af77 Privacy Policy

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, af77 acts as the Personal Information Controller (PIC) in respect of all personal data collected from players, prospective players, and visitors to the af77 Platform at af77.biz.

af77 is a PAGCOR-licensed online gaming operator serving Filipino players across the Philippines. As a licensed gaming operator, af77 is subject to PAGCOR's data governance requirements in addition to the obligations imposed by the Data Privacy Act and the National Privacy Commission (NPC).

References in this Privacy Policy to "af77," "we," "us," or "our" refer to the af77 gaming platform and its duly authorized operators. References to "you," "your," or "Player" refer to any individual whose personal data af77 processes in connection with the af77 Platform.

This Privacy Policy applies to all personal data collected and processed by af77 in connection with:

• Registration and maintenance of af77 player accounts
• Use of any service, product, or feature available on the af77 Platform, including live casino, slots, sports betting, Bingo, Monster Hi-Lo, and Color Prediction
• Processing of deposits, withdrawals, and other financial transactions through af77's supported Philippine payment channels (GCash, PayMaya, BPI, BDO, Metrobank)
• KYC identity and age verification required under PAGCOR licensing and Philippine anti-money laundering regulations
• Customer support interactions via live chat or email
• Participation in af77 promotions, bonus programs, and loyalty schemes
• Browsing the af77 website at af77.biz, whether or not you are a registered Player

This Privacy Policy does not apply to third-party websites, services, or products that may be referenced on the af77 Platform but are not operated or controlled by af77. Interactions with payment processors, software providers, or any external platform are governed by their respective privacy policies.

af77 collects the following categories of personal data in the operation of its licensed gaming platform:

af77 collects personal data through the following channels and mechanisms:

4.1 Directly From You: When you register an af77 account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in a promotion, you provide personal data directly to af77.

4.2 Automatically During Platform Use: When you access the af77 Platform, technical data is collected automatically through cookies, server logs, and similar tracking technologies. This includes your IP address, browser details, and session activity data.

4.3 From Third-Party Verification Services: af77 may receive identity and age verification data from third-party KYC service providers engaged to assist with PAGCOR-mandated verification requirements.

4.4 From Payment Processors: af77 receives transaction confirmation data from Philippine payment processors (GCash, PayMaya, banks) sufficient to match a deposit or withdrawal to your af77 account, but does not receive full payment credentials.

4.5 From Fraud Prevention Services: af77 may receive risk signals or device fingerprinting data from licensed fraud detection service providers for the purpose of protecting the Platform and its players from fraud, account takeover, and money laundering.

af77 processes personal data collected from Filipino players for the following specific, legitimate, and declared purposes:

• Account Registration and Management: To create, maintain, and manage your af77 player account, including processing af77 login sessions and authenticating your identity.
• KYC and Age Verification: To comply with PAGCOR licensing requirements mandating identity and age verification of all registered players. af77 is legally required to verify that all players are at least 21 years of age.
• Payment Processing: To process deposits and withdrawals through your chosen Philippine payment method (GCash, PayMaya, BPI, BDO, or Metrobank) and to maintain accurate transaction records as required by PAGCOR and Philippine financial regulations.
• Anti-Money Laundering (AML) Compliance: To monitor transactions, detect suspicious patterns, and report to relevant Philippine authorities as required under Republic Act No. 9160 (the Anti-Money Laundering Act) and PAGCOR AML directives.
• Fraud Prevention and Platform Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, bonus abuse, and other forms of misconduct that could harm af77 or its players.
• Game Delivery and Platform Operation: To provide access to af77's game library, process bets and payouts accurately, maintain bet records, and deliver promotions and bonus entitlements.
• Responsible Gaming: To implement and monitor responsible gaming tools, including deposit limits, session limits, cooling-off periods, and self-exclusion, and to identify and respond to signs of problematic gaming behavior.
• Customer Support: To respond to your inquiries, resolve complaints, and provide assistance through af77's live chat and email support channels.
• Legal and Regulatory Compliance: To comply with PAGCOR's reporting requirements, National Privacy Commission obligations, Philippine tax regulations, and any other applicable legal obligation.
• Marketing Communications (with consent): To send promotional emails, bonus notifications, and personalized game recommendations to Players who have opted in to marketing communications from af77.
• Platform Improvement: To analyze aggregated and anonymized usage data for the purpose of improving the af77 Platform's performance, user experience, and game library.

af77 processes personal data only where a lawful basis exists under the Philippine Data Privacy Act of 2012. The specific legal bases applicable to af77's processing activities are as follows:

Compliance with a Legal Obligation: Processing of identity, age verification, AML transaction monitoring, and responsible gaming data is required by PAGCOR regulations, Republic Act No. 10173, Republic Act No. 9160, and other applicable Philippine laws. af77 has no discretion to avoid this processing.

