pin 77 Privacy Policy

1. Data Controller

pin 77 ("pin 77," "we," "us," or "our") is the data controller responsible for the personal information collected through the pin 77 online gaming platform accessible at pin77.asia and any associated mobile-optimised interfaces (collectively, the "Platform"). As data controller, pin 77 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Data Privacy Act of 2012 (Republic Act No. 10173, as amended), its Implementing Rules and Regulations, and all applicable issuances of the National Privacy Commission (NPC) of the Philippines.

This Privacy Policy applies to all registered players, visitors, and any other individuals whose personal data is processed by pin 77 in connection with the Platform. By registering an account or continuing to use 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.

2. Information We Collect

2.1 Information You Provide Directly

When you register an account, complete identity verification, make a deposit or withdrawal, contact customer support, or participate in a promotion, pin 77 may collect the following categories of personal information:

• Identity data: Full legal name, date of birth, gender, nationality, and a copy of your government-issued identification document (e.g., PhilSys National ID, passport, driver's licence, SSS/GSIS ID, or PRC ID).
• Contact data: Email address, mobile number, and residential address (including city, province, and postal code).
• Financial data: GCash account number, PayMaya/Maya account details, bank account number and bank name (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, or other eligible Philippine banks), and debit card details where applicable. pin 77 does not store full card numbers; payment tokenisation is used where card data is involved.
• Account credentials: Username and encrypted password. pin 77 never stores passwords in plain text.
• Communications data: Records of your correspondence with pin 77 customer support, including live chat transcripts and email exchanges.

2.2 Information Collected Automatically

When you access the Platform, pin 77's systems automatically collect certain technical and behavioural data, including:

• Device and connection data: IP address, device type, operating system, browser type and version, screen resolution, and mobile network information.
• Usage data: Pages visited, games played, session duration, wagering history, deposit and withdrawal history, bonus usage, and navigation patterns within the Platform.
• Geolocation data: Approximate location derived from your IP address, used to verify that you are accessing the Platform from a permitted jurisdiction.
• Cookie and tracking data: Information collected via cookies, web beacons, and similar technologies as described in Section 8 of this Policy.

2.3 Information from Third Parties

pin 77 may receive personal information about you from third-party identity verification providers, payment processors, fraud prevention services, and, where applicable, from publicly available sources such as sanctions lists and politically exposed persons (PEP) databases, in order to comply with our anti-money laundering and KYC obligations under Philippine law.

3. How We Use Your Data

pin 77 processes your personal data for the following purposes:

• Account management: To create, maintain, and administer your pin 77 account, including verifying your identity and eligibility to use the Platform.
• Service delivery: To provide access to games, process deposits and withdrawals, credit bonuses, and deliver customer support.
• Legal and regulatory compliance: To fulfil our obligations under the Data Privacy Act, the Anti-Money Laundering Act (AMLA), PAGCOR regulations, and other applicable Philippine laws, including KYC verification, transaction monitoring, and suspicious activity reporting.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, multi-accounting, bonus abuse, money laundering, and other prohibited conduct.
• Responsible gaming: To monitor gaming behaviour for signs of problem gambling and to administer self-exclusion, deposit limit, and cooling-off requests in accordance with our Responsible Gaming Policy.
• Marketing and promotions: To send you information about pin 77 promotions, bonuses, and new game releases, where you have provided your consent or where we have a legitimate interest in doing so. You may opt out of marketing communications at any time via your account settings or by contacting support.
• Platform improvement: To analyse usage patterns, conduct A/B testing, and improve the functionality, performance, and user experience of the Platform.
• Dispute resolution: To investigate and resolve complaints, disputes, and chargebacks.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, pin 77 processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary to perform the contract between you and pin 77 (i.e., to provide the gaming services you have registered for).
• Legal obligation: Processing is required to comply with applicable Philippine laws and regulations, including AMLA, PAGCOR directives, and NPC issuances.
• Legitimate interests: Processing is necessary for pin 77's legitimate interests in fraud prevention, platform security, and business analytics, provided those interests are not overridden by your rights and freedoms.
• Consent: For marketing communications and the use of non-essential cookies, processing is based 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.

5. Sharing Your Data

pin 77 does not sell 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 and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya/Maya, and Philippine banking partners, for the purpose of processing deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and screen against sanctions and PEP lists.
• Game providers: Software providers whose games are hosted on the pin 77 Platform may receive limited technical data (e.g., session tokens) necessary to deliver the game experience.
• 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 directive.
• Professional advisers: Lawyers, auditors, and accountants engaged by pin 77, subject to professional confidentiality obligations.
• IT and infrastructure providers: Cloud hosting, cybersecurity, and analytics service providers engaged by pin 77 to operate and maintain the Platform, subject to data processing agreements.

