1q77 Casino Privacy Policy

1 Introduction

1q77 ("we," "us," "our," or "1q77") is the operator of the online casino and gaming platform accessible at https://1q77.cam ("Platform"). We are licensed and regulated by the Philippine Amusement and Gaming Corporation (PAGCOR) and are committed to protecting the privacy of every person who uses our Platform.

This Privacy Policy describes the types of personal data we collect, the purposes for which we process it, the legal bases for that processing, how long we keep it, who we share it with, and the rights you have as a data subject under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations ("IRR").

This Policy should be read alongside the 1q77 Terms and Conditions, which govern your use of the Platform. Defined terms used in this Policy have the same meaning as in the Terms and Conditions unless otherwise stated.

2 Data Controller

For the purposes of the Philippine Data Privacy Act, 1q77 is the Personal Information Controller (PIC) in respect of your personal data. This means 1q77 determines the purposes and means by which your personal data is processed.

Our Data Protection Officer (DPO) can be contacted at [email protected] for all privacy-related inquiries, data subject requests, and complaints. Please include "Data Privacy" in the subject line of your communication to ensure it is directed to the appropriate team.

3 Personal Data We Collect

1q77 collects the following categories of personal data in connection with your use of the Platform:

We do not collect sensitive personal information as defined under the DPA (such as health data, religious beliefs, or political affiliations) unless specifically required by law or provided voluntarily by you in a support communication.

4 How We Collect Personal Data

1q77 collects personal data through the following channels:

• Directly from you — when you register an account, complete KYC verification, make deposits or withdrawals, contact customer support, or participate in surveys and promotions on the 1q77 Platform.
• Automatically through the Platform — including IP addresses, device identifiers, session data, and gameplay logs generated during your use of the 1q77 Platform.
• From third-party payment providers — such as GCash, PayMaya, BPI, BDO, and Metrobank, in connection with deposit and withdrawal transactions. These providers share only the data necessary to process and verify your transactions.
• From identity verification services — 1q77 may use third-party KYC and AML screening services to verify your identity and screen against regulatory watchlists as required by PAGCOR's compliance framework.
• From public sources — including publicly available government databases and PAGCOR's self-exclusion register, where applicable.

5 Purposes of Processing

1q77 processes your personal data for the following specific purposes:

• Creating and managing your 1q77 account, including authentication and security;
• Processing and verifying deposits, withdrawals, and payment transactions in Philippine Peso;
• Conducting mandatory KYC identity verification before processing withdrawals;
• Detecting, preventing, and investigating fraud, money laundering, and prohibited conduct on the 1q77 Platform;
• Complying with PAGCOR licensing conditions, anti-money-laundering (AML) obligations, and all applicable Philippine laws;
• Administering bonuses, promotions, and loyalty programs for eligible 1q77 players;
• Providing customer support and resolving disputes;
• Sending essential service communications — including security alerts, account notifications, and policy updates;
• Sending marketing communications where you have opted in to receive them (you may opt out at any time);
• Improving the 1q77 Platform through aggregated analytics and performance monitoring;
• Enforcing the 1q77 Terms and Conditions, including self-exclusion and responsible gaming obligations.

6 Legal Basis for Processing

Under the Philippine Data Privacy Act, 1q77 relies on the following legal bases for processing your personal data:

• Contractual necessity — processing required to fulfill our obligations to you under the 1q77 Terms and Conditions, including account management, payment processing, and game delivery;
• Legal obligation — processing necessary to comply with PAGCOR licensing requirements, AML laws, tax reporting obligations, and other applicable Philippine statutes;
• Legitimate interests — processing for fraud prevention, platform security, dispute resolution, and internal analytics, where our legitimate interests are not overridden by your rights and freedoms;
• Consent — processing for optional marketing communications and non-essential analytics cookies, where you have provided freely given and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Sharing Your Personal Data

1q77 does not sell your personal data. We share personal data only with the following categories of recipients, and only to the extent necessary for the specified purpose:

• PAGCOR and Philippine regulators — as required by our operating license and applicable gaming and AML laws;
• Payment processors — GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, for the purpose of processing your financial transactions on the 1q77 Platform;
• KYC and AML service providers — third-party identity verification and watchlist screening services engaged by 1q77 to meet its PAGCOR compliance obligations;
• Technology and infrastructure providers — cloud hosting, content delivery, and cybersecurity vendors that process data on 1q77's behalf under binding data processing agreements;
• Game software providers — to the limited extent necessary to deliver the specific game titles available on the 1q77 Platform, such as session tokens and bet data;
• Law enforcement and courts — where required by a valid legal process, court order, or lawful request from a Philippine law enforcement authority.

All third parties with whom 1q77 shares personal data are bound by contractual data protection obligations consistent with the Philippine DPA. We do not permit third-party service providers to use your personal data for their own marketing or commercial purposes.

8 Cross-Border Data Transfers

Some of 1q77's technology vendors and game software providers operate infrastructure located outside the Philippines. Where personal data is transferred to a country other than the Philippines, 1q77 ensures that appropriate safeguards are in place in accordance with Section 21 of the Philippine Data Privacy Act and the NPC's guidelines on cross-border data transfers.

