pd77 Privacy Policy

This Privacy Policy ("Policy") is issued by pd77 ("pd77", "we", "us", "our") and applies to all personal data collected, processed, stored, and disclosed by pd77 in connection with the pd77 online gaming platform accessible at pd77.asia, including all sub-domains, mobile-optimized versions, and any related services ("Platform").

This Policy is intended to inform users of the pd77 Platform, including registered account holders, visitors who have not yet registered, and individuals whose data pd77 processes in connection with its regulatory compliance obligations ("you", "your", "data subject"), about pd77's data processing practices and your rights under applicable data protection law.

This Policy must be read in conjunction with pd77's Terms & Conditions and Responsible Gaming Policy. By accessing or using the Platform, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, you should discontinue use of the Platform.

For the purposes of applicable data protection legislation, including the Philippine Data Privacy Act of 2012, the data controller responsible for your personal data is pd77, the operator of the pd77 Platform.

pd77 has designated a Data Protection Officer ("DPO") who is responsible for overseeing the implementation of this Policy and ensuring compliance with applicable data protection laws. You may contact the DPO with privacy-related inquiries using the contact details provided in Section 16 of this Policy.

Where pd77 engages third-party service providers to process personal data on its behalf, those providers act as data processors under documented agreements that require them to maintain appropriate security measures and to process data only in accordance with pd77's instructions and applicable law.

pd77 collects the following categories of personal data, depending on your interaction with the Platform:

pd77 does not collect sensitive personal information — such as data relating to racial or ethnic origin, political opinions, religious beliefs, health conditions (other than gambling-related self-disclosure for responsible gaming purposes), or biometric data — except where specifically required by law or explicitly consented to by the data subject.

pd77 collects personal data through the following mechanisms:

• Direct provision by you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or update your account profile, you directly provide personal data to pd77.
• Automated technical collection: When you access the pd77 Platform, our systems automatically collect technical data including your IP address, device identifiers, browser information, and session activity. This data is collected through server logs, cookies, and similar tracking technologies described in Section 11.
• Third-party payment processors: When you transact via GCash, Maya, BPI, BDO, or other payment providers, those providers transmit transaction confirmation data to pd77 sufficient to identify the transaction and verify the payment. pd77 does not receive or store your full payment provider login credentials.
• Identity verification services: pd77 may engage accredited identity verification providers to assist with KYC verification. These providers process your government-issued ID documentation on pd77's behalf and return a verification outcome to pd77.
• Publicly available sources: In connection with fraud prevention and compliance obligations, pd77 may cross-reference data against publicly available records, sanctions lists, and politically exposed persons databases.

pd77 processes your personal data for the following specific purposes:

• Account creation and management: To register, authenticate, and administer your pd77 account, including processing your login credentials and account settings.
• KYC and identity verification: To verify your identity, age (21+ requirement), and eligibility to use the Platform in compliance with PAGCOR regulations and anti-money laundering obligations.
• Payment processing: To process deposits, withdrawals, and bonus credits; to maintain accurate transaction records; and to reconcile financial accounts.
• Game operation: To deliver, record, and calculate the outcomes of gaming sessions; to maintain game history; and to resolve disputes.
• Fraud prevention and security: To detect, investigate, and prevent fraud, money laundering, collusion, bonus abuse, and other prohibited conduct; to protect the security and integrity of the Platform.
• Regulatory compliance: To fulfill reporting obligations under PAGCOR regulations, Philippine anti-money laundering law (AMLA), and other applicable legal and regulatory requirements.
• Customer support: To respond to your inquiries, resolve complaints, and provide technical assistance.
• Responsible gaming: To administer self-exclusion requests, deposit limits, cooling-off periods, and other responsible gaming tools; to identify and respond to signs of problem gambling.
• Platform improvement: To analyze platform usage patterns, game performance, and user experience data to improve our products and services. This analysis is conducted on aggregated or anonymized data where possible.
• Marketing communications: Where you have provided explicit consent, to send you promotional offers, bonus notifications, and platform updates by email or SMS. You may withdraw this consent at any time via your account communication preferences.

