aq77 Privacy Policy - How We Protect Your Personal Data

1. Introduction

This Privacy Policy ("Policy") describes how aq77 ("aq77", "we", "us", or "our") collects, uses, stores, shares, and protects personal information in connection with your use of the aq77 online gaming platform accessible at aq77.lat, including all related pages, services, features, and functionality (collectively, the "Platform").

aq77 operates under PAGCOR licensing and is committed to full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission ("NPC"). Our data processing practices are designed to uphold the principles of transparency, legitimate purpose, and proportionality embedded in Philippine privacy law.

By registering an aq77 account or using any feature of our Platform, you acknowledge that you have read and understood this Policy, and you consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please do not use the Platform and contact us to close your account.

2. Who We Are (Data Controller)

For the purposes of the Philippine Data Privacy Act of 2012 and related regulations, aq77 acts as the personal information controller ("PIC") in respect of personal data collected through the Platform. This means aq77 is responsible for determining the purposes and means of processing your personal data.

Our designated Data Privacy Officer ("DPO") oversees all data protection matters and can be contacted at the details provided in Section 15 of this Policy. The DPO is responsible for ensuring aq77's ongoing compliance with the DPA, monitoring internal data processing activities, and serving as the primary point of contact for players wishing to exercise their data privacy rights.

3. Personal Data We Collect

3.1 Identity and Contact Data

When you register an account with aq77, we collect: your full legal name; date of birth; residential address (including barangay, city/municipality, province, and postal code); email address; and mobile telephone number. This information is necessary to create and manage your account, verify your identity, and comply with PAGCOR's Know Your Customer (KYC) requirements.

3.2 Identity Verification Documents

To comply with anti-money laundering laws and PAGCOR regulations, aq77 may request copies of government-issued photo identification (e.g., Philippine passport, driver's licence, SSS/GSIS/PhilHealth/Unified Multi-Purpose ID, voter's ID), proof of residential address (e.g., utility bill, bank statement dated within 90 days), and proof of payment method ownership. These documents are stored securely and processed only for verification and regulatory compliance purposes.

3.3 Financial Data

aq77 collects transaction records related to deposits and withdrawals processed through your account, including amounts, timestamps, payment method references (e.g., last four digits of a bank account, registered GCash number), and transaction identifiers. Full payment credentials such as complete bank account numbers or GCash PINs are not stored by aq77; these are handled directly by your payment provider using their own security infrastructure.

3.4 Gaming Activity Data

We collect records of your gaming activity on the Platform, including games played, bet amounts, game outcomes, session durations, and wagering history. This data is used to manage your account, calculate balances, fulfil regulatory reporting obligations, and, where you consent, personalise your gaming experience.

3.5 Technical and Device Data

When you access the Platform, our servers automatically collect certain technical information, including your IP address, device type, operating system and version, browser type and version, screen resolution, time zone, and unique device identifiers. This information is used for security monitoring, fraud detection, platform optimisation, and analytics.

3.6 Communications Data

We retain records of communications between you and the aq77 customer support team, including live chat transcripts, email correspondence, and support ticket histories. These records are used to resolve disputes, improve service quality, and train our support staff.

3.7 Marketing Preferences

Where you have opted in to receive promotional communications from aq77, we store your marketing preferences, including your preferred communication channel and the categories of offers you have expressed interest in. You may update or withdraw marketing consent at any time through your account settings or by contacting support.

4. How We Collect Your Data

aq77 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions;
• Automated collection: Technical and device data collected automatically when you access the Platform via cookies, server logs, and similar tracking technologies (see Section 10);
• Third-party sources: Identity verification data from accredited KYC and AML screening service providers; payment transaction data from licensed payment processors (GCash, Maya, BPI, BDO, UnionBank, etc.); fraud detection signals from security partners; and publicly available information from government registers where permitted by law.