Performance of a Contract: Processing of account data, contact data, and payment data is necessary to fulfill af77's contractual obligations to you under the Terms and Conditions you accepted at registration — including delivering gaming services, processing your withdrawals, and maintaining your account.

Legitimate Interests: Processing of gaming activity data, technical data, and communication data is conducted on the basis of af77's legitimate interests in operating a secure, fair, and commercially viable PAGCOR-licensed gaming platform. These interests are balanced against your privacy rights and do not override them.

Consent: Processing of data for marketing communications is conducted only on the basis of your freely given, specific, and informed consent. You have the right to withdraw this consent at any time without affecting the lawfulness of any processing carried out before withdrawal.

af77 does not sell, rent, or trade your personal data to any third party. af77 shares personal data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• PAGCOR: af77 is required to provide player data, transaction records, and gaming activity reports to PAGCOR as part of its ongoing licensing obligations. Such disclosures are mandatory and govern af77's continued authorization to operate.
• Philippine Law Enforcement and Regulatory Authorities: af77 will disclose personal data to the Anti-Money Laundering Council (AMLC), National Privacy Commission (NPC), Bureau of Internal Revenue (BIR), or other relevant Philippine government agencies where legally required by court order, regulatory direction, or applicable law.
• Licensed Payment Processors: Transaction data necessary to process your deposit or withdrawal is shared with GCash, PayMaya, BPI, BDO, or Metrobank as applicable. These processors operate under their own regulatory obligations and privacy frameworks.
• KYC Verification Service Providers: Identity documents and verification data are processed by third-party KYC providers contracted by af77 under data processing agreements that bind those providers to confidentiality and data protection obligations consistent with the Philippine DPA.
• Game Software Providers: For the purpose of delivering live dealer games and RNG slots, limited session data (Player ID, bet amounts, game outcomes) is shared with af77's licensed game software providers under data processing agreements.
• Fraud Prevention and Security Providers: Technical and behavioral data is shared with licensed fraud prevention service providers for the purpose of protecting the af77 Platform and its players.
• Professional Advisers: af77's legal counsel, auditors, and compliance advisers may receive personal data on a confidential basis where necessary to provide professional services to af77.

Some of af77's third-party service providers — including game software platforms and fraud prevention tools — may process personal data on servers located outside the Philippines. Where such international transfers occur, af77 ensures that adequate safeguards are in place in accordance with Section 21 of the Data Privacy Act and the NPC's rules on cross-border data flows.

Safeguards applicable to international transfers by af77 include: binding data processing agreements with contractual clauses meeting Philippine DPA standards, transfers only to jurisdictions recognized by the NPC as providing adequate levels of data protection, and supplier due diligence reviews assessing the data protection practices of any offshore processor.

If you would like further information about the specific safeguards af77 applies to international data transfers, you may contact af77's Data Protection Officer using the contact details provided in Section 16 of this Policy.

af77 retains personal data for no longer than is necessary to fulfill the purposes for which it was collected, unless a longer retention period is required or permitted by applicable Philippine law or PAGCOR regulatory requirements. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your active af77 account and for a minimum of five (5) years after account closure, as required by PAGCOR licensing terms and Philippine AML regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, consistent with Philippine financial record-keeping requirements and PAGCOR audit obligations.
• Gaming Activity Records: Retained for a minimum of three (3) years from the date of the gaming session, sufficient to support dispute resolution and regulatory inquiry.
• Communication and Support Records: Retained for two (2) years from the date of the communication, or longer where the subject of the communication is the subject of an active dispute or regulatory investigation.
• Technical and Log Data: Retained for twelve (12) months, except where specific log records are required for active fraud or security investigations.
• Marketing Data: Retained until you withdraw your consent to marketing communications from af77, after which marketing data will be deleted or anonymized within thirty (30) days.

af77 implements technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to:

• Encryption in Transit: All data transmitted between your browser or device and the af77 Platform is encrypted using TLS 1.2 or higher (HTTPS). Login credentials and financial data are never transmitted in plaintext.
• Encryption at Rest: Sensitive personal data stored on af77's systems is encrypted at rest using AES-256 or equivalent standard. This includes identity documents, financial records, and authentication credentials.
• Access Controls: Access to personal data within af77 is strictly limited on a need-to-know basis, enforced through role-based access controls and multi-factor authentication for administrative systems.
• Password Security: af77 account passwords are hashed using a one-way cryptographic function before storage. af77 staff cannot read your password in any form. This is why af77 support will never ask for your password.
• Intrusion Detection and Monitoring: af77's systems are continuously monitored for security incidents, unauthorized access attempts, and anomalous activity patterns.
• Third-Party Security Assessments: af77 conducts periodic security assessments and vulnerability testing to identify and remediate security weaknesses in its systems.
• Incident Response: af77 maintains a documented data breach incident response procedure. In the event of a personal data breach that poses a risk to your rights, af77 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay where required.

