gl77 Privacy Policy

This Privacy Policy ("Policy") describes how gl77 ("we," "us," "gl77," or "the Platform") collects, uses, stores, protects, and shares personal data obtained from users ("you," "Player," or "User") of the gl77 website at gl77.club and all related services, features, and products offered through the platform.

This Policy is prepared in compliance with the Republic of the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the National Privacy Commission (NPC) issuances and guidelines applicable at the time of publication.

This Policy applies to all personal data processed in connection with:

• Account registration and management on the gl77 platform;
• Participation in any gaming activity offered through gl77, including slots, live casino, sports betting, bingo, sabong, and eSports;
• Deposits, withdrawals, and all other financial transactions processed through gl77's payment channels, including GCash, PayMaya, BPI, BDO, and Metrobank;
• Customer support interactions via live chat, email, or any other communication channel;
• Participation in promotional offers, loyalty programs, or any other incentive activities hosted by gl77.

For the purposes of the Data Privacy Act of 2012 and this Policy, gl77 acts as the Personal Information Controller (PIC) in respect of personal data collected through the gl77 platform. As PIC, gl77 determines the purposes and means of processing personal data obtained from Players and other users of the platform.

Third-party service providers engaged by gl77 — including game software providers, payment processors, and identity verification services — act as Personal Information Processors (PIPs) when they process personal data on gl77's behalf. gl77 enters into data processing agreements with all such processors to ensure appropriate data protection standards are maintained.

gl77's designated Data Protection Officer (DPO) can be contacted for privacy-related inquiries as described in Section 16 of this Policy.

gl77 collects personal data that is necessary, proportionate, and relevant to the purposes described in this Policy. The categories of personal data collected and the circumstances in which each is collected are set out below.

3.1 Registration Data

Collected when you create a gl77 account:

• Full legal name (as it appears on a government-issued Philippine ID);
• Date of birth (for age verification — players must be 21 or older);
• Philippine mobile number (primary account identifier and OTP delivery);
• Email address;
• Username or display name (where applicable);
• Account password (stored in hashed, non-reversible form — never in plaintext).

3.2 KYC & Identity Verification Data

Collected as part of the Know Your Customer process required before first withdrawal:

• Copy of a valid Philippine government-issued ID (passport, driver's license, SSS ID, PhilHealth card, GSIS card, or Postal ID);
• Selfie photograph for identity matching purposes;
• Proof of address where required by regulatory obligations;
• Source of funds declarations for players subject to enhanced due diligence.

3.3 Financial & Transaction Data

• GCash wallet number linked to your account;
• PayMaya account details where applicable;
• Bank account numbers for BPI, BDO, or Metrobank transfers;
• Full transaction history including deposit amounts, withdrawal amounts, bonus credits, and bet records — all denominated in Philippine Peso (₱).

3.4 Technical & Usage Data

• IP address and approximate geolocation at time of login;
• Device type, operating system, and browser or app version;
• Session timestamps and duration;
• Game play data including games accessed, bet sizes, win/loss outcomes, and session patterns;
• Cookies and similar tracking technologies (see Section 8).

3.5 Communication Data

• Contents of live chat support interactions;
• Email correspondence with gl77 support;
• Survey responses, complaint records, and feedback submissions.

gl77 processes personal data only for specific, legitimate purposes and on a lawful basis in each instance. The table below outlines the primary processing purposes, the data categories used, and the applicable legal basis:

gl77 does not use personal data for automated individual decision-making that produces legal or similarly significant effects on Players without providing an appropriate human review mechanism.

gl77 does not sell, rent, or trade personal data to third parties for their own commercial purposes. Data is shared only in the following specific circumstances:

5.1 Service Providers (Processors)

gl77 engages third-party service providers who process personal data on our behalf under data processing agreements that bind them to confidentiality and appropriate security obligations. These include:

• Identity verification providers — for KYC processing;
• Payment processors — GCash (GXI), PayMaya (VGPPI), and banking partners for processing financial transactions;
• Game software providers — who receive anonymised session data for game function and RNG certification purposes;
• Cloud hosting and infrastructure providers — for secure data storage and platform operations;
• Customer support platform providers — for live chat and ticket management;
• Analytics providers — using anonymised or pseudonymised data for platform performance analysis.

