ll77 Casino Privacy Policy

1. Introduction & Data Controller Identity

This Privacy Policy is issued by ll77 — the online gaming platform operating at the domain https://ll77.bid ("ll77", "we", "us", "our"). ll77 is the data controller responsible for the personal information collected from players who access, register with, or use the ll77 platform.

ll77 is committed to protecting the privacy and personal data of all users, in particular Filipino players whose data is processed under the Philippine Data Privacy Act (Republic Act No. 10173, hereinafter "RA 10173") and its Implementing Rules and Regulations (IRR) as administered by the National Privacy Commission (NPC).

By creating an account on ll77 or using our Services, 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. If you do not agree with any part of this Policy, you should not access or use the ll77 platform.

2. Scope of This Privacy Policy

This Policy applies to all personal data collected and processed by ll77 in connection with:

• Your registration of an ll77 player account.
• Your use of any game, betting, or financial feature on the ll77 platform at ll77.bid.
• Your interactions with ll77 customer support via live chat or email.
• Your participation in promotions, surveys, or loyalty programmes offered by ll77.
• Any other interaction between you and ll77 through which personal data is shared.

This Policy does not apply to third-party services, game studio platforms, or external payment providers (such as GCash or Maya) that you access through or in connection with ll77. Those parties are governed by their own separate privacy policies, over which ll77 exercises no control. ll77 encourages you to review the privacy policies of these third-party providers independently.

3. Personal Data We Collect

ll77 collects personal data through several channels — directly from you during registration and account use, automatically through your use of the platform, and in certain cases from third-party verification providers. The categories of personal data ll77 may collect include:

ll77 does not collect sensitive personal information as defined under RA 10173 (such as health data, biometric data beyond KYC face matching, or political affiliations) unless specifically required for a regulatory obligation and with your explicit consent.

4. Legal Basis for Processing

ll77 processes your personal data only where a valid legal basis exists under RA 10173 and applicable Philippine law. The primary legal bases on which ll77 relies are:

• Contractual Necessity: Processing necessary to perform the contract between you and ll77 — specifically, to operate your player account, process deposits and withdrawals, and provide access to games and services.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including KYC and anti-money laundering obligations under PAGCOR regulatory requirements and the Anti-Money Laundering Act (AMLA) of the Philippines.
• Legitimate Interests: Processing necessary for ll77's legitimate interests, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, where these interests are not overridden by your fundamental rights.
• Consent: Processing for optional purposes such as marketing communications and analytics, where you have given freely given, specific, and informed consent. You may withdraw this consent at any time through your account settings without affecting the lawfulness of prior processing.

5. How ll77 Uses Your Personal Data

ll77 uses the personal data it collects for the following specific purposes:

• Account Management: Creating, maintaining, and securing your ll77 player account, including processing password resets, two-factor authentication, and account notifications.
• Transaction Processing: Facilitating GCash, Maya, QR Ph, bank transfer, and other Philippine payment method deposits and withdrawals to and from your ll77 wallet.
• Identity Verification (KYC): Verifying your identity and age (21+ requirement) as mandated by Philippine gaming regulatory requirements before processing your first withdrawal.
• Fraud Detection & Security: Monitoring account activity for suspicious patterns, identifying potential instances of money laundering, bonus abuse, or account compromise, and taking protective action.
• Responsible Gaming: Monitoring gameplay patterns that may indicate problem gambling behaviour and proactively contacting players where warranted. Applying player-requested self-exclusion and deposit limit settings.
• Customer Support: Responding to your enquiries, complaints, and support requests via live chat and email, and maintaining records of these interactions for quality assurance.
• Platform Improvement: Analysing aggregated and anonymised platform usage data to improve game performance, navigation, and user experience for Filipino players.
• Legal Compliance: Retaining transaction and identity records as required by Philippine anti-money laundering regulations, responding to lawful requests from PAGCOR or other competent Philippine regulatory authorities.
• Marketing (with consent): Sending promotional offers, bonus notifications, and platform updates where you have opted in to receive such communications. You may opt out at any time.

