nn77a Privacy Policy

Who We Are

This Privacy Policy is issued by nn77a ("nn77a," "we," "us," or "our"), the operator of the online casino and sports betting platform accessible at nn77a.com. nn77a operates under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to the laws of the Republic of the Philippines.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, hereinafter "DPA"), nn77a acts as the Personal Information Controller in respect of the personal data it collects from players and visitors to the nn77a platform.

This Privacy Policy applies to all personal data collected through the nn77a website, mobile-optimised web application, customer support channels, and any other touchpoints through which you interact with nn77a.

Data We Collect

nn77a collects the following categories of personal data from players and platform visitors:

How We Collect Data

nn77a collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification (KYC), making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the nn77a platform, including through cookies, web beacons, and server logs. See Section 7 for details on our cookie practices.
• Third-party sources: Identity verification data from KYC service providers; fraud and risk signals from payment processors; publicly available information used to verify your identity or comply with anti-money laundering (AML) obligations.
• Regulatory sources: Information received from PAGCOR or other competent Philippine authorities in connection with regulatory compliance obligations.

Why We Use Your Data

nn77a uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your nn77a account, including processing your registration and verifying your identity.
• Service delivery: To provide access to casino games, sports betting markets, live dealer games, bingo, and all other features of the nn77a platform.
• Payment processing: To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other supported payment methods.
• Regulatory compliance: To fulfil our obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA), and the Philippine Data Privacy Act, including age verification (21+), KYC, and transaction monitoring.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct on the platform.
• Responsible gaming: To monitor gaming behaviour, identify signs of problem gambling, and administer self-exclusion, deposit limits, and other responsible gaming tools.
• Customer support: To respond to your enquiries, resolve disputes, and improve our support services.
• Marketing communications: To send you promotional offers, bonuses, and platform updates — only where you have given your explicit consent to receive such communications.
• Platform improvement: To analyse usage patterns, conduct research, and improve the features, performance, and security of the nn77a platform.

Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, nn77a processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your nn77a account and deliver the services you have registered for.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AMLA obligations, and NPC requirements.
• Legitimate interests: Processing necessary for nn77a's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — primarily for marketing communications and optional platform features. You may withdraw consent at any time without affecting the lawfulness of prior processing.

Data Sharing & Disclosure

nn77a does not sell your personal data. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash (Mynt), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, UnionBank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and comply with regulatory obligations.
• Game content providers: Licensed game studios and software providers whose games are available on the nn77a platform, to the extent necessary for game delivery and dispute resolution.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory instruction.
• IT and infrastructure providers: Cloud hosting, cybersecurity, and platform infrastructure providers engaged by nn77a to operate the platform, subject to strict data processing agreements.
• Professional advisers: Legal counsel, auditors, and compliance consultants, where necessary for the conduct of nn77a's business.

All third parties with whom nn77a shares personal data are required to handle that data in accordance with applicable data protection laws and nn77a's data protection standards.

Cookies & Tracking Technologies

nn77a uses cookies and similar tracking technologies to operate and improve the platform. Cookies are small text files stored on your device when you visit the nn77a website.

We use the following types of cookies:

• Strictly necessary cookies: Essential for the platform to function. These include session authentication cookies and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language, display settings) to personalise your experience on the nn77a platform.
• Analytics cookies: Collect anonymised data about how players use the platform, helping us identify areas for improvement. No personally identifiable information is included in analytics data.
• Marketing cookies: Used only where you have consented, to deliver relevant promotional content within the nn77a platform.

You can manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair the functionality of the nn77a platform. nn77a does not use third-party advertising networks or cross-site tracking cookies.

Data Retention

nn77a retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR licensing requirements and AMLA obligations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• Gaming history: Retained for a minimum of three (3) years from the date of the relevant gaming session.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with nn77a's data disposal procedures.

Data Security

nn77a 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:

• AES-256 encryption for data stored at rest on nn77a servers.
• TLS 1.3 encryption for all data transmitted between your device and the nn77a platform.
• Multi-factor authentication (MFA) options for player accounts.
• 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 practices.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, nn77a will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the DPA.

Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by nn77a:

• Right to be informed: The right to be notified of how your personal data is collected and processed — which this Privacy Policy fulfils.
• Right of access: The right to request a copy of the personal data nn77a holds about you.
• 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, subject to nn77a's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact nn77a's Data Protection Officer using the contact details in Section 14. nn77a will respond to all valid data subject requests within thirty (30) days of receipt.

Children's Privacy

The nn77a platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine gambling regulations. nn77a does not knowingly collect personal data from individuals under the age of 21.

If nn77a becomes aware that personal data has been collected from a person under 21 years of age, the relevant account will be immediately suspended, all associated data will be deleted, and any funds in the account will be handled in accordance with applicable regulatory requirements.

If you believe that a minor has registered on the nn77a platform, please contact our support team immediately so that we can take prompt action.

Cross-Border Data Transfers

nn77a's primary data processing infrastructure is located within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international game content studios.

Where such transfers occur, nn77a ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual clauses requiring the recipient to apply data protection standards equivalent to those required under the Philippine DPA.
• Transfers only to countries or organisations that the NPC has determined provide an adequate level of data protection.
• Your explicit consent, where required by applicable law.

You may request details of the safeguards applicable to any specific cross-border transfer by contacting our Data Protection Officer.

Updates to This Privacy Policy

nn77a may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players via the email address associated with their account and/or by displaying a prominent notice on the nn77a platform.

The effective date of the current version of this Privacy Policy is displayed at the top of this page. We encourage you to review this Privacy Policy periodically to stay informed about how nn77a protects your data.

Your continued use of the nn77a platform following the publication of any updates to this Privacy Policy constitutes your acknowledgement of the revised policy.

Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or nn77a's data practices, please contact our Data Protection Officer (DPO):

• Email: [email protected]
• Live Chat: Available within the nn77a platform 24/7 after login.
• Response time: nn77a aims to acknowledge all privacy-related enquiries within 3 business days and to resolve them within 30 calendar days.

If you are not satisfied with nn77a's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) through its official complaints process.