5.2 Legal & Regulatory Authorities

gl77 may disclose personal data to government authorities, regulatory bodies, law enforcement agencies, or courts of competent jurisdiction when required to do so by applicable Philippine law, by court order, or where disclosure is necessary to prevent fraud, money laundering, or other illegal activity.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of gl77's business, personal data held by gl77 may be transferred to the acquiring entity, provided that the acquiring entity is bound to process such data in accordance with this Privacy Policy or an equivalent standard.

gl77 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The following general retention schedules apply:

Upon expiry of the applicable retention period, personal data is either securely deleted from gl77's systems or anonymised to a degree where re-identification is not reasonably possible, consistent with NPC guidelines on data disposal.

gl77 implements a layered approach to information security designed to protect personal data against unauthorized access, disclosure, alteration, or destruction. The following technical and organizational measures are in place:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the gl77 platform;
• Password hashing using industry-standard cryptographic algorithms — account passwords are never stored in plaintext;
• Two-factor authentication (2FA) available for all player accounts via SMS OTP to registered Philippine mobile numbers;
• Segregated data storage — KYC documents, financial records, and session data are held in logically separated systems with role-based access controls;
• Regular penetration testing and vulnerability assessments conducted by qualified security professionals;
• Access controls ensuring that personal data is accessible only to gl77 personnel who require it for their specific role;
• Audit logging of access to sensitive data categories, retained for security investigation purposes;
• Employee data privacy training for all gl77 staff with access to personal data.

While gl77 employs robust security measures, no system is entirely immune to security risks. Players are responsible for maintaining the security of their own account credentials and should contact gl77 support immediately upon detecting any unauthorized account activity.

gl77 uses cookies and similar tracking technologies to operate the platform effectively, maintain session integrity, and improve the user experience for Filipino players. The types of cookies used are as follows:

8.1 Strictly Necessary Cookies

These cookies are essential for the platform to function. They maintain your login session, remember your preferred language setting, and protect against cross-site request forgery (CSRF) attacks. These cannot be disabled as they are integral to platform security and functionality.

8.2 Functional Cookies

These remember your preferences — such as game lobby layout, notification preferences, and responsible gaming settings — across sessions. Disabling functional cookies may affect your platform experience.

8.3 Analytical Cookies

gl77 uses anonymised analytics data to understand how Players interact with the platform, which game categories are most accessed, and where technical performance improvements are needed. Individual Players are not identified through analytical cookies — only aggregated patterns are analysed.

8.4 Managing Cookies

You can manage cookie preferences through your browser settings. Most browsers allow you to view, delete, and block cookies. Note that disabling strictly necessary cookies will prevent you from logging into and using gl77. Instructions for managing cookies in common Philippine-market browsers (Chrome, Firefox, Samsung Internet) are available through those browsers' help documentation.

gl77 is strictly an adult platform. No person under the age of 21 years is permitted to register an account, use any gl77 service, or participate in any real-money gaming activity on the platform. This age requirement aligns with the Philippine regulatory framework for online gaming as administered by PAGCOR.

gl77 does not knowingly collect personal data from individuals under 21 years of age. Age is collected at registration and is verified through the KYC process prior to any withdrawal being processed. If gl77 discovers or has reasonable grounds to suspect that an account has been created by a person under 21 years of age:

• The account will be immediately suspended pending investigation;
• Any real-money balance on the account arising from deposits made by the minor will be refunded to the verified payment method used for deposits, less any bonus amounts;
• The personal data collected during the registration and KYC process will be retained only for the period required to complete the investigation and satisfy any regulatory reporting obligations, and then securely deleted;
• The matter may be referred to relevant Philippine authorities where circumstances warrant.

Parents and guardians who believe a minor under their care may have registered a gl77 account should contact gl77 customer support immediately via live chat for prompt investigation and account closure.

To exercise any of your data rights as described in this Policy and under RA 10173, submit a request through one of the following channels:

• Live Chat: Available 24/7 on the gl77 platform — identify yourself as the account holder and state the specific right you wish to exercise;
• Email: [email protected] — include your registered mobile number, account email, and a description of your request. Do not include your password in any email communication.

