies that remember your language preference, game display settings, and responsible gaming limit configurations.
• Analytics cookies: First-party analytics used to measure aggregate Platform usage, identify performance issues, and improve game loading times. Data collected is aggregated and not used for individual profiling.

ff77 does not use third-party advertising or retargeting cookies. You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to the Platform.

10 Your Rights Under the Data Privacy Act of 2012

As a data subject under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights with respect to your personal data held by ff77:

• Right to be Informed: The right to know what personal data ff77 collects about you, the purpose of processing, and how it is shared — as described in this Privacy Policy.
• Right to Access: The right to request a copy of the personal data ff77 holds about you, including a description of how it has been processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your ff77 account profile; for KYC-bound data, please contact support.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ff77's legal retention obligations under PAGCOR and AML regulations.
• Right to Object: The right to object to processing based on legitimate interests, including direct marketing communications. You may withdraw marketing consent at any time through your account notification settings.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format, where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe ff77 has processed your personal data in violation of the DPA.

To exercise any of these rights, submit a written request to [email protected], referencing "Data Subject Request" in your message. ff77 will respond within thirty (30) days of receipt of a valid request. We may request supporting identification to verify your identity before processing the request.

11 Children and Minors

ff77 is strictly prohibited from providing gaming services to any person under 21 years of age. ff77 does not knowingly collect personal data from individuals under 21. The KYC verification process is specifically designed to identify and prevent account registration by minors.

If ff77 becomes aware that personal data has been collected from a person under 21, the account will be immediately suspended, all funds will be returned to their source payment method following verification, and the personal data will be securely deleted. If you believe a minor has created an ff77 account, please report this to [email protected] immediately.

12 International Data Transfers

ff77's primary data infrastructure is located within the Philippines. In limited circumstances, personal data may be processed by service providers operating from outside the Philippines — for example, certain game content providers and cloud infrastructure services. Where such transfers occur, ff77 ensures that appropriate safeguards are in place consistent with Section 21 of the Data Privacy Act of 2012 and NPC guidelines on cross-border data transfers, including contractual clauses that obligate the overseas processor to apply data protection standards equivalent to those required under Philippine law.

13 Amendments to This Privacy Policy

ff77 reviews and updates this Privacy Policy periodically to reflect changes in our data processing practices, Platform features, regulatory requirements, or applicable law. Material changes will be communicated to registered players via email or in-platform notification at least seven (7) days prior to the effective date of the change.

The "Last updated" date at the top of this policy reflects the date of the most recent revision. Continued use of the ff77 Platform following publication of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to the revised Privacy Policy, you should cease using the Platform and may request account closure pursuant to the ff77 Terms and Conditions.

14 Contact Us & Data Protection Officer

For questions about this Privacy Policy, to exercise your data subject rights, or to report a privacy concern, please contact:

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) if you believe your data privacy rights have been violated. The NPC's contact details are available on the official NPC website.