5. How We Use Your Personal Data

aq77 uses the personal data it collects for the following purposes:

• Account creation and management: Setting up, maintaining, and securing your aq77 player account;
• Identity verification and KYC compliance: Verifying your identity, age, and source of funds in accordance with PAGCOR and AMLC requirements;
• Transaction processing: Processing deposits and withdrawals securely and accurately;
• Game delivery: Providing access to casino games, sports betting markets, and other Platform features;
• Customer support: Responding to enquiries, resolving disputes, and improving service quality;
• Regulatory compliance: Meeting obligations under applicable Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act (RA 9160), and the Data Privacy Act (RA 10173);
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, cheating, and other prohibited conduct on the Platform;
• Responsible gaming: Monitoring gaming behaviour to identify potential problem gambling patterns and applying responsible gaming tools where appropriate;
• Platform improvement and analytics: Analysing usage patterns to improve Platform performance, user experience, and game offerings;
• Marketing communications: Sending promotional offers, bonus notifications, and event updates where you have provided valid consent to receive such communications.

6. Legal Bases for Processing

Under the Philippine Data Privacy Act, aq77 processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to perform the contract between you and aq77 (i.e., providing the Platform and related services), including account management and transaction processing;
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act, NPC regulations, and other applicable Philippine law;
• Legitimate interests: Processing necessary for aq77's legitimate interests in fraud prevention, platform security, and service improvement, balanced against your privacy rights;
• Consent: Processing for marketing communications and non-essential analytics, which we only conduct where you have given clear, informed, and freely withdrawable consent.

7. Sharing Your Personal Data

aq77 does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data sharing or processing agreements:

• Payment processors: GCash, Maya, BPI, BDO, UnionBank, Metrobank, QR Ph, GrabPay, and 7-Eleven, solely to process your financial transactions;
• Identity verification and AML screening providers: Accredited third-party KYC and fraud detection services engaged to verify player identities and screen for financial crime risk;
• Game providers: Licensed game software providers (e.g., JILI, Pragmatic Play, Evolution Gaming) who may process limited technical data to deliver their games via the Platform;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government bodies, where disclosure is required by law or regulatory directive;
• Law enforcement: Philippine law enforcement agencies or courts where disclosure is compelled by a lawful order or is necessary to prevent serious harm;
• IT and infrastructure providers: Cloud hosting, cybersecurity, and data backup service providers engaged to maintain Platform operations, bound by confidentiality and data processing agreements.

8. International Data Transfers

Some of the third-party service providers aq77 engages — including certain game providers and cloud infrastructure partners — may be located outside the Philippines. Where personal data is transferred internationally, aq77 ensures that such transfers are protected by appropriate safeguards, including contractual clauses that impose data protection obligations equivalent to those required under the Philippine DPA, or that the receiving jurisdiction has been assessed as providing an adequate level of data protection.

aq77 will not transfer your personal data to a foreign jurisdiction unless the transfer is permitted under the DPA's cross-border transfer provisions and the recipient is bound by appropriate data protection obligations. You may request further information about specific international transfers by contacting our Data Privacy Officer.

9. Data Retention

aq77 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including meeting legal, regulatory, and reporting requirements. Our standard retention periods are as follows:

• Account and identity data: Retained for the duration of your account plus five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and anti-money laundering obligations under RA 9160;
• Transaction records: Retained for five (5) years from the date of each transaction, as required by the AMLC;
• Gaming activity records: Retained for three (3) years from the date of the relevant gaming session;
• Customer support records: Retained for two (2) years from the date of last interaction;
• Marketing preference data: Retained until you withdraw consent, plus six (6) months to process the withdrawal request;
• Technical and device logs: Retained for twelve (12) months from collection, after which they are anonymised or deleted.

Upon expiry of the applicable retention period, personal data is securely and irreversibly deleted or anonymised in accordance with aq77's data disposal procedures.

