Privacy Policy

1. Introduction

fill77 ("fill77," "we," "us," or "our") operates an online gaming platform accessible at fill77.com, offering casino games, sports betting, and related entertainment services to players in the Philippines. We understand that your personal information is important to you, and we take our responsibility to protect it seriously.

This Privacy Policy ("Policy") sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by fill77. This Policy applies to all users of the fill77 website, mobile application, and any related services (collectively, the "Platform").

fill77 is committed to handling your personal data in accordance with applicable Philippine data protection laws, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, as well as the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

We encourage you to read this Policy in full. If you have any questions about how fill77 handles your personal data, please contact us using the details provided in Section 14 of this Policy.

2. Data Controller

For the purposes of applicable data protection legislation, fill77 is the data controller responsible for your personal information collected through the Platform. As data controller, fill77 determines the purposes and means by which your personal data is processed.

fill77 has appointed a Data Protection Officer (DPO) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact our DPO using the contact details set out in Section 14.

3. Personal Data We Collect

fill77 collects and processes the following categories of personal data about you, depending on how you interact with the Platform:

fill77 does not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required by applicable law or regulatory obligation (for example, in the context of responsible gaming assessments).

4. How We Collect Your Data

fill77 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies. See Section 10 for more information on cookies.
• Third-party sources: Data received from payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank), identity verification providers, fraud prevention services, and analytics partners, where permitted by applicable law.
• Publicly available sources: In limited circumstances, fill77 may supplement your profile with information from publicly available sources for the purposes of fraud prevention or regulatory compliance.

5. How We Use Your Personal Data

fill77 uses your personal data for the following purposes:

• Account management: To register and maintain your fill77 account, verify your identity, and manage your player profile.
• Service delivery: To provide access to games, process bets, calculate and pay out winnings, and deliver the full range of fill77 services.
• Payment processing: To process deposits and withdrawals via your chosen payment method, and to maintain accurate financial records.
• Legal and regulatory compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, PAGCOR regulatory requirements, and the Data Privacy Act of 2012.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, and other unlawful conduct on the Platform.
• Responsible gaming: To monitor player activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, cooling-off periods, and self-exclusion.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Platform improvement: To analyse usage patterns, conduct research, and improve the performance, features, and user experience of the fill77 Platform.
• Marketing communications: To send you promotional offers, bonuses, and news about fill77 services, where you have provided your consent to receive such communications. You may opt out at any time.

6. Legal Basis for Processing

fill77 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 contract with you, including account registration, game access, and payment processing.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML obligations, PAGCOR requirements, and tax reporting.
• Legitimate interests: Processing necessary for fill77's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, and informed consent, including the sending of marketing communications. You may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Sharing Your Personal Data

fill77 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your transactions.
• Identity verification providers: Third-party KYC and age verification services engaged to verify your identity and age in compliance with regulatory requirements.
• Fraud prevention and AML services: Specialist providers engaged to detect and prevent fraudulent activity and money laundering on the Platform.
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other competent Philippine authorities, where required by law or regulatory directive.
• IT and platform service providers: Cloud hosting, data storage, analytics, and customer support technology providers engaged by fill77 to operate the Platform.
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by fill77 in connection with its legal and compliance obligations.

8. Data Retention

fill77 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

As a general rule, fill77 applies the following retention periods:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and PAGCOR regulatory requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by applicable Philippine law.
• Customer support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Technical and usage data: Retained for up to twelve (12) months from collection, unless required for longer periods for security or fraud investigation purposes.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent, as evidence of your preferences.

Where personal data is no longer required, fill77 will securely delete or anonymise it in accordance with our internal data disposal procedures.

9. Security Measures

fill77 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the fill77 Platform.
• Encryption at rest for sensitive personal and financial data stored on fill77 servers.
• Multi-factor authentication (MFA) options for Player accounts to prevent unauthorised access.
• Role-based access controls ensuring that fill77 staff can only access personal data necessary for their specific job functions.
• Regular security audits and penetration testing conducted by independent cybersecurity specialists.
• Intrusion detection and monitoring systems operating continuously to identify and respond to potential security threats.
• Staff training on data protection obligations and secure data handling practices.

While fill77 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are responsible for keeping your account credentials confidential and for notifying fill77 immediately if you suspect any unauthorised access to your account.

10. Cookies & Tracking Technologies

fill77 uses cookies and similar tracking technologies to enhance your experience on the Platform, to analyse usage patterns, and to support security and fraud prevention functions. A cookie is a small text file placed on your device when you visit the Platform.

fill77 uses the following categories of cookies:

• Strictly necessary cookies: Essential for the Platform to function correctly. These cookies enable core features such as account login, session management, and security. They cannot be disabled without affecting Platform functionality.
• Performance and analytics cookies: Used to collect anonymised information about how visitors use the Platform, including pages visited, time spent, and error messages encountered. This data helps fill77 improve the Platform experience.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to provide a more personalised experience.
• Targeting and marketing cookies: Used, with your consent, to deliver relevant promotional content and to measure the effectiveness of fill77's marketing campaigns. These cookies do not track your activity on third-party websites.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the fill77 Platform. For strictly necessary cookies, no consent is required as they are essential to the operation of the service.

11. Your Data Privacy Rights

Under the Data Privacy Act of 2012 and applicable NPC regulations, you have the following rights in relation to your personal data held by fill77:

• Right to be informed: You have the right to be informed about how fill77 collects and uses your personal data, as set out in this Policy.
• Right of access: You have the right to request a copy of the personal data fill77 holds about you, along with information about how it is processed.
• Right to rectification: You have the right to request that fill77 correct any inaccurate or incomplete personal data held about you.
• Right to erasure: You have the right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to fill77's 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 fill77's overriding legal obligations.
• 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 prior processing.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that fill77 has not handled your personal data in accordance with applicable law.

12. Minors & Age Policy

The fill77 Platform is strictly intended for individuals who are 21 years of age or older. fill77 does not knowingly collect, process, or store personal data from individuals under the age of 21.

If fill77 becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage user will be handled in accordance with applicable regulatory requirements.

If you are a parent or guardian and believe that your child has registered on fill77 or provided personal data to fill77 without your consent, please contact us immediately at [email protected] so that we can take appropriate action.

13. Changes to This Privacy Policy

fill77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision will always be displayed at the top of this page.

Where changes to this Policy are material, fill77 will notify registered Players via the email address associated with their account and/or via a prominent notice on the Platform prior to the changes taking effect. We encourage you to review this Policy periodically to stay informed about how fill77 protects your personal data.

Your continued use of the fill77 Platform following the posting of any changes to this Policy constitutes your acceptance of those changes. If you do not agree to the revised Policy, you must cease using the Platform and may request account closure by contacting fill77 customer support.

14. Contact & Data Requests

If you have any questions, concerns, or requests relating to this Privacy Policy or fill77's handling of your personal data, please contact our Data Protection Officer. Our team is committed to responding promptly and transparently to all privacy-related enquiries.

For general account, payment, or technical support, please visit our FAQ page or contact our support team directly. For responsible gaming concerns, please visit our Responsible Gaming page.