Privacy Policy

1 Introduction

top 77 ("top 77," "we," "us," or "our") is committed to protecting the privacy and personal data of all users ("you," "User," or "Player") of the top 77 online gaming platform accessible at top-77.app (the "Platform"). This Privacy Policy describes how we collect, use, store, share, and protect your personal information when you access or use the Platform.

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

                 This Privacy Policy should be read together with our Terms & Conditions. Capitalized terms not defined here have the meanings given to them in the Terms & Conditions.
              

2 Personal Data We Collect

2.1 Information You Provide Directly

When you register for an account, complete KYC verification, make a deposit or withdrawal, or contact our support team, you may provide us with the following categories of personal data:

Identity Data: Full legal name, date of birth, nationality, government-issued ID number (e.g., Philippine passport, driver's license, SSS/UMID card);
Contact Data: Email address, mobile number, residential address (including barangay, city, province, and ZIP code);
Financial Data: GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records;
Account Data: Username, encrypted password, account preferences, communication preferences, and responsible gaming settings;
Support Data: Records of your communications with our customer support team, including chat logs and email correspondence.

2.2 Information Collected Automatically

When you access the Platform, we automatically collect certain technical data, including:

IP address and approximate geolocation;
Device type, operating system, and browser type and version;
Pages visited, time spent on each page, and navigation paths;
Session identifiers and authentication tokens;
Game activity logs, including bets placed, games played, and outcomes.

2.3 Information from Third Parties

We may receive personal data about you from third-party sources, including payment processors, identity verification service providers, fraud prevention agencies, and regulatory authorities, where permitted by applicable law.

3 How We Use Your Personal Data

top 77 processes your personal data for the following purposes:

Account Management: To create, maintain, and administer your top 77 account, including verifying your identity and age (21+ requirement);
Service Delivery: To provide access to games, process deposits and withdrawals, and deliver customer support;
Legal Compliance: To comply with our obligations under Philippine law, including anti-money laundering (AML) regulations, KYC requirements, and PAGCOR regulatory requirements;
Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct;
Responsible Gaming: To monitor gameplay patterns and enforce responsible gaming tools such as deposit limits, loss limits, and self-exclusion;
Platform Improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the Platform;
Communications: To send you transactional notifications (e.g., deposit confirmations, withdrawal updates) and, where you have opted in, promotional communications about top 77 offers and new games.

                 You may opt out of promotional communications at any time by updating your notification preferences in your account settings or by contacting our support team.
              

4 Legal Basis for Processing

top 77 processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

Contractual Necessity: Processing is necessary to perform our contract with you (i.e., the Terms & Conditions) — for example, to process your deposits and withdrawals and provide access to games;
Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations and PAGCOR licensing requirements;
Legitimate Interests: Processing is necessary for our legitimate interests in operating a secure, fair, and compliant gaming platform, provided those interests are not overridden by your rights and freedoms;
Consent: Where we rely on your consent (e.g., for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

5 Data Sharing & Disclosure

top 77 does not sell or rent your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to process your financial transactions;
Identity Verification Providers: Third-party KYC and AML service providers engaged to verify your identity and screen for sanctions;
Game Providers: Licensed game studios (e.g., Pragmatic Play, PG Soft, Jili, JDB, Evolution) that supply games on the Platform — these providers may receive anonymized gameplay data;
Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where required by law or court order;
IT & Security Service Providers: Cloud hosting, cybersecurity, and fraud detection vendors engaged to support the operation and security of the Platform;
Professional Advisors: Lawyers, auditors, and accountants, where necessary for legal, compliance, or financial purposes.

All third-party service providers engaged by top 77 are contractually required to process your personal data only for the specified purpose and to maintain appropriate security measures.

6 Data Retention

top 77 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements;
Transaction Records: Retained for a minimum of five (5) years from the date of each transaction;
KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship;
Support Communications: Retained for two (2) years from the date of the last communication;
Technical Logs: Retained for up to twelve (12) months for security and fraud investigation purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with our data disposal procedures.

7 Cookies & Tracking Technologies

top 77 uses cookies and similar tracking technologies to operate and improve the Platform. The types of cookies we use are:

Strictly Necessary Cookies: Essential for the Platform to function — these include session cookies that keep you logged in and security tokens that protect against cross-site request forgery. These cannot be disabled.
Analytics Cookies: Used to collect anonymized data about how users interact with the Platform, helping us identify areas for improvement. No personally identifiable information is collected through analytics cookies.
Preference Cookies: Used to remember your settings and preferences, such as language and display options.

top 77 does not use third-party advertising or tracking cookies. You can manage or delete cookies through your browser settings; however, disabling strictly necessary cookies may affect the functionality of the Platform.

8 Security Measures

top 77 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction, including:

Transport Layer Security (TLS) encryption for all data transmitted between your device and the Platform;
AES-256 encryption for sensitive data stored at rest, including identity documents and financial records;
Multi-factor authentication options for account access;
Regular penetration testing and vulnerability assessments conducted by independent security firms;
Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
24/7 security monitoring and intrusion detection systems;
Regular staff training on data protection and information security best practices.

While top 77 takes all reasonable steps to protect your data, no system is completely immune to security risks. You are responsible for keeping your account credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

9 Your Rights as a Data Subject

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by top 77:

Right to Be Informed: You have the right to be informed of how your personal data is being collected and processed — which is the purpose of this Privacy Policy;
Right of Access: You may request a copy of the personal data we hold about you, along with information about how it is being processed;
Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you;
Right to Erasure: You may 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: You may object to the processing of your personal data where we rely on legitimate interests as the legal basis, or where processing is for direct marketing purposes;
Right to Data Portability: You may request a copy of your personal data in a structured, commonly used, and machine-readable format;
Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details provided in Section 12. We will respond to all verified requests within thirty (30) days. We may need to verify your identity before processing your request.

                 Some rights are subject to limitations — for example, we cannot delete data that we are legally required to retain for AML compliance purposes. We will always explain the reason if we are unable to fulfill a request in full.
              

10 Children's Privacy

The top 77 Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law governing casino-style gambling. top 77 does 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 21 years of age, we will immediately suspend the relevant account, delete the personal data, and void any associated transactions. If you believe that a minor has registered on the Platform, please contact us immediately at the details provided in Section 12.

Parents and guardians are encouraged to use parental control tools and to monitor their children's online activity to prevent underage access to gambling platforms.

11 Updates to This Privacy Policy

top 77 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The revised Privacy Policy will be posted on this page with an updated effective date.

Where changes are material — meaning they significantly affect your rights or how we process your personal data — we will notify you by email to your registered address or by a prominent notice on the Platform prior to the changes taking effect. Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms.

We encourage you to review this page periodically to stay informed about how top 77 protects your personal data.

12 Contact Us & Data Protection Officer

top 77 has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact:

Data Protection Officer, top 77
Email: [email protected]
General Support: [email protected]
Response Time: We aim to acknowledge all privacy-related inquiries within 72 hours and provide a full response within 30 days.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.

This Privacy Policy was last updated on January 1, 2026 and is the current binding version applicable to all users of the top 77 Platform.

How top 77 Protects Your Privacy

Encrypted Data Storage

No Selling of Your Data

Your Rights Under RA 10173

Secure Transactions

Transparent Cookie Use

Breach Notification

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