af77 uses cookies and similar tracking technologies (including local storage and session tokens) on the af77 Platform. The following categories of cookies are used:

Strictly Necessary Cookies: These cookies are essential to the operation of the af77 Platform. They maintain your af77 login session, store your authentication token during an active session, and enable core security functions such as CSRF protection. These cookies cannot be disabled without preventing you from using af77's services.

Functional Cookies: These cookies remember your Platform preferences (such as language settings, display preferences, and last-accessed game category) to provide a more convenient experience when you return to af77. These cookies do not track your activity across other websites.

Analytics Cookies: af77 uses aggregated, anonymized analytics data to understand how players use the Platform — which pages are most visited, how long sessions last, and which features are most used. This data is used only to improve the af77 Platform and is not linked to individual player identities.

You can manage cookie preferences through your browser settings. Blocking strictly necessary cookies will prevent you from accessing your af77 account. Blocking functional or analytics cookies will not affect your ability to play but may reduce your experience on the Platform.

Under the Philippine Data Privacy Act of 2012, af77 players have the following enforceable rights with respect to their personal data. These rights may be exercised by contacting af77's Data Protection Officer at the details provided in Section 16.

To exercise any of the above rights, contact af77's Data Protection Officer by email at [email protected] or via live chat on the af77 Platform. af77 will respond to all verifiable requests within thirty (30) calendar days. af77 will not charge a fee for exercising your rights unless requests are manifestly unfounded, repetitive, or excessive.

The af77 Platform is strictly intended for adults who are at least twenty-one (21) years of age, as required by PAGCOR and Philippine gaming law. af77 does not knowingly collect personal data from any individual under the age of 21.

Any account registered by, or found to be used by, a person under 21 years of age will be immediately suspended. All personal data associated with such an account will be deleted to the minimum extent permitted by applicable law, and any funds in the account will be handled in accordance with PAGCOR's applicable guidelines.

af77 may send you marketing communications — including bonus offers, promotional emails, game announcements, and personalized recommendations — only where you have given your explicit consent to receive such communications at the time of account registration or thereafter.

You may withdraw your consent to marketing communications from af77 at any time by:

• Clicking the "Unsubscribe" link in any marketing email you receive from af77
• Updating your communication preferences in your af77 account settings
• Contacting af77 support via live chat or email at [email protected] with a clear request to stop marketing communications

Withdrawal of marketing consent will be processed within five (5) business days. Note that transactional communications — such as deposit confirmations, withdrawal notifications, security alerts, and account verification messages — are not marketing communications and will continue to be sent regardless of your marketing preference, as they are necessary for the operation of your af77 account.

af77 may update this Privacy Policy from time to time to reflect changes in applicable law, PAGCOR regulatory requirements, af77's data processing activities, or industry best practice. When material changes are made, af77 will notify registered Players by email to their registered address, or by a prominent notice on the af77 Platform, at least seven (7) days before the revised Policy takes effect.

The effective date of the current version of this Privacy Policy is stated at the top of the document. Continued use of the af77 Platform after the effective date of any revision constitutes your acknowledgment of the updated Policy. If you do not agree with the revised Policy, you should cease using the af77 Platform and may request account closure.

All previous versions of this Privacy Policy are archived and available upon request to af77's Data Protection Officer.

af77 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Philippine Data Privacy Act. The af77 DPO is the primary point of contact for all privacy-related inquiries, rights requests, and complaints from Filipino players.

• Role: Data Protection Officer, af77
• Email: [email protected] — Please include "Data Privacy Request" in the subject line for all privacy-related inquiries
• Live Chat: Available 24/7 via the af77 Platform — mention "Data Privacy" at the start of your chat session
• Response Time: af77 acknowledges all DPO inquiries within two (2) business days and provides a substantive response within thirty (30) calendar days

If you are not satisfied with af77's response to a privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.

This Privacy Policy is governed by, and shall be construed in accordance with, the laws of the Republic of the Philippines, including specifically Republic Act No. 10173 (the Data Privacy Act of 2012), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission.

Any dispute arising out of or in connection with this Privacy Policy, including any question regarding its existence, validity, or termination, shall be subject to the exclusive jurisdiction of the competent courts and regulatory bodies of the Republic of the Philippines.