All third-party service providers engaged by pin 77 are contractually required to process your personal data only for the specified purpose, to implement appropriate security measures, and to comply with applicable Philippine data protection law.

6. Data Retention

pin 77 retains your personal data for as long as your account is active and for such additional period as is necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Transaction records (deposits, withdrawals, wagers) are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for three (3) years from the date of the last interaction.
• Marketing consent records are retained for the duration of your account and for one (1) year following account closure or withdrawal of consent.
• Cookie and analytics data is retained in accordance with the retention periods specified in our Cookie Policy (see Section 8).

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with pin 77's data disposal procedures.

7. Security Measures

pin 77 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the pin 77 Platform.
• Encryption of sensitive data at rest, including passwords (hashed with a strong one-way algorithm) and financial account details.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning of the Platform's infrastructure.
• Multi-factor authentication options for player accounts and mandatory multi-factor authentication for all pin 77 staff with access to personal data systems.
• Incident response procedures, including notification to the National Privacy Commission and affected data subjects within the timeframes prescribed by the Data Privacy Act in the event of a personal data breach.

While pin 77 takes all reasonable steps to protect your personal data, no system is completely immune to security risks. You are responsible for maintaining the security of your own account credentials and for notifying pin 77 immediately if you suspect any unauthorised access to your account.

8. Cookies & Tracking Technologies

pin 77 uses cookies and similar tracking technologies (such as web beacons and local storage) to operate the Platform, remember your preferences, analyse usage, and deliver relevant content. The categories of cookies used by pin 77 are as follows:

• Strictly necessary cookies: Essential for the Platform to function. These cookies enable core features such as session management, login authentication, and security. They cannot be disabled.
• Functional cookies: Used to remember your preferences (e.g., language, display settings) and to personalise your experience on the Platform.
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the Platform, helping pin 77 identify areas for improvement. These cookies are only set with your consent.
• Marketing cookies: Used to deliver relevant promotional content and to measure the effectiveness of pin 77's marketing campaigns. These cookies are only set with your consent.

You can manage your cookie preferences at any time through the cookie settings panel accessible from the footer of the Platform. Please note that disabling certain cookies may affect the functionality of the Platform.

9. Your Rights Under the Data Privacy Act

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by pin 77:

• Right to be informed: The right to be notified of how your personal data is collected, used, and processed — as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data pin 77 holds about you and information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to pin 77's 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 and to transmit it to another data controller, where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that pin 77 has processed your personal data in violation of the Data Privacy Act.

To exercise any of the above rights, please contact pin 77's Data Protection Officer (DPO) using the contact details provided in Section 13. pin 77 will respond to all data subject requests within thirty (30) calendar days of receipt, in accordance with the Data Privacy Act and NPC regulations.

10. Minors

The pin 77 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine law and PAGCOR regulations. pin 77 does not knowingly collect personal data from individuals under the age of 21. If pin 77 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 without recourse.

If you are a parent or guardian and believe that your child has registered an account or provided personal data to pin 77, please contact our Data Protection Officer immediately using the details in Section 13 so that we can take prompt corrective action.

11. Cross-Border Data Transfers

pin 77 primarily stores and processes your 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 game software vendors operating internationally.

Where such cross-border transfers occur, pin 77 ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that impose data protection obligations equivalent to those required under the Data Privacy Act of 2012. pin 77 will not transfer your personal data to a foreign jurisdiction that does not provide an adequate level of data protection without your explicit consent or without implementing the safeguards required by the NPC.

12. Changes to This Policy

pin 77 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, pin 77 will notify you by posting the revised Policy on the Platform and, where appropriate, by sending a notification to your registered email address. The "Last updated" date at the top of this Policy will be revised accordingly.

Your continued use of the Platform following the posting of a revised Privacy Policy constitutes your acknowledgment of the changes. If you do not agree to the revised Policy, you must cease using the Platform and may request account closure by contacting customer support.

13. Contact & Data Protection Officer

pin 77 has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012 and NPC Circular No. 16-01. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact the pin 77 DPO at:

Data Protection Officer — pin 77
Email: [email protected]

For general customer support enquiries unrelated to data privacy, you may contact our support team at [email protected] or via live chat on the Platform, available 24 hours a day, 7 days a week.

If you are not satisfied with pin 77's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines through its official channels.