6. Data Sharing & Third-Party Disclosure

ll77 does not sell, rent, or trade your personal data to third parties for their independent commercial purposes. ll77 shares personal data only in the following specific circumstances and with the following categories of recipients:

• Payment Processors: GCash (Mynt), Maya (Voyager Innovations), BancNet QR Ph, GrabPay, BPI, BDO, Metrobank, and 7-Eleven payment systems — solely for the purpose of processing your financial transactions. Each processor handles your data under their own privacy policies and applicable Philippine financial regulations.
• KYC & Identity Verification Providers: Third-party identity verification services that assist ll77 in confirming your identity and age as required by its regulatory obligations. These providers are bound by strict data processing agreements and process data solely for KYC purposes.
• Game Content Providers: Licensed third-party game studios whose games are accessible through the ll77 platform may receive session and wager data necessary for game functionality, dispute resolution, and RNG audit compliance. Game studios do not receive personally identifiable registration or financial data beyond what is technically necessary for game session management.
• Regulatory & Legal Authorities: ll77 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), courts, or other competent Philippine governmental authorities when required by law, court order, or legitimate regulatory inquiry.
• Professional Advisors: Legal, audit, and compliance professionals engaged by ll77 who are bound by professional confidentiality obligations.
• Corporate Transactions: In the event of a merger, acquisition, or asset sale involving ll77, player data may be transferred to the acquiring entity subject to the same privacy protections as outlined in this Policy. Players will be notified of any such transfer in advance.

7. Data Retention

ll77 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account and Registration Data: Retained for the duration of your active account plus a minimum of five (5) years after account closure, in compliance with Philippine anti-money laundering record-keeping requirements.
• KYC Identity Documents: Retained for a minimum of five (5) years following account closure, or longer if required by a specific regulatory obligation or ongoing investigation.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLC and PAGCOR record retention requirements.
• Gameplay Data: Session and gameplay records are retained for two (2) years from the date of the session for operational, dispute resolution, and responsible gaming monitoring purposes.
• Customer Support Records: Live chat transcripts and email correspondence are retained for two (2) years from the date of the interaction.
• Marketing Preferences: Retained until you withdraw consent or close your account, plus six (6) months to process the opt-out.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised so that it can no longer be associated with an identifiable individual. Anonymised or aggregated analytical data may be retained indefinitely for platform improvement purposes.

8. Security Measures

ll77 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure:

• Encryption in Transit: All data transmitted between your device and the ll77 platform is protected by 256-bit Transport Layer Security (TLS 1.3). The ll77 domain maintains an A-grade SSL certificate.
• Encryption at Rest: Personal data and financial records stored in ll77 databases are encrypted using AES-256 encryption.
• Access Controls: Access to personal data is restricted to ll77 personnel with a documented operational need. All internal access is logged, monitored, and subject to regular review.
• Two-Factor Authentication: ll77 offers OTP-based 2FA to all players and applies mandatory 2FA on all internal administrative access to production systems.
• Penetration Testing: ll77 systems undergo regular independent security assessments to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: ll77 maintains a documented data breach response procedure. In the event of a confirmed data breach affecting your personal data, ll77 will notify you and the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, in accordance with NPC breach notification rules.

9. Cookies & Tracking Technologies

ll77 uses cookies and similar browser-based tracking technologies to operate the platform and improve user experience. The categories of cookies used are as follows:

• Essential Cookies: Strictly necessary for the ll77 platform to function. These include session authentication cookies, security tokens, and load balancing cookies. Essential cookies cannot be disabled without impairing your ability to log in and use the platform.
• Functional Cookies: Used to remember your preferences such as language settings, game layout preferences, and responsible gaming tool configurations across sessions.
• Analytics Cookies: Optional cookies that collect anonymised data about how players navigate and use the ll77 platform. This data is used to identify usability issues, improve page load performance, and prioritise feature development. These cookies are only deployed where you have consented.
• Security Cookies: Short-lived cookies used in fraud detection and bot prevention systems to distinguish legitimate player sessions from automated traffic.

