pu77 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how pu77 ("we," "us," "our," "the Company") collects, uses, processes, discloses, and protects personal information obtained from users ("you," "Player," "User") of the pu77 online gaming platform accessible at pu77.cam and any associated mobile applications or services (collectively, the "Platform").

pu77 operates under the regulatory authority of the Philippine Amusement and Gaming Corporation (PAGCOR) and is committed to full compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations, and all issuances of the National Privacy Commission (NPC) of the Philippines.

By registering an account, accessing the Platform, or providing your personal information to pu77 in any manner, you acknowledge that you have read this Privacy Policy in full, that you understand how your information will be processed, and that you consent to such processing as described herein. If you do not agree with any part of this Policy, you should not use the Platform or provide any personal information to pu77.

2. Data Controller

For the purposes of the Data Privacy Act of 2012, pu77 is the data controller responsible for the collection, processing, and protection of your personal information. As data controller, we determine the purposes for which and the means by which your personal data is processed.

pu77 has designated a Data Protection Officer (DPO) responsible for overseeing our data protection strategy, ensuring compliance with the DPA and NPC regulations, and serving as the primary point of contact for data subjects exercising their privacy rights. You may contact our DPO through the contact information provided in Section 14 of this Policy.

3. Information We Collect

pu77 collects various categories of personal information necessary to provide gaming services, maintain platform security, and comply with legal and regulatory obligations. The types of information we collect include:

3.1 Registration Information

When you create a pu77 account, we collect the following mandatory information:

• Full legal name (as it appears on government-issued identification)
• Date of birth (to verify you meet the minimum age requirement of 21 years)
• Philippine residential address (street, barangay, city/municipality, province, postal code)
• Valid email address
• Mobile phone number (Philippine +63 number)
• Username and password (encrypted and stored securely)
• Preferred currency (typically PHP)
• Security questions and answers (optional, for account recovery)

3.2 Know Your Customer (KYC) Documents

To comply with PAGCOR licensing requirements and Philippine Anti-Money Laundering Act (AMLA) regulations, we collect and verify identity documents including:

• Philippine government-issued photo identification (National ID, Passport, Driver's License, PRC ID, SSS/GSIS ID, Postal ID, or similar)
• Proof of address documents (utility bills, bank statements, government correspondence not older than 3 months)
• Proof of payment method ownership (screenshots of e-wallet accounts showing your name, bank account statements, or credit card copies with sensitive numbers masked)
• Selfie photograph holding your ID document (for biometric verification in certain cases)

3.3 Financial & Transaction Data

We collect and process information related to all financial transactions on the Platform:

• Deposit amounts, methods, timestamps, and transaction reference numbers
• Withdrawal requests, amounts, destination accounts, and processing status
• Bonus claims, wagering progress, and fulfillment status
• Account balance history and transaction ledgers
• Payment method details (for GCash, Maya, bank account numbers as applicable; cryptocurrency wallet addresses for USDT transactions)

3.4 Gaming Activity & Behavioral Data

We automatically collect data related to your use of the Platform to improve services, detect fraud, and ensure responsible gaming compliance:

• Games played, bet amounts, win/loss records, session durations
• Login timestamps, session frequency, and activity patterns
• Device information (IP address, device type, operating system, browser type, screen resolution)
• Geographic location data (derived from IP address; precise GPS location if you grant permission via mobile app)
• Marketing preferences, bonus opt-ins, promotional communications engagement metrics
• Responsible gaming tool usage (deposit limits set, self-exclusion requests, session timers)

3.5 Communications Data

When you contact pu77 customer support or communicate with us through any channel, we collect and retain:

• Live chat transcripts, email correspondence, and phone call recordings (with your consent where required by law)
• Customer support ticket history, complaint details, and resolution records
• Feedback, survey responses, and product improvement suggestions

3.6 Automatically Collected Technical Data

Our Platform automatically collects certain technical information through cookies and similar technologies:

• Browser cookies, session tokens, and local storage data
• Page views, click paths, referral URLs, and navigation behavior
• Error logs, crash reports, and performance metrics
• Third-party analytics data (Google Analytics or similar, anonymized where possible)

4. Purpose of Processing

pu77 processes your personal information for the following legitimate and lawful purposes:

5. Legal Basis for Processing

pu77 processes your personal information on the following legal bases as recognized under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Consent: For marketing communications, optional profiling, and any processing activity where you have provided clear, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Contractual Necessity: Processing required to fulfill our obligations under the Terms and Conditions you agreed to upon registration, including account management, payment processing, and game provision.
• Legal Obligation: Processing necessary to comply with PAGCOR licensing requirements, the Anti-Money Laundering Act, the Data Privacy Act, tax regulations, and other applicable Philippine laws and regulations.
• Legitimate Interests: Processing necessary for fraud prevention, platform security, responsible gaming enforcement, and the improvement of pu77 services, provided such interests are not overridden by your fundamental rights and freedoms.