Such safeguards include contractual clauses approved by the National Privacy Commission (NPC), binding corporate rules, or transfers to countries that the NPC has determined provide an adequate level of data protection. You may request details of the specific safeguards applicable to any particular transfer by contacting 1q77's Data Protection Officer.

9 Data Retention Periods

1q77 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account and identity data — retained for the duration of the active account and for a minimum of five (5) years following account closure, in compliance with PAGCOR AML record-keeping requirements;
• Financial transaction records — retained for a minimum of five (5) years following the date of the transaction, as required by Philippine AML law;
• Gaming session data — retained for two (2) years from the date of the session for fraud investigation and dispute resolution purposes;
• Customer support communications — retained for two (2) years from the date of the last communication;
• Marketing consent records — retained for the duration of the consent and for one (1) year following withdrawal of consent;
• KYC documents — retained for five (5) years from account closure or from the date the documents were submitted, whichever is later.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with 1q77's data disposal procedures.

10 Security Measures

1q77 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 1q77 Platform;
• AES-256 encryption for personal data stored on 1q77's servers;
• Multi-factor authentication requirements for all 1q77 administrative and staff accounts;
• Role-based access controls ensuring that personal data is accessible only to staff with a legitimate operational need;
• Regular penetration testing and vulnerability assessments of the 1q77 Platform and infrastructure;
• Mandatory data protection training for all 1q77 personnel who handle personal data;
• An incident response plan providing for prompt notification to the National Privacy Commission and affected data subjects in the event of a reportable personal data breach.

Notwithstanding these measures, no data transmission over the internet is completely secure. 1q77 cannot guarantee the absolute security of data transmitted to the Platform, and transmission is at your own risk. Once received, however, we use all commercially reasonable efforts to protect your data within our systems.

11 Cookies & Tracking Technologies

1q77 uses cookies and similar tracking technologies on the Platform. Cookies are small data files stored on your device that help the Platform function correctly and allow us to understand how players use the 1q77 service.

The following categories of cookies are used on the 1q77 Platform:

• Strictly necessary cookies — essential for the Platform to function. These include session authentication tokens, security cookies, and load-balancing cookies. These cannot be disabled without impairing core Platform functionality.
• Functional cookies — used to remember your preferences, such as language settings and whether you have accepted this Privacy Policy.
• Analytics cookies — used by 1q77 to collect aggregated, anonymized information about how players navigate and use the Platform, for the purpose of improving the user experience. These are not linked to your identity.

1q77 does not use third-party advertising cookies or cross-site tracking technologies. You may configure your browser to refuse or delete cookies at any time. Note that disabling strictly necessary cookies may prevent certain Platform features from working correctly.

12 Minors & Age Policy

The 1q77 Platform is strictly intended for use by individuals who are 21 years of age or older, in accordance with PAGCOR regulations governing online gaming in the Philippines. 1q77 does not knowingly collect personal data from individuals under the age of 21.

If 1q77 becomes aware that personal data has been collected from an individual under the age of 21 — whether through misrepresentation during registration or any other means — we will promptly close the account, delete all associated personal data, and reverse any transactions where legally permissible.

Parents and guardians who believe that a minor has registered on the 1q77 Platform should contact us immediately at [email protected]. We will investigate and act on all such reports within 72 hours.

13 Your Data Subject Rights

Under the Philippine Data Privacy Act, you have the following rights in respect of your personal data held by 1q77. You may exercise any of these rights by contacting our Data Protection Officer at [email protected]:

1q77 will respond to all verified data subject requests within thirty (30) calendar days. In complex cases, this period may be extended by a further thirty (30) days, with prior notice to you. We will verify your identity before processing any request to ensure we are responding to the correct data subject.

14 Complaints

If you believe that 1q77 has not handled your personal data in accordance with this Privacy Policy or the Philippine Data Privacy Act, we encourage you to contact our Data Protection Officer in the first instance at [email protected]. We are committed to resolving all privacy complaints promptly and fairly.

If you are not satisfied with our response, or if you believe a complaint requires regulatory attention, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent regulatory body responsible for overseeing compliance with the Philippine Data Privacy Act. Contact details for the NPC are available on the official National Privacy Commission website.

15 Changes to This Privacy Policy

1q77 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable laws, or PAGCOR regulatory requirements. When material changes are made, 1q77 will notify registered players by email to their registered address and by posting a notice on the 1q77 Platform.

The updated Privacy Policy will take effect on the date indicated at the top of the document. Your continued use of the 1q77 Platform following the effective date of any revision constitutes acceptance of the updated Policy. If you do not accept the revised terms, you should discontinue use of the Platform and contact support to close your account.

16 Contact Us

For all privacy-related inquiries, data subject access requests, and complaints, please contact the 1q77 Data Protection Officer through the following channels:

• Email: [email protected] — please use the subject line "Data Privacy Request" to ensure prompt routing to our DPO team
• Live Chat: Available 24/7 from within your logged-in 1q77 account dashboard
• Response commitment: Email inquiries are acknowledged within 24 hours and resolved within 30 calendar days of identity verification

When submitting a data subject request, please provide your full name, registered email address, and a brief description of your request so we can verify your identity and locate your account records efficiently. For security purposes, 1q77 will not process data subject requests received from unverified senders.