10. Cookies & Tracking Technologies

10.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They allow the site to recognise your device on subsequent visits and store certain preferences or session information. aq77 uses cookies and similar tracking technologies (such as local storage and session tokens) to operate the Platform effectively.

10.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function. These include session authentication cookies that keep you logged in during your visit. They cannot be disabled without affecting Platform functionality;
• Performance and analytics cookies: We use first-party analytics cookies to understand how players use the Platform, which pages are most visited, and where technical errors occur. This data is aggregated and does not identify individual players;
• Functionality cookies: These remember your preferences (e.g., language, game lobby settings) to provide a more personalised experience;
• Responsible gaming cookies: Session timers and reality check tools rely on cookies to track your session duration and trigger alerts as configured in your responsible gaming settings.

aq77 does not use third-party advertising or behavioural tracking cookies. Your browsing activity on aq77 is not shared with advertising networks.

10.3 Managing Cookies

You can manage or delete cookies through your browser settings at any time. Please note that disabling strictly necessary cookies will impair your ability to log in and use the Platform. Guidance on managing cookies for common browsers is available from the browser developers' support pages.

11. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by aq77:

• Right to be informed: The right to know whether aq77 holds personal data about you, how it is being used, and with whom it has been shared;
• Right of access: The right to obtain a copy of your personal data held by aq77 in a reasonable and portable format;
• Right to rectification: The right to correct inaccurate or incomplete personal data about you;
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation 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 and to request its transfer to another data controller;
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe aq77 has not handled your personal data in compliance with the DPA.

12. Children's Privacy

The aq77 Platform is strictly intended for persons aged 21 years and above in compliance with PAGCOR's age restrictions for online casino gaming in the Philippines. aq77 does not knowingly collect personal data from individuals under the age of 21. All registration attempts are subject to age verification procedures.

If aq77 becomes aware that personal data has been collected from a person under 21 without parental or guardian consent, we will take immediate steps to delete such data and close the associated account. If you believe a minor has registered on the aq77 Platform, please contact our support team immediately at [email protected] so we can investigate and act promptly.

13. Security Measures

aq77 implements a comprehensive information security programme to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our technical and organisational security measures include:

• TLS 1.3 encryption for all data transmitted between your device and our servers;
• AES-256 encryption for personal data stored in our databases;
• Multi-factor authentication for all internal administrative access to player data systems;
• Regular penetration testing and vulnerability assessments by independent cybersecurity firms;
• 24/7 security monitoring and intrusion detection systems;
• Role-based access controls limiting employee access to only the data necessary for their job function;
• Mandatory data privacy and security training for all aq77 employees who handle personal data;
• Formal data breach response procedures, including NPC notification within 72 hours of discovery of a notifiable breach as required by NPC Circular 16-03.

While aq77 takes all reasonable precautions to protect your data, no internet-based system can be guaranteed completely secure. You are responsible for keeping your aq77 login credentials confidential and for ensuring the security of the device you use to access the Platform.

14. Changes to This Privacy Policy

aq77 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. When material changes are made, we will notify registered players by email to their registered address and post a prominent notice on the Platform at least seven (7) days before the changes take effect, unless a shorter notice period is required by applicable law.

The "Effective Date" at the top of this Policy indicates when the current version came into force. We recommend reviewing this Policy periodically. Your continued use of the Platform after any revision takes effect constitutes your acceptance of the updated Policy. If you do not agree to the revised Policy, you may close your account by contacting the aq77 Customer Support team.

15. Contact Us & Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or aq77's data processing practices, please contact our Data Privacy Officer directly:

• Data Privacy Officer, aq77
• Email: [email protected] — please include "Data Privacy" in the subject line
• Live Chat: Available 24/7 on the Platform (ask to be connected to the Data Privacy team)
• Response Time: We aim to acknowledge all privacy requests within 72 hours and resolve them within 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 (NPC) through their official channels. aq77 cooperates fully with all NPC investigations.