6. Data Sharing & Disclosure

pu77 does not sell, rent, or trade your personal information to third parties for commercial marketing purposes. We may share your personal data only in the following limited and lawful circumstances:

6.1 Service Providers & Data Processors

We engage trusted third-party service providers who process data on our behalf under strict contractual agreements that require them to maintain equivalent data protection standards. These include payment processors (GCash, Maya, banking partners), game software providers, fraud detection and identity verification services, cloud hosting and IT infrastructure providers, and customer support platform operators. All such providers are bound by data processing agreements consistent with the DPA.

6.2 Regulatory and Law Enforcement Authorities

pu77 is legally obligated to disclose certain information to Philippine regulatory and law enforcement authorities, including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), and the Philippine National Police or other competent authorities, when required by law, court order, or valid regulatory demand. Such disclosures are made strictly within the scope of the legal requirement and with appropriate records kept.

6.3 Business Transfers

In the event of a merger, acquisition, corporate restructuring, or sale of all or substantially all of pu77's assets, your personal information may be transferred to the successor entity. We will notify you via email and/or a prominent Platform notification before your information becomes subject to a different privacy policy following any such transaction.

6.4 Protection of Rights

We may disclose your information where we reasonably believe disclosure is necessary to enforce our Terms and Conditions, protect the rights, property, or safety of pu77, our employees, our players, or the general public, or to prevent fraud and criminal activity.

7. Data Retention

pu77 retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, as required by applicable law, or as specified below:

• Account and KYC records: Retained for a minimum of five (5) years from the date of account closure, as required by PAGCOR regulations and AMLA compliance obligations.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction, consistent with BIR and AMLC record-keeping requirements.
• Gaming activity logs: Retained for three (3) years for operational, fraud prevention, and dispute resolution purposes.
• Customer support communications: Retained for two (2) years from the resolution of the relevant support interaction.
• Marketing consent records: Retained for the duration of your account plus two (2) years to demonstrate compliance with consent requirements.
• Self-exclusion records: Retained for the duration of the exclusion period plus five (5) years to prevent re-registration circumvention.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized using industry-standard data destruction procedures so that it can no longer be attributed to any identifiable individual.

8. Security Measures

pu77 implements comprehensive technical and organizational security measures to protect your personal information against unauthorized access, accidental loss, destruction, alteration, and unlawful disclosure. Our security infrastructure includes:

• Encryption: All data transmitted between your device and pu77 servers is protected using TLS 1.3 (Transport Layer Security) encryption. Sensitive data at rest, including KYC documents, financial records, and authentication credentials, is encrypted using AES-256 standard.
• Access Controls: Personal data is accessible only to pu77 employees and contractors with a documented operational need. Access is governed by role-based permissions, regularly reviewed, and revoked immediately upon employment termination.
• Two-Factor Authentication: pu77 offers and encourages the use of two-factor authentication (2FA) for all player accounts to add an additional layer of protection beyond username and password.
• Penetration Testing & Vulnerability Assessment: Our Platform undergoes regular third-party security audits, penetration testing, and vulnerability scanning to identify and remediate weaknesses proactively.
• Data Breach Response: We maintain a documented incident response plan. In the event of a personal data breach that is likely to result in risk to your rights and freedoms, pu77 will notify the National Privacy Commission within 72 hours and affected individuals without undue delay, in accordance with NPC Circular requirements.

