Privacy Policy — top7777

01 Introduction

top7777 ("top7777," "we," "us," or "our") operates the online gaming platform accessible at top7777.app and any associated mobile applications (collectively, the "Platform"). We are committed to protecting the privacy and personal data of every player and visitor who interacts with the top7777 Platform.

This Privacy Policy ("Policy") describes how top7777 collects, uses, stores, shares, and protects your personal information when you register an account, use our services, or otherwise interact with the Platform. It also explains the rights available to you under applicable Philippine data protection law.

This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, which are incorporated by reference. By registering an account or using the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

If you do not agree with any part of this Policy, you must discontinue use of the Platform and may request account closure by contacting our support team.

02 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, top7777 acts as the Personal Information Controller in respect of the personal data collected through the Platform.

top7777 is responsible for determining the purposes and means of processing your personal data. Where top7777 engages third-party service providers to process personal data on its behalf, those providers act as Personal Information Processors and are bound by data processing agreements that require them to handle your data only in accordance with top7777's instructions and applicable law.

For all data privacy inquiries, requests, and complaints, you may contact top7777's designated Data Protection Officer at: [email protected]

03 Personal Data We Collect

top7777 collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

3.1 Registration & Identity Data

• Full legal name as it appears on your government-issued identification
• Date of birth (to verify the 21+ age requirement)
• Email address and mobile phone number
• Username and encrypted password
• Residential address (city, province, postal code)

3.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, UMID, driver's license, PhilSys national ID)
• Proof of address documents (e.g., utility bills, bank statements)
• Proof of payment method ownership where required
• Selfie or liveness verification images where applicable

3.3 Financial & Transaction Data

• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method references
• GCash, PayMaya, BPI, BDO, Metrobank, or other payment account identifiers (masked where possible)
• Account balance history and bonus transaction records

3.4 Gaming Activity Data

• Game session logs, including games played, wager amounts, wins, and losses
• Bonus usage and wagering requirement progress
• Responsible gaming tool settings (deposit limits, session reminders, self-exclusion status)

3.5 Technical & Device Data

• IP address and approximate geolocation derived from IP
• Device type, operating system, and browser information
• Session identifiers and authentication tokens
• Cookie data and similar tracking technologies (see Section 7)

3.6 Communications Data

• Records of your communications with top7777 customer support
• Feedback, survey responses, and promotional opt-in preferences

top7777 does not intentionally collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive data is collected (such as government ID numbers), it is handled with heightened security measures.

04 How We Use Your Personal Data

top7777 uses the personal data we collect for the following purposes:

top7777 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

05 Legal Basis for Processing

top7777 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform the contract between you and top7777 — specifically, to provide you with access to the Platform, process your transactions, and manage your account.
• Legal obligation: Processing is required to comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, age verification requirements, and regulatory reporting duties.
• Legitimate interests: Processing is necessary for top7777's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and improving the quality of our services, provided those interests are not overridden by your rights and interests.
• Consent: For certain processing activities — such as sending you marketing communications or using non-essential cookies — top7777 relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

06 Data Sharing & Disclosure

top7777 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

6.1 Service Providers

top7777 engages trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), KYC and identity verification providers, cloud hosting and infrastructure providers, customer support platform providers, and fraud detection and cybersecurity services. These providers are contractually bound to process your data only on top7777's instructions and in accordance with applicable data protection law.

6.2 Regulatory and Law Enforcement Authorities

top7777 may disclose personal data to Philippine government agencies, regulatory bodies, or law enforcement authorities where required by law, court order, or regulatory directive. This includes disclosures required under the Anti-Money Laundering Act (AMLA) and its amendments, and any applicable PAGCOR regulatory requirements.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of top7777's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to this Privacy Policy that result from it.

6.4 With Your Consent

top7777 may share your personal data with other third parties where you have given your explicit consent to such sharing.

top7777 does not transfer your personal data to recipients outside the Philippines except where necessary to provide the Platform's services (for example, to cloud infrastructure providers) and only where adequate data protection safeguards are in place.

07 Cookies & Tracking Technologies

top7777 uses cookies and similar technologies (such as local storage and session tokens) on the Platform. Cookies are small text files placed on your device that help us provide a functional and secure gaming experience.

Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and responsible gaming tool configurations to personalize your experience.
• Analytics Cookies: Help top7777 understand how players use the Platform in aggregate — such as which games are most popular and where players encounter difficulties — so we can improve our services. Analytics data is processed in aggregated, anonymized form where possible.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and bot traffic on the Platform.

top7777 does not use third-party advertising or cross-site tracking cookies. You can manage cookie preferences through your browser settings; however, disabling strictly necessary cookies may impair your ability to use the Platform.

