top77fn Privacy Policy

1. Introduction

This Privacy Policy ("Policy") applies to all personal data collected and processed by top77fn ("the Platform," "we," "us," or "our") in connection with your use of the top77fn website, mobile interface, games, and related services (collectively, the "Services").

top77fn is committed to protecting the privacy and security of all players and visitors. We process personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").

By registering an account or using the top77fn 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. If you do not agree, please discontinue use of the platform.

2. Data Controller

top77fn acts as the personal information controller ("PIC") in respect of the personal data you provide when using the Services. As PIC, top77fn determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data privacy laws.

For all data privacy inquiries, requests, and complaints, you may contact our Data Protection Officer ("DPO") using the contact details provided in Section 14 of this Policy.

3. Data We Collect

top77fn collects personal data through various means, including directly from you during registration and account use, automatically through your use of the platform, and from third-party service providers where necessary. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name
• Date of birth (for age verification — 21+ requirement)
• Email address and mobile number
• Username and encrypted password
• Government-issued identification documents (for KYC verification)
• Proof of address

3.2 Financial Data

• GCash or PayMaya account details (reference numbers only — we do not store full wallet credentials)
• Bank account details for transfer transactions (account name and number)
• Debit card details (processed securely through our payment processor — top77fn does not store full card numbers)
• Transaction history: deposits, withdrawals, and game wagers

3.3 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration, pages visited, and features used
• Game history and betting patterns
• Cookie identifiers and similar tracking technologies

3.4 Communications Data

• Records of your communications with top77fn customer support
• Feedback, survey responses, and promotional opt-in preferences

4. How We Use Your Data

top77fn uses your personal data for the following purposes:

5. Legal Basis for Processing

top77fn processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable laws, including AML regulations, KYC requirements, and gaming regulatory obligations.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time.

6. Data Sharing & Disclosure

top77fn does not sell your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, and banking partners, for the purpose of processing deposits and withdrawals.
• Game providers: Third-party game software providers who supply games on the top77fn platform, subject to data processing agreements.
• KYC and identity verification providers: Third-party services used to verify player identity and age in compliance with regulatory requirements.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies, where required by law.
• IT and security service providers: Cloud hosting, cybersecurity, and analytics providers operating under strict data processing agreements.
• Legal and professional advisors: Lawyers, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third-party recipients are required to process your data only for the specified purpose and in accordance with applicable Philippine data privacy laws.

7. Data Retention

top77fn retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for five (5) years following account closure, in compliance with AML record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• Game history and session data: Retained for three (3) years from the date of the session.
• Customer support communications: Retained for two (2) years from the date of the last communication.
• Marketing preferences: Retained until you withdraw consent or request deletion.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with top77fn's data disposal procedures.

8. Data Security

top77fn implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit
• Encryption of sensitive data at rest, including financial information and identity documents
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Two-factor authentication (2FA) for player accounts and internal systems
• Regular security audits, penetration testing, and vulnerability assessments
• Continuous monitoring for suspicious activity and potential data breaches
• Staff training on data privacy and security obligations

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, top77fn will notify the National Privacy Commission and affected data subjects in accordance with the timeframes prescribed by the DPA and NPC regulations.

9. Cookies & Tracking Technologies

top77fn uses cookies and similar tracking technologies to operate and improve the platform. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the platform to function. These cannot be disabled. They include session management, authentication, and security cookies.
• Analytics cookies: Used to understand how players use the platform, which pages are most visited, and where improvements can be made. Data is aggregated and anonymised where possible.
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming limits you have set.
• Marketing cookies: Used only with your explicit consent to deliver relevant promotional content. You may opt out at any time through your account settings.

You can manage your cookie preferences through your browser settings or through the cookie preference centre in your top77fn account. Note that disabling strictly necessary cookies may affect platform functionality.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act, you have the following rights in respect of your personal data held by top77fn:

• Right to be informed: The right to know what personal data we collect, how we use it, and with whom we share it — as set out in this Policy.
• Right to access: The right to request a copy of the personal data top77fn holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• 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 our legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 14. top77fn will respond to all verified data subject requests within fifteen (15) calendar days of receipt, in accordance with NPC guidelines.

11. Minors & Age Restriction

top77fn does not knowingly collect personal data from individuals under the age of 21. Access to the platform is strictly limited to persons aged 21 and above in accordance with Philippine gaming regulations. If top77fn becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be closed.

If you are a parent or guardian and believe that a minor has registered on top77fn, please contact our support team immediately so that we can take appropriate action.

12. International Data Transfers

top77fn primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or accessed by service providers located outside the Philippines — for example, cloud infrastructure providers or international game software suppliers.

Where such transfers occur, top77fn ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to process data to a standard equivalent to that required under Philippine law. top77fn will not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards.

13. Changes to This Policy

top77fn reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. Material changes will be communicated to registered players via email or an in-platform notification at least seven (7) days before taking effect.

The effective date at the top of this Policy will be updated whenever changes are made. We encourage you to review this Policy periodically. Your continued use of top77fn following the publication of an updated Policy constitutes your acceptance of the revised terms.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by top77fn, please contact our Data Protection Officer:

If you are not satisfied with top77fn's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information on how to file a complaint is available through the NPC's official channels.