1q77 Privacy Policy

1. Introduction & Scope

This Privacy Policy ("Policy") describes how 1q77 ("1q77," "we," "us," or "our") collects, uses, stores, shares, and protects personal information obtained from individuals ("you," "Player," or "User") who access or use the 1q77 online gaming platform available at 1q77.net, including any associated mobile applications or digital services (collectively, the "Platform").

This Policy applies to all personal data processed by 1q77 in connection with your use of the Platform, whether you are a registered player, a visitor browsing the site, or a person who contacts us through our support channels. By accessing the Platform or creating an account, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read alongside our Terms & Conditions, which govern your use of the Platform. In the event of any conflict between this Policy and the Terms & Conditions on matters of data privacy, this Policy shall prevail.

2. Data Controller Information

1q77 acts as the data controller in respect of the personal data collected through the Platform. As data controller, 1q77 determines the purposes and means of processing your personal information and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

If you have any questions, concerns, or requests relating to the processing of your personal data, you may contact our designated Data Protection Officer (DPO) using the contact details provided in Section 13 of this Policy. We are committed to addressing all data privacy inquiries promptly and in accordance with applicable Philippine law.

3. Personal Data We Collect

1q77 collects personal data that is necessary for the operation of the Platform, compliance with legal obligations, and the delivery of a safe and enjoyable gaming experience. The categories of personal data we collect include:

We do not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. Where sensitive data (such as government ID numbers) is collected, it is handled with heightened security measures and access controls.

4. How We Use Your Data

1q77 uses the personal data we collect for the following purposes:

• Account Registration & Management: To create and maintain your player account, verify your identity, and manage your profile settings.
• Service Delivery: To provide access to games, process deposits and withdrawals, apply bonuses, and deliver the core features of the 1q77 Platform.
• Identity Verification (KYC): To comply with PAGCOR regulatory requirements and anti-money laundering (AML) obligations by verifying your identity before processing withdrawals.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal conduct on the Platform.
• Responsible Gaming: To monitor gaming behavior, apply player-requested limits, identify potential problem gambling patterns, and administer self-exclusion requests.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Legal & Regulatory Compliance: To fulfill our obligations under Philippine law, including the Data Privacy Act, PAGCOR regulations, and applicable AML legislation.
• Platform Improvement: To analyze usage patterns, troubleshoot technical issues, and improve the performance and features of the Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have given your explicit consent to receive such communications.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 1q77 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to upon registration — including account management, game access, and payment processing.
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, AML obligations, and tax reporting duties.
• Legitimate Interests: Processing carried out for 1q77's legitimate business interests, such as fraud prevention, platform security, and service improvement — provided these interests are not overridden by your rights and freedoms.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications and optional platform features. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

1q77 does not sell, rent, or trade your personal data. We may share your information with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Service Providers: GCash, PayMaya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) receive the financial data necessary to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and AML screening services that assist us in verifying player identities and screening against regulatory watchlists.
• Game Software Providers: Licensed game developers and live dealer studios whose games are hosted on the 1q77 Platform may receive anonymized or pseudonymized usage data for game performance and fairness auditing purposes.
• Regulatory Authorities: PAGCOR and other competent Philippine government agencies, where disclosure is required by law, court order, or regulatory directive.
• IT & Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under strict data processing agreements.
• Professional Advisors: Legal counsel, auditors, and compliance consultants, where necessary for the conduct of our business and subject to professional confidentiality obligations.

All third-party service providers engaged by 1q77 are required to implement appropriate technical and organizational security measures and are prohibited from using your personal data for any purpose beyond the specific service they provide to us.

7. Cookies & Tracking Technologies

The 1q77 Platform uses cookies and similar technologies (such as local storage and session tokens) to operate core platform functions and improve your experience. The types of cookies we use are:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without affecting platform functionality.
• Functional Cookies: Used to remember your preferences, such as language settings, display options, and game lobby filters, so you don't have to reconfigure them on each visit.
• Analytics Cookies: Used to collect anonymized data about how players interact with the Platform — such as which games are most popular and where technical errors occur — to help us improve performance. This data is not linked to your personal identity.

1q77 does not use advertising or third-party tracking cookies. We do not share cookie data with ad networks or social media platforms.

You can manage or delete cookies through your browser settings at any time. Note that disabling strictly necessary cookies may prevent you from accessing certain features of the Platform, including your account login.

8. Data Retention

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

• Active Account Data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, in accordance with PAGCOR and AML record-keeping requirements.
• KYC & Identity Documents: Retained for a minimum of five (5) years from the date of submission or account closure, whichever is later, as required by Philippine AML regulations.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Support Communications: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years, to demonstrate compliance with consent requirements.
• Technical & Usage Logs: Retained for up to twelve (12) months for security and performance monitoring purposes.

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

9. Data Security

1q77 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:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data at rest, including financial information and government ID details.
• Role-based access controls ensuring that only authorized personnel can access personal data, and only to the extent required for their specific function.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

10. Your Rights Under the DPA

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 1q77:

• Right to Be Informed: The right to know what personal data we collect, how it is used, and with whom it is shared — as set out in this Policy.
• Right of Access: The right to request a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information 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 retention obligations.
• Right to Object: The right to object to the 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, and machine-readable format, where technically feasible.
• Right to Lodge a Complaint: The right to lodge 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 our Data Protection Officer using the details in Section 13. We will respond to all verified requests within fifteen (15) business days, or within the timeframe required by applicable law where this differs.

11. Children & Minors

The 1q77 Platform is strictly intended for individuals who are twenty-one (21) years of age or older, in accordance with Philippine law governing casino-style gambling. 1q77 does not knowingly collect personal data from persons under the age of 21.

If we become 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. If you believe that a minor has registered on the Platform, please contact our support team immediately so we can investigate and take appropriate action.

Parents and guardians are encouraged to use parental control tools and to monitor their children's online activity to prevent underage access to gambling platforms.

12. Changes to This Policy

1q77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. When material changes are made, we will notify registered players via their registered email address and/or by posting a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. We encourage you to review this Policy periodically to stay informed about how we protect your personal data. Your continued use of the Platform following the publication of an updated Policy constitutes your acceptance of the revised terms.

13. Contact & Complaints

If you have any questions about this Privacy Policy, wish to exercise your data subject rights, or have a concern about how 1q77 handles your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Website: 1q77.net

We aim to acknowledge all privacy-related inquiries within five (5) business days and to resolve them within fifteen (15) business days. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines:

• National Privacy Commission (NPC) — the independent government body responsible for administering and implementing the Data Privacy Act of 2012 in the Philippines.