Under the Philippine Data Privacy Act of 2012, pd77 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill pd77's obligations under the Terms & Conditions you agreed to upon registration — including account management, game operation, and payment processing.
• Legal obligation: Processing required to comply with applicable Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160, as amended), and the Data Privacy Act itself.
• Legitimate interests: Processing necessary for pd77's legitimate business interests, including fraud prevention, platform security, and product improvement, where those interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, freely given, and informed consent. You may withdraw consent for these purposes at any time without affecting the lawfulness of processing carried out prior to withdrawal.

pd77 may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate safeguards:

• Payment processors: GCash (Mynt), Maya Philippines, BancNet, and other payment service providers engaged to process your transactions.
• Identity verification providers: Third-party KYC and document verification services operating under data processing agreements with pd77.
• Game content providers: Licensed gaming studios whose games are hosted on the pd77 Platform may receive anonymized or pseudonymized session data for game operation and auditing purposes.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other Philippine government agencies where disclosure is required by law or regulatory order.
• Fraud prevention services: Industry fraud intelligence databases and anti-fraud service providers engaged by pd77 to protect the Platform and its players.
• Professional advisers: Legal counsel, auditors, and accountants bound by professional confidentiality obligations.
• Business successors: In the event of a merger, acquisition, or sale of assets affecting the pd77 Platform, your data may be transferred to the successor entity, subject to equivalent privacy protections.

pd77 does not sell, rent, or trade your personal data to third-party advertisers, data brokers, or any other commercial entity for marketing purposes.

The pd77 Platform primarily serves Filipino players and its core data processing infrastructure is operated with data residency considerations appropriate for the Philippine market. However, certain service providers engaged by pd77 — including cloud infrastructure providers, identity verification services, and game studios — may be headquartered or operate data centers outside the Philippines.

Where personal data is transferred to a country that may not provide an equivalent level of data protection to that available under Philippine law, pd77 implements appropriate safeguards, including contractual data protection obligations (standard contractual clauses), to ensure that your data remains protected at a standard consistent with this Policy and applicable Philippine law.

By using the pd77 Platform, you acknowledge that your data may be transferred and processed in countries outside the Philippines in connection with the services described in this Policy.

pd77 retains personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by law and regulation:

• KYC and identity documents: Minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and the Anti-Money Laundering Act.
• Transaction records: Minimum of five (5) years from the date of the transaction, in accordance with AMLC record-keeping requirements.
• Game history: Three (3) years from the date of the gaming session, or longer where required for dispute resolution or regulatory purposes.
• Support communications: Two (2) years from the date of the last communication, or longer where the matter relates to an ongoing dispute or legal claim.
• Marketing consent records: Until withdrawal of consent plus one (1) year, to demonstrate the lawfulness of marketing communications sent prior to withdrawal.

Upon expiry of the applicable retention period, pd77 will securely delete or irreversibly anonymize your personal data, unless continued retention is required by law or by a legitimate unresolved legal claim.

pd77 implements technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures include:

• Encryption in transit: All data transmitted between your device and the pd77 Platform is encrypted using TLS 1.2 or higher (HTTPS). pd77 enforces HTTPS across all Platform endpoints.
• Encryption at rest: Sensitive personal data, including identity documents and financial data, is encrypted at rest using industry-standard encryption algorithms.
• Access controls: Access to personal data within pd77's systems is restricted to authorized personnel on a need-to-know basis and is governed by role-based access control policies.
• Two-factor authentication: pd77 offers 2FA for player accounts and enforces multi-factor authentication for internal systems that access personal data.
• Regular security assessments: pd77 conducts periodic security assessments, including vulnerability scanning and penetration testing, to identify and remediate security weaknesses.
• Incident response: pd77 maintains a data breach response procedure. In the event of a personal data breach that poses a risk to affected individuals, pd77 will notify the National Privacy Commission and affected data subjects within the timeframes required by law.

