gt77 Privacy Policy

gt77 (accessible at gt77.vu, hereinafter "gt77," "we," "us," or "our") is an online gaming platform operating under licensing granted by the Philippine Amusement and Gaming Corporation ("PAGCOR"). We are committed to protecting the privacy and personal data of all users who access our platform, including registered players, visitors, and individuals who contact our support team.

This Privacy Policy is prepared in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (the "DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC") of the Philippines. This policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal data in connection with the operation of the gt77 platform.

By registering an account on gt77, accessing the platform, or submitting your personal information to us in any form, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with this policy, please do not register an account or use the gt77 platform.

This Privacy Policy must be read together with gt77's Terms & Conditions and Responsible Gaming Policy, which are incorporated by reference.

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, the data controller responsible for your personal information is:

gt77 has designated a Data Protection Officer ("DPO") as required under Section 21 of the Data Privacy Act of 2012. The DPO is responsible for overseeing gt77's data protection compliance, handling data subject requests, and serving as the primary point of contact for the National Privacy Commission. Contact details for the DPO are provided in Section 15 of this policy.

gt77 collects several categories of personal data in connection with the provision of its gaming services. The following table summarizes the categories of data collected:

gt77 does not intentionally collect sensitive personal information as defined under Section 3(l) of the Data Privacy Act — including health data, racial or ethnic origin, religious beliefs, political opinions, or sexual life — unless specifically required for responsible gaming compliance (e.g., problem gambling self-declaration) or mandated by law, in which case explicit consent will be obtained separately.

gt77 collects personal data through the following means:

• Direct Submission: Information you provide when registering an account, completing KYC verification, submitting deposit or withdrawal requests, contacting support, or participating in promotions.
• Automated Technical Collection: Data collected automatically when you access the gt77 platform, including IP addresses, device identifiers, session logs, and cookie data as described in Section 10.
• Payment Processors: Transaction data received from payment service providers — including GCash, PayMaya, and bank partners — in connection with deposits and withdrawals.
• Identity Verification Partners: Data received from third-party KYC and identity verification services engaged by gt77 to confirm the authenticity of submitted documents.
• Fraud Prevention Services: Information received from fraud screening and anti-money laundering compliance services used by gt77 to detect and prevent financial crime.
• PAGCOR and Regulatory Sources: Information received from PAGCOR or other competent Philippine authorities as part of licensing compliance, player exclusion registries, or regulatory investigations.

Under Section 12 and 13 of the Data Privacy Act of 2012, gt77 must have a lawful basis for processing personal data. The following table sets out our processing purposes and the applicable legal basis for each:

gt77 does not sell, rent, or trade your personal information to unaffiliated third parties for their own marketing purposes. We may disclose your personal data to the following categories of recipients only to the extent necessary and in accordance with the Data Privacy Act:

• PAGCOR and Philippine Regulatory Authorities: gt77 is required by its operating license to provide player account data, transaction records, and gaming activity reports to PAGCOR upon request or pursuant to regular reporting obligations. Disclosure to PAGCOR is a legal obligation and is non-negotiable under Philippine gaming law.
• Anti-Money Laundering Council (AMLC): gt77 is required to report covered and suspicious transactions to the AMLC under Republic Act No. 9160, as amended. Reports are made in compliance with the law and without prior notice to the affected account holder where legally required.
• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners receive the minimum data necessary to process approved deposits and withdrawals on your behalf. These providers are bound by their own regulatory obligations and contractual data protection terms with gt77.
• Identity Verification & KYC Providers: Third-party identity verification services receive submitted documents and biometric data solely for the purpose of verifying your identity. These providers operate under data processing agreements with gt77 that require them to handle your data in compliance with Philippine data protection law.
• Fraud Prevention & Security Services: gt77 uses specialized security and fraud analytics providers who may process technical data (IP addresses, device fingerprints, behavioral patterns) to detect and prevent unauthorized access and fraudulent transactions.
• Game Content Providers: Game providers such as JILI, Pragmatic Play, and PG Soft may receive session data and game activity logs necessary to operate their games and manage RTP compliance. No identity data is shared with game providers beyond what is technically required for game function.
• Law Enforcement: gt77 will disclose personal data to Philippine law enforcement agencies where required by valid legal process — including court orders, subpoenas, or NBI or PNP requests — or where disclosure is necessary to prevent imminent harm.
• Professional Advisors: gt77's legal counsel, external auditors, and compliance consultants may access personal data as necessary in their professional capacity, subject to confidentiality obligations.

All third parties who process personal data on behalf of gt77 are required to enter into data sharing or data processing agreements as applicable under the Data Privacy Act, ensuring that your data is handled with the same standard of protection gt77 applies internally.

gt77's primary data infrastructure is located in the Philippines. In certain instances — particularly in connection with game server infrastructure, cloud hosting, or international payment processing — personal data may be transferred to or processed in servers or systems located outside the Republic of the Philippines.

Where such international transfers occur, gt77 ensures that appropriate safeguards are in place in accordance with Section 21(c) of the Data Privacy Act of 2012 and the NPC's regulations on cross-border data transfers. Safeguards employed include:

• Data transfer agreements incorporating the NPC's standard contractual clauses or equivalent protections;
• Transfers only to jurisdictions that the NPC has determined provide an adequate level of protection; or
• Transfers made pursuant to your explicit consent or on the basis of other legal grounds permitted under the DPA.

