Privacy Policy — th7777 Gaming Platform

01 Introduction

th7777 ("th7777," "we," "us," "our") operates the online gaming and sports betting platform accessible at th7777.app. This Privacy Policy describes how th7777 collects, uses, stores, shares, and protects the personal information of users ("you," "your," "Player") who access or use the th7777 platform, including the website, mobile application, and any related services.

This Privacy Policy is incorporated into and forms part of the th7777 Terms & Conditions. By registering for a th7777 account or using any part of the th7777 platform, 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.

th7777 is committed to complying with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its implementing rules and regulations. We take our obligations as a personal information controller seriously and have implemented appropriate technical and organizational measures to protect your data.

02 Personal Data We Collect

th7777 collects the following categories of personal data from players and platform users:

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, nationality, government-issued ID number	Account registration, KYC verification, age verification
Contact Data	Email address, Philippine mobile number, residential address	Account communication, transaction notifications, support
Financial Data	GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank), transaction history	Processing deposits and withdrawals, fraud prevention, AML compliance
Technical Data	IP address, device type, browser type, operating system, session data	Platform security, fraud detection, service optimization
Usage Data	Games played, bets placed, betting history, login timestamps, session duration	Responsible gaming monitoring, personalization, platform improvement
Communications Data	Support chat logs, email correspondence, complaint records	Customer support, dispute resolution, quality assurance
Verification Documents	Copies of government-issued ID, proof of address, selfie verification	KYC compliance, identity verification, regulatory requirements

03 How We Collect Your Data

th7777 collects personal data through the following means:

• Direct collection: Information you provide when registering for an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the th7777 platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud screening data from payment processors; and, where applicable, data from PAGCOR or other regulatory bodies for compliance purposes.
• Payment processors: Transaction data shared by GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners when you make deposits or request withdrawals.

04 How We Use Your Personal Data

th7777 uses your personal data for the following purposes:

• Account management: To create, maintain, and manage your th7777 player account, including processing your registration and verifying your identity.
• Transaction processing: To process deposits, withdrawals, and bet settlements accurately and securely via GCash, PayMaya, and Philippine bank transfers.
• Regulatory compliance: To comply with PAGCOR licensing requirements, anti-money laundering (AML) obligations under Republic Act No. 9160, and the Data Privacy Act of 2012.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the th7777 platform.
• Responsible gaming: To monitor gaming activity for signs of problem gambling, enforce deposit limits and self-exclusion requests, and comply with responsible gaming obligations.
• Customer support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform improvement: To analyze usage patterns, identify technical issues, and improve the features and performance of the th7777 platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided consent or where permitted by applicable law. You may opt out of marketing communications at any time.

05 Legal Basis for Processing

th7777 processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

• Contractual necessity: Processing required to perform our obligations under the th7777 Terms & Conditions, including account management and transaction processing.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AML requirements, and tax obligations.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

06 Data Sharing & Disclosure

th7777 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Privacy Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners, for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers: Third-party service providers engaged to assist with identity verification and document authentication.
• Regulatory authorities: PAGCOR and other Philippine government agencies, where disclosure is required by law, court order, or regulatory requirement.
• Fraud prevention and security providers: Third-party services engaged to assist with fraud detection, cybersecurity, and platform integrity.
• Technology and infrastructure providers: Cloud hosting, data storage, and platform technology providers who process data on our behalf under strict data processing agreements.
• Professional advisors: Legal counsel, auditors, and compliance consultants, where necessary for the operation of th7777's business.

07 Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device when you visit the th7777 website or use the th7777 app. They help us recognize your device, maintain your session, and improve your experience on the platform.

7.2 Types of Cookies We Use

• Essential cookies: Required for the th7777 platform to function correctly, including maintaining your login session and processing transactions. These cannot be disabled.
• Performance cookies: Used to collect anonymized data about how players use the th7777 platform, helping us identify and fix technical issues and improve performance.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to personalize your experience.
• Marketing cookies: Used to deliver relevant promotional content. These are only placed with your consent and can be disabled at any time through your browser settings.

7.3 Managing Cookies

You can control and manage cookies through your browser settings. Please note that disabling essential cookies may affect the functionality of the th7777 platform, including your ability to log in and place bets.

08 Data Retention

th7777 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including compliance with legal, regulatory, and contractual obligations. Specific retention periods include:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and Philippine AML regulations.
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Republic Act No. 9160 (Anti-Money Laundering Act) and its implementing rules.
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction.
• Support and communications records: Retained for three (3) years from the date of the last communication, for dispute resolution and quality assurance purposes.
• Technical and usage data: Retained for up to twenty-four (24) months, after which it is anonymized or deleted.

When personal data is no longer required for any lawful purpose, th7777 will securely delete or anonymize it in accordance with our internal data disposal procedures.

09 Data Security

th7777 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and the th7777 platform is encrypted using TLS (Transport Layer Security) protocols. Sensitive data stored on our servers is encrypted at rest.
• Access controls: Access to personal data is restricted to authorized th7777 personnel and third-party processors who require it to perform their functions. All access is logged and audited.
• Two-factor authentication: th7777 supports and encourages the use of two-factor authentication (2FA) to protect your account from unauthorized access.
• Regular security assessments: th7777 conducts regular vulnerability assessments and penetration testing to identify and address potential security weaknesses in the platform.
• Incident response: th7777 maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, we will notify the National Privacy Commission (NPC) and affected players in accordance with the Data Privacy Act of 2012.

10 Your Data Protection Rights

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights with respect to your personal data held by th7777:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
• Right of access: You have the right to request a copy of the personal data th7777 holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You may update certain account information directly through your th7777 account settings.
• Right to erasure: You have 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 and regulatory retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to applicable legal grounds.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that th7777 has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact the th7777 Data Privacy Officer using the contact details provided in Section 14 of this Privacy Policy. th7777 will respond to all verified data subject requests within thirty (30) days of receipt.

11 Children's Privacy

The th7777 platform is strictly intended for persons who are 21 years of age or older, consistent with PAGCOR regulations governing online gaming in the Philippines. th7777 does not knowingly collect personal data from persons under the age of 21.

If th7777 becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. Any winnings accrued on an underage account will be forfeited. If you believe that a minor has registered on the th7777 platform, please contact our support team immediately.

12 Third-Party Links

The th7777 platform may contain links to third-party websites or services for informational purposes. th7777 is not responsible for the privacy practices or content of any third-party websites. This Privacy Policy applies solely to data collected by th7777 through the th7777 platform. We encourage you to review the privacy policies of any third-party sites you visit.

13 Changes to This Privacy Policy

th7777 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, th7777 will notify registered players via the email address on file or through a prominent notice on the platform. The effective date of the most recent version will always be displayed at the top of this page.

Your continued use of the th7777 platform following notification of changes to this Privacy Policy constitutes your acceptance of the revised policy. If you do not agree to the updated Privacy Policy, you must cease using the platform and may request account closure in accordance with the th7777 Terms & Conditions.

14 Contact & Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by th7777, please contact our Data Privacy Officer:

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you are not satisfied with th7777's response to your data privacy concern.