While pd77 employs these safeguards, no digital transmission or storage system is completely secure. Players are responsible for maintaining the security of their own account credentials and devices.

pd77 uses cookies and similar tracking technologies on the Platform to enable core functionality, improve user experience, and — where you have consented — to deliver relevant promotional content.

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies, security cookies, and cookies that remember your language and region preferences. These cookies cannot be disabled without impairing Platform functionality.
• Functional cookies: Enable enhanced features such as remembering your game preferences, recently played titles, and responsible gaming settings. These improve your experience but are not strictly required.
• Analytics cookies: Collect aggregated, anonymized data about Platform usage patterns — such as which games are most popular and where navigation flows break down — to help pd77 improve the Platform. No individual player is identified in analytics data.
• Marketing cookies: Used to deliver promotional messages relevant to your interests, where you have explicitly consented. These cookies track interaction with pd77 promotional content.

You may manage your cookie preferences at any time through your browser settings. Disabling strictly necessary cookies will impair your ability to use the Platform. Disabling other cookie categories will not affect your ability to access and play games on pd77.

The pd77 Platform is strictly for individuals who are at least twenty-one (21) years of age. pd77 does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the KYC process, and accounts that cannot be verified as belonging to an individual who has reached the minimum age will be suspended or permanently closed.

If pd77 becomes aware that personal data has been collected from a person under the age of 21 — whether through an erroneous registration, a third-party notification, or any other means — pd77 will promptly delete that data, close the associated account, and refund any deposited funds to the originating payment method, subject to verification.

Parents and guardians who believe that a minor in their care has registered on the pd77 Platform are urged to contact pd77 immediately via live chat or email so that the account can be closed and the minor's data deleted without delay.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pd77. You may exercise these rights by contacting pd77's Data Protection Officer using the contact details in Section 16:

pd77 will respond to verified data subject requests within thirty (30) calendar days of receipt. Where a request is complex or involves a large volume of data, pd77 may extend this period by a further thirty (30) days, with notification to the data subject. pd77 reserves the right to verify the identity of the requesting party before processing any data subject request.

If you have a concern about how pd77 handles your personal data, pd77 encourages you to contact the Data Protection Officer in the first instance using the contact details in Section 16. pd77 commits to acknowledging all privacy complaints within five (5) business days and to responding substantively within thirty (30) calendar days.

If you are not satisfied with pd77's response to your complaint, or if you believe pd77 has processed your data in violation of the Philippine Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. Information about how to file a complaint with the NPC is available on the NPC's official website.

pd77 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. Material changes — those that significantly affect how your personal data is processed or your rights as a data subject — will be communicated to registered players via email notification to your registered address and/or via a prominent notice on the Platform, at least fourteen (14) days before the revised Policy takes effect.

The "Effective Date" at the top of this Policy indicates when the current version came into force. Your continued use of the pd77 Platform following the effective date of any revised Policy constitutes your acknowledgment of the changes. If you do not agree with a revised Policy, you should cease using the Platform and contact support to close your account.

We recommend reviewing this Policy periodically to stay informed about how pd77 protects your data.

For any questions, concerns, or requests relating to this Privacy Policy or pd77's data processing practices, you may contact the pd77 Data Protection Officer through the following channels:

Live Chat: Available 24/7 via the chat widget on any page of the pd77 Platform. For urgent data security matters — such as suspected unauthorized access to your account — live chat provides the fastest response.

Email: For written privacy inquiries, data subject access requests, or formal complaints, you may write to pd77 at the email address below. This is a plain text address — not a clickable link:

[email protected]  |  Subject line: Privacy / DPO Request

pd77 aims to acknowledge all written DPO inquiries within two (2) business days and to provide a substantive response within thirty (30) calendar days. For subject access requests involving a large volume of data, the response period may be extended by a further thirty (30) days with advance notification.