You may request details of the specific safeguards applicable to any international transfer of your personal data by contacting gt77's Data Protection Officer at the address provided in Section 15.

gt77 retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with gt77's data disposal procedures. Anonymized data (from which you can no longer be identified) may be retained indefinitely for statistical and analytics purposes.

gt77 implements organizational, technical, and physical security measures designed to protect your personal data from unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• SSL/TLS Encryption: All data transmitted between your device and the gt77 platform is encrypted using SSL/TLS 256-bit encryption. Look for the padlock icon and gt77.vu in your browser's address bar to confirm your connection is secure.
• Password Hashing: Account passwords are stored using one-way cryptographic hashing algorithms. gt77 never stores passwords in plain text and cannot recover your password — only reset it via verified OTP.
• Access Controls: Access to personal data within gt77 systems is restricted to authorized personnel on a need-to-know basis. Employees handling personal data are subject to confidentiality obligations and receive regular data privacy training.
• Two-Factor Authentication: gt77 supports SMS OTP-based two-factor authentication (2FA) for player accounts, providing an additional security layer beyond password credentials.
• Penetration Testing: gt77 engages independent cybersecurity professionals to conduct regular penetration testing and security assessments of its platform infrastructure.
• Incident Response: gt77 maintains a formal data breach response procedure. In the event of a personal data breach affecting your data, gt77 will notify you and the National Privacy Commission within the timeframes required under the Data Privacy Act and NPC Circular No. 16-03.
• Segregated Player Funds: Financial data associated with player wallet balances is maintained in systems segregated from operational financial records, providing an additional layer of financial data integrity.

gt77 uses cookies and similar tracking technologies on its platform. A cookie is a small text file placed on your device by the web server when you visit a website. gt77 uses the following categories of cookies:

• Strictly Necessary Cookies: Essential for the platform to function. These cookies manage your login session, remember your language preferences, and maintain the security of your connection. They cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your preferences and settings (e.g., preferred game category, responsible gaming settings, display preferences) to improve your experience on subsequent visits.
• Analytics Cookies: Collect anonymized data about how players use the gt77 platform — which pages are visited most, where users encounter errors, and how navigation flows are used. This data helps gt77 improve its service. Where possible, analytics data is processed in aggregated, non-identifiable form.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and account takeover patterns. These cookies are strictly necessary for platform security.

gt77 does not use third-party advertising or behavioral tracking cookies for the purpose of targeting advertising outside of the gt77 platform. You may control non-essential cookie preferences through the cookie settings interface available when you first access the platform. Please note that disabling strictly necessary or security cookies may impair platform functionality and account security.

gt77 enforces a strict 21 years minimum age requirement for all registered players, consistent with PAGCOR licensing conditions and Philippine gaming law. gt77 does not knowingly collect personal data from individuals under the age of 21.

During account registration, players are required to declare that they are at least 21 years of age. This declaration is verified through mandatory KYC procedures that require submission of a government-issued Philippine ID confirming date of birth. Any account found to belong to an individual below the age of 21 will be immediately suspended, and all associated data will be processed solely for the purposes of regulatory reporting and legal compliance before being deleted in accordance with our retention schedule.

If gt77 discovers that it has inadvertently collected personal data from a person under 21, it will take steps to delete such data promptly from its systems and will notify the relevant supervisory authority if required by applicable law. Parents and guardians who have reason to believe a minor has registered on gt77 are encouraged to contact our Data Protection Officer immediately using the details in Section 15.

As a data subject under the Philippine Data Privacy Act of 2012, you hold the following rights with respect to your personal data processed by gt77. These rights may be exercised by contacting the gt77 Data Protection Officer as described in Section 15:

To exercise any of the above rights, please submit a written request to gt77's Data Protection Officer using the contact details in Section 15. gt77 will respond within thirty (30) calendar days from receipt of a complete and valid request. We may need to verify your identity before processing your request to protect against unauthorized access to your data.

If you have concerns about how gt77 handles your personal data, we encourage you to follow this process:

1. Contact the gt77 DPO: Submit your concern in writing to gt77's Data Protection Officer at the address provided in Section 15. Include your full name, registered account email or mobile number, and a clear description of your concern. The DPO will acknowledge receipt within five (5) business days and provide a substantive response within thirty (30) calendar days.
2. Formal Internal Review: If you are unsatisfied with the DPO's initial response, you may request an internal review by gt77's senior compliance management. This second-level review will be completed within thirty (30) additional calendar days.
3. National Privacy Commission: If you remain unsatisfied after gt77's internal resolution process, you have the right to file a formal complaint with the National Privacy Commission (NPC) of the Philippines. The NPC has jurisdiction over data privacy complaints involving Philippine-resident data subjects and data controllers operating under Philippine law.

gt77 reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, technology, or regulatory requirements. When material changes are made, gt77 will notify registered players by SMS to their registered Philippine mobile number and/or by prominent notice on the gt77 platform homepage, with a minimum of fourteen (14) days' notice before the updated policy takes effect (except where a shorter notice period is required by law).

The effective date at the top of this document indicates when the current version entered into force. For significant changes, gt77 will also maintain an accessible summary of key amendments to assist players in understanding what has changed. Prior versions of this Privacy Policy are available upon written request to the DPO.

Your continued use of the gt77 platform following the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not accept a material change to this policy, you may request voluntary account closure in accordance with gt77's Terms & Conditions.

For any questions, concerns, or requests relating to this Privacy Policy or your personal data rights under the Data Privacy Act of 2012, please contact gt77's Data Protection Officer through the following channels:

When submitting a data subject rights request, please include: (1) your full name as registered on your gt77 account; (2) your registered Philippine mobile number or email address; (3) a description of the right you wish to exercise; and (4) any supporting information relevant to your request. gt77 reserves the right to verify your identity before processing any request that would grant access to or modification of account data.