08 Data Retention

top7777 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML and regulatory record-keeping requirements.
• KYC verification documents: Retained for a minimum of five (5) years following the completion of the verification process or account closure, whichever is later.
• Financial transaction records: Retained for a minimum of five (5) years following the date of the transaction, in compliance with applicable financial regulations.
• Gaming activity logs: Retained for a minimum of two (2) years following the date of the gaming session, or longer where required for dispute resolution or regulatory purposes.
• Customer support communications: Retained for a minimum of two (2) years following the resolution of the relevant support interaction.
• Marketing consent records: Retained for the duration of your consent and for a reasonable period thereafter to demonstrate compliance.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with top7777's data disposal procedures.

09 Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by top7777:

• Right to be Informed: You have the right to be informed about how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right to Access: You may request a copy of the personal data top7777 holds 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. You can update basic account information directly through your top7777 account settings.
• 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 top7777's legal retention obligations.
• Right to Object: You may object to the processing of your personal data where top7777 relies on legitimate interests as the legal basis, or where your data is used for direct marketing purposes.
• Right to Data Portability: You may request that top7777 provide 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. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe top7777 has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, please contact top7777's Data Protection Officer at [email protected]. top7777 will respond to verified requests within thirty (30) calendar days. We may need to verify your identity before processing your request.

10 Data Security

top7777 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the top7777 Platform
• Encryption of sensitive data at rest, including KYC documents and financial records
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Multi-factor authentication requirements for administrative access to systems containing personal data
• Regular security assessments, vulnerability scanning, and penetration testing
• Incident response procedures for detecting, reporting, and responding to personal data breaches
• Staff training on data protection obligations and secure data handling practices

While top7777 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. top7777 cannot guarantee absolute security and is not responsible for unauthorized access resulting from circumstances beyond our reasonable control, including breaches caused by your own failure to maintain the security of your account credentials.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, top7777 will notify affected players and the National Privacy Commission in accordance with the requirements of the Data Privacy Act and its implementing rules.

11 Children's Privacy

The top7777 Platform is strictly intended for adults aged 21 years and above in compliance with Philippine gambling regulations. top7777 does not knowingly collect personal data from individuals under the age of 21.

If top7777 discovers or has reason to believe that a registered account belongs to a person under 21 years of age, we will immediately suspend the account, conduct an investigation, and take appropriate action including permanent account closure and forfeiture of any balance in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that a minor has registered on the top7777 Platform or provided us with personal data, please contact us immediately at [email protected] so that we can take prompt action.

12 Third-Party Links

The top7777 Platform may contain links to internal pages and features. Where the Platform integrates with third-party payment providers such as GCash, PayMaya, BPI, BDO, or Metrobank for the purpose of processing transactions, those providers operate under their own privacy policies and data protection practices.

top7777 is not responsible for the privacy practices or content of third-party payment processors or any other external services you may access in connection with using the Platform. We encourage you to review the privacy policies of any third-party service providers you interact with when using top7777's payment features.

top7777 does not embed third-party advertising networks, social media tracking pixels, or external analytics services that would share your personal data with unrelated third parties.

13 Changes to This Privacy Policy

top7777 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or Platform features. When material changes are made, top7777 will notify registered players via the email address associated with their account and by posting a prominent notice on the Platform.

The "Last Updated" date at the top of this page will be revised whenever this Policy is updated. Your continued use of the Platform after the effective date of any revised Privacy Policy constitutes your acknowledgment of the updated Policy.

We recommend reviewing this Privacy Policy periodically to stay informed about how top7777 protects your personal data. If you have concerns about any changes, you may contact our Data Protection Officer or request account closure.

14 Contact & Complaints

If you have any questions, concerns, or requests regarding this Privacy Policy or the way top7777 handles your personal data, please contact our Data Protection Officer:

Email: [email protected]

Platform: top7777.app

top7777 will acknowledge your inquiry within five (5) business days and aim to resolve all data privacy requests within thirty (30) calendar days. For complex requests, we may require additional time and will notify you accordingly.

If you are not satisfied with top7777's response to your data privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the government body responsible for administering and implementing the Data Privacy Act of 2012.

For questions about your account, payments, or gaming activity, you may also visit our FAQ page or the Finance / Wallet section of the Platform.

This Privacy Policy was last updated in January 2026 and supersedes all previous versions.