Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how pin77.com ("we," "us," "our," or "the Platform") collects, uses, stores, shares, and protects the personal data of individuals ("you," "Player," or "User") who access or use the pin77.com website, games, and related services.

pin77.com is committed to protecting the privacy and personal data of all players, particularly those based in the Philippines. This Policy is drafted in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC).

By registering an account on pin77.com , depositing funds, or otherwise using pin77.com in any capacity, 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 this Policy, you must not use pin77.com.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, pin77.com acts as the Personal Information Controller (PIC) in respect of the personal data it collects from players. This means pin77.com determines the purposes and means of processing your personal data.

Where pin77.com engages third-party service providers to process personal data on its behalf (for example, payment processors or identity verification providers), those parties act as Personal Information Processors (PIPs) and are contractually bound to process data only on pin77.com's documented instructions and in accordance with applicable data privacy law.

3 Personal Data We Collect

pin77.com collects the following categories of personal data, depending on how you interact with the platform:

4 How We Collect Your Data

pin77.com collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access pin77.com, including through cookies, web beacons, and server logs (see Section 10 for details);
• Third-party sources: Identity verification data from KYC service providers; fraud signals from payment processors; publicly available information used for AML screening.

pin77.com does not purchase personal data lists from data brokers or third-party marketing companies.

5 How We Use Your Personal Data

pin77.com uses your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your pin77.com account;
• Identity and age verification: Confirming that you meet the 21+ age requirement and verifying your identity in compliance with KYC obligations;
• Payment processing: Facilitating deposits and withdrawals via GCash, Maya, bank transfer, and debit card;
• Game operation: Delivering games, recording results, calculating winnings, and resolving disputes;
• Regulatory compliance: Meeting obligations under Philippine gaming regulations, the Data Privacy Act, and anti-money laundering laws;
• Fraud and security: Detecting, investigating, and preventing fraudulent activity, unauthorized access, and other security threats;
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behavior and enforcing player-set limits and self-exclusion requests;
• Customer support: Responding to your inquiries, complaints, and support requests;
• Marketing communications: Sending you promotional offers and updates about pin77.com, where you have consented to receive such communications. You may opt out at any time;
• Platform improvement: Analyzing usage patterns to improve the performance, features, and user experience of pin77.com.

6 Legal Basis for Processing

Under the Data Privacy Act of 2012, pin77.com processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and pin77.com (i.e., operating your account, processing payments, delivering games);
• Legal obligation: Processing required to comply with applicable laws, including KYC/AML obligations, gaming regulations, and tax reporting requirements;
• Legitimate interests: Processing for fraud prevention, security monitoring, and platform improvement, where these interests are not overridden by your privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing & Disclosure

pin77.com does not sell your personal data. We may share your data with the following categories of recipients only where necessary and under appropriate safeguards:

• Payment processors: GCash, Maya, and banking partners, solely to process your financial transactions;
• Identity verification providers: Third-party KYC service providers used to verify your identity and age;
• Game providers: Licensed third-party game studios that supply games on the pin77.com platform, who may receive anonymized session data for game operation purposes;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities, where required by law or regulatory order;
• Law enforcement: Philippine law enforcement agencies, where required by a valid legal process or where disclosure is necessary to prevent or investigate a crime;
• Professional advisers: Lawyers, auditors, and accountants, subject to professional confidentiality obligations.

8 Data Retention

pin77.com retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulation. Specific retention periods include:

• Account and identity data: Retained for the duration of your account plus a minimum of 5 years after account closure, in compliance with AML record-keeping requirements;
• Financial transaction records: Retained for a minimum of 5 years from the date of each transaction, as required by the Anti-Money Laundering Act;
• Gaming records: Retained for a minimum of 3 years for dispute resolution and regulatory audit purposes;
• Support communications: Retained for 2 years from the date of the last interaction;
• Marketing consent records: Retained until you withdraw consent, plus a reasonable period thereafter as evidence of the consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with pin77.com's data disposal procedures.

9 Security Measures

pin77.com implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction:

• Encryption: All data in transit is protected by 256-bit SSL/TLS encryption. Sensitive data at rest is encrypted using AES-256;
• Access controls: Personal data is accessible only to authorized pin77.com personnel on a strict need-to-know basis, enforced through role-based access controls;
• Two-factor authentication: Available for all player accounts and mandatory for administrative access to systems containing personal data;
• Regular security audits: pin77.com conducts periodic penetration testing and vulnerability assessments of its systems;
• Incident response: pin77.com maintains a documented data breach response procedure. In the event of a personal data breach that poses a real risk to affected individuals, we will notify the NPC and affected players within the timeframes required by the DPA.

10 Cookies & Tracking Technologies

pin77.com uses cookies and similar tracking technologies to operate the platform, remember your preferences, and analyze usage patterns. The following types of cookies are used:

• Strictly necessary cookies: Essential for the platform to function. These cannot be disabled as they are required for login sessions, security, and core game functionality;
• Functional cookies: Remember your preferences such as language settings and responsible gaming limits to provide a personalized experience;
• Analytics cookies: Collect anonymized data about how players use pin77.com to help us improve the platform. Used only with your consent;
• Session cookies: Temporary cookies that expire when you close your browser, used to maintain your login session during a visit.

You can manage your cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to use the core features of pin77.com, though some personalization features may be limited.

11 Minors

pin77.com is strictly an adult platform. In accordance with Philippine gaming regulations, you must be at least 21 years of age to register and use pin77.com. We do not knowingly collect personal data from individuals under 21 years of age.

If pin77.com discovers or has reason to believe that an account belongs to a person under 21, the account will be immediately suspended, all associated data will be reviewed, and the matter may be referred to the appropriate authorities. Any funds in such an account will be handled in accordance with applicable regulations.

If you are a parent or guardian and believe that a minor has registered on pin77.com, please contact our support team immediately so we can take appropriate action.

12 Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by pin77.com:

• Right to be informed: The right to know what personal data pin77.com collects about you and how it is used — which is the purpose of this Policy;
• Right of access: The right to request a copy of the personal data pin77.com 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 our legal retention obligations;
• Right to object: The right to object to 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, machine-readable format;
• Right to lodge a complaint: The right to file 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 pin77.com's Data Protection Officer using the contact details in Section 15. We will respond to all verified requests within 15 business days, in accordance with NPC guidelines.

13 International Data Transfers

pin77.com primarily processes personal data within the Philippines. Where it is necessary to transfer personal data to recipients located outside the Philippines — for example, to international game providers or cloud infrastructure providers — pin77.com ensures that such transfers are conducted in compliance with the DPA and NPC guidelines.

Safeguards for international transfers may include standard contractual clauses approved by the NPC, binding corporate rules, or transfers to countries that the NPC has recognized as providing an adequate level of data protection.

14 Changes to This Privacy Policy

pin77.com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. When material changes are made, we will notify registered players by email or through a prominent notice on the platform at least 7 days before the changes take effect.

The "Last updated" date at the top of this Policy indicates when it was most recently revised. Your continued use of pin77.com after the effective date of any revised Policy constitutes your acceptance of the updated terms. We encourage you to review this Policy periodically.

15 Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data privacy rights, or want to raise a concern about how pin77.com handles your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 through the pin77.com website
• General Support: [email protected]

We aim to acknowledge all privacy-related inquiries within 3 business days and to resolve them within 15 business days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines through official government channels.