9. Your Data Rights

Under the Data Privacy Act of 2012, you are entitled to exercise the following rights with respect to your personal information held by pu77. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14:

• Right to Be Informed: The right to know what personal data pu77 holds about you, the purposes for which it is processed, and with whom it is shared — as documented in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data pu77 holds about you in a readable format. We will respond to verified access requests within thirty (30) days.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal information in your pu77 account. You may update many details directly through your account settings.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal obligations to retain certain records for regulatory compliance periods.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to Object: The right to object to processing of your personal data for direct marketing purposes at any time. You may also object to other forms of processing based on legitimate interests, subject to overriding legal grounds.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe pu77 has processed your personal data in violation of the DPA. The NPC may be reached at its official government website and offices.

10. Cookies & Tracking Technologies

pu77 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, and analyze usage patterns. Cookies are small text files placed on your device when you visit pu77.cam. We use the following categories of cookies:

10.1 Strictly Necessary Cookies

These cookies are essential for the Platform to function and cannot be switched off in our systems. They are set in response to your actions such as logging in, setting preferences, and filling in forms. Without these cookies, services you have requested cannot be provided.

10.2 Performance & Analytics Cookies

These cookies allow us to count visits and traffic sources so we can measure and improve Platform performance. They help us understand which pages are most visited and how players navigate the site. All information collected is aggregated and therefore anonymous. If you do not allow these cookies, we will not know when you have visited our Platform.

10.3 Functional Cookies

These cookies enable the Platform to provide enhanced functionality and personalization, such as remembering your preferred language, game layout settings, and display preferences. They may be set by pu77 or by third-party providers whose services are embedded on our pages.

10.4 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse cookies or to delete cookies already stored on your device. Please note that disabling strictly necessary cookies may impair your ability to use certain features of the pu77 Platform, including account login. Detailed instructions for managing cookies in common browsers are available through each browser's help documentation.

11. Protection of Minors

The pu77 Platform is strictly intended for persons aged 21 years and above. We do not knowingly collect personal information from individuals under 21 years of age. Our registration process includes mandatory date of birth verification, and we conduct identity checks as part of our KYC process to enforce this age restriction.

If pu77 discovers or is notified that personal information has been collected from an individual under the age of 21 without proper parental or guardian verification, we will take immediate steps to deactivate the account, delete the relevant personal data, and refund any deposits made to the account in accordance with PAGCOR guidelines.

Parents and guardians who believe their child may have accessed the pu77 Platform or provided personal information to us are encouraged to contact our customer support team immediately. We will investigate and act promptly on all such reports.

12. International Data Transfers

pu77 primarily processes and stores your personal data on servers located within or accessible from the Philippines. In certain cases, such as when engaging international game software providers, cloud infrastructure services, or specialized fraud prevention vendors, your personal data may be transferred to and processed in countries outside the Philippines.

Where such international transfers occur, pu77 ensures that adequate safeguards are in place to protect your personal information at a standard consistent with the Data Privacy Act of 2012. These safeguards include contractual clauses incorporating data protection obligations equivalent to Philippine DPA standards, binding corporate rules where applicable within group entities, and transfer only to jurisdictions deemed adequate by the National Privacy Commission.

By using the pu77 Platform and agreeing to this Privacy Policy, you acknowledge and consent to the potential transfer of your personal information to countries outside the Philippines as described in this section, provided such transfers are conducted with appropriate protections in place.

13. Changes to This Privacy Policy

pu77 reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, regulatory requirements, or Platform features. The effective date of the current version is always displayed at the top of this page.

For material changes that significantly affect how we process your personal data or your privacy rights, pu77 will provide advance notice via email to your registered address and/or a prominent notification within your Platform account dashboard. We recommend checking this page periodically to stay informed of any updates.

Your continued use of the pu77 Platform following notification of material changes constitutes your acceptance of the revised Privacy Policy. If you do not agree with the updated Policy, you should discontinue your use of the Platform and may request account closure in accordance with our Terms and Conditions.

14. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by pu77, please contact us through the following channels:

• Data Protection Officer: Reachable via our customer support team, which will route your inquiry to the appropriate DPO contact.
• Live Chat: Available 24 hours a day, 7 days a week in English and Tagalog via the chat interface on pu77.cam.
• Email: [email protected] — please include "Privacy" or "Data Request" in your subject line for prompt routing.

pu77 aims to respond to all privacy-related inquiries and data subject requests within thirty (30) calendar days of receipt. For complex requests, we may extend this period by up to an additional thirty (30) days, in which case we will notify you of the extension and the reason for the delay within the initial thirty-day period.