You may control cookie settings through your browser's built-in cookie management features. Disabling essential cookies will prevent you from logging into your ll77 account. Disabling functional or analytics cookies will not prevent platform access but may affect certain personalisation features.

ll77 does not use third-party advertising cookies or behavioural targeting cookies that track your activity across other websites or mobile applications.

10. Your Data Rights Under RA 10173

As a data subject under the Philippine Data Privacy Act, you have the following rights in relation to your personal data held by ll77:

• Right to Be Informed: The right to be informed that your personal data is being collected and processed, including the purposes and legal basis for such processing.
• Right of Access: The right to request a copy of the personal data ll77 holds about you and information about how it is being processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account details directly through your ll77 account settings. KYC document updates require submission through support.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent, or where processing is unlawful — subject to ll77's legal retention obligations under Philippine financial and gaming regulations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible, and to transmit it to another controller.
• Right to Object: The right to object to the processing of your data for purposes based on legitimate interests or for direct marketing purposes. Where you object to marketing processing, ll77 will cease such processing immediately.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe ll77's processing of your personal data violates RA 10173.

To exercise any of these rights, please submit a written request to ll77 via email (support at ll77.bid) or through live chat, clearly identifying yourself and the specific right you wish to exercise. ll77 will respond to rights requests within 15 business days of receiving a verifiable request. Complex requests may require up to 30 business days, in which case ll77 will notify you of the extension and the reason.

11. Children & Minors

The ll77 platform is strictly intended for adults aged 21 years and older in accordance with Philippine gambling law. ll77 does not knowingly collect personal data from individuals under the age of 21.

ll77 applies KYC age verification to all accounts to enforce this requirement. Where ll77 discovers or has reasonable grounds to believe that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, all associated funds held pending review, and the personal data scheduled for deletion in accordance with applicable law.

12. International Data Transfers

The primary processing of personal data at ll77 occurs within the Philippines. Where personal data is transferred to or accessed from service providers or game studios located outside the Philippines (for example, international game studios or cloud hosting infrastructure with data centres in other Asian jurisdictions), ll77 ensures such transfers are made:

• Only to recipients in countries or organisations that provide an adequate level of data protection as assessed under Philippine law or the NPC's guidance.
• Under contractual arrangements that impose data processing obligations equivalent to those required by RA 10173, including purpose limitation, data security requirements, and sub-processor restrictions.
• Where strictly necessary for the operation of your account or the provision of a specific game or service.

ll77 does not transfer your personal data to international data brokers, advertising networks, or marketing platforms.

13. Third-Party Links & Services

The ll77 platform may contain references to or integrations with third-party services including payment providers (GCash, Maya), identity verification platforms, and game studio portals. These third-party services are governed by their own privacy policies, which are independent of this Policy. ll77 is not responsible for the privacy practices, data handling, or security measures of any third-party service.

ll77 recommends that you review the privacy policies of GCash, Maya, and any other third-party service you interact with through or in connection with the ll77 platform. If you have concerns about how a payment processor or game studio handles your data, those concerns should be directed to the relevant third party.

14. Amendments to This Privacy Policy

ll77 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made to this Policy, ll77 will notify registered players through:

• A prominent notice on the ll77 platform displayed upon your next login following the amendment.
• An email notification to your registered email address.
• An updated "Effective Date" at the top of this Privacy Policy page.

Your continued use of the ll77 platform after the effective date of any amendments constitutes your acceptance of the revised Privacy Policy. If you do not accept the revised Policy, you should cease using ll77 and may request account closure. Amendments do not retroactively alter the lawfulness of data processing activities completed prior to the effective date of the change.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or ll77's data processing activities, please contact us through the following channels:

• Live Chat: Available 24/7 from within your ll77 account. Use live chat for urgent account-related privacy questions.
• Email: support at ll77.bid — for written privacy requests, rights exercise submissions, and formal complaints.

For formal data subject rights requests (access, rectification, erasure, portability, objection), please submit your request in writing via email with the subject line "Data Privacy Request – [Your Username]". Include your full name, account username, and a clear description of the right you are exercising. ll77 will verify your identity before processing any rights request.

If you are not satisfied with ll77's response to a privacy complaint or rights request, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.