All data rights requests are subject to identity verification. gl77 will not process a data access, erasure, or portability request without confirming that the requestor is the verified account holder. This protects against unauthorized access to your data by third parties.

Response timelines:

• Data access requests: Fulfilled within 30 calendar days of identity verification;
• Rectification requests: Actioned within 15 business days;
• Erasure requests: Assessed and responded to within 30 calendar days — note that certain data must be retained for legal compliance reasons;
• Marketing opt-out requests: Processed within 5 business days.

If you believe your data rights under RA 10173 have not been respected by gl77, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC's contact details and complaint procedures are available on the official NPC website.

Some of gl77's service providers and infrastructure partners operate servers or processing facilities outside the Philippines. Where personal data is transferred to another country in connection with gl77's services, gl77 ensures that such transfers comply with the requirements of RA 10173 and applicable NPC issuances regarding cross-border data transfers.

Safeguards applied to international data transfers include:

• Binding contractual clauses with overseas processors that require them to maintain equivalent data protection standards to those applicable in the Philippines;
• Transfers only to jurisdictions assessed as providing adequate data protection, or with appropriate safeguards in place;
• Data minimisation — only the minimum personal data necessary for the specific processing purpose is transferred cross-border.

Players may request information about the specific safeguards in place for any international transfer of their personal data by contacting gl77's Data Protection Officer as described in Section 16.

gl77 may send promotional communications — including bonus offers, new game announcements, seasonal promotions, and VIP loyalty notifications — to Players who have opted in to receive such communications during account registration or through their account settings.

Marketing communications are sent through the following channels where consent has been provided:

• SMS to your registered Philippine mobile number;
• Email to your registered email address;
• In-platform notifications within the gl77 dashboard.

You may update your marketing communication preferences at any time through Account Settings within the gl77 platform, or by contacting support. Marketing opt-out requests are actioned within 5 business days. Please note that opting out of marketing communications does not affect transactional notifications — such as deposit confirmations, withdrawal updates, and account security alerts — which are sent regardless of marketing preference settings because they are necessary for account management.

The gl77 platform may incorporate or reference third-party services, including game content provided by software providers such as Pragmatic Play, PG Soft, JILI, Habanero, and Spadegaming. These providers operate their own privacy policies governing any data processed through their software, which may include anonymised gameplay data for RNG certification and game audit purposes.

gl77 is not responsible for the privacy practices of any third-party service providers beyond the contractual data processing obligations imposed through gl77's data processing agreements. Players are encouraged to review the privacy policies of any third-party services they interact with independently.

gl77's platform does not include links to external websites in its main content areas. Where any reference to external resources is made in a regulatory or responsible gaming context, gl77 cannot be held responsible for the content or privacy practices of those external sites.

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected Players, gl77 will:

• Notify the National Privacy Commission (NPC) of the breach within 72 hours of becoming aware of it, where feasible, in accordance with the NPC's data breach notification requirements;
• Notify affected Players directly — by email and/or SMS to their registered contact details — without undue delay, providing clear information about the nature of the breach, the data affected, the likely consequences, and the measures taken or proposed to address the breach and mitigate its effects;
• Maintain an internal register of all data breaches for audit and regulatory review purposes.

Player notification will include practical guidance on steps Players can take to protect themselves — for example, changing account passwords, monitoring GCash transaction history, or contacting their bank if financial account details may have been involved.

gl77 reviews and updates this Privacy Policy periodically to reflect changes in our data practices, changes in applicable Philippine law, NPC guidance updates, or changes to our platform and services. When material changes are made to this Policy, gl77 will:

• Update the "Last Updated" date at the top of this page;
• Post a notice within the gl77 platform informing Players of significant changes;
• Where required by law, seek fresh consent from Players before processing their data in a materially different manner.

Your continued use of the gl77 platform following notification of changes to this Policy constitutes your acceptance of the updated Privacy Policy. If you do not accept the updated Policy, you must cease using gl77 and may request account closure in accordance with the procedure described in gl77's Terms and Conditions.

gl77 recommends that Players review this Privacy Policy each time they access the platform following an extended period of absence to stay informed of any changes.

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by gl77, please contact us through the following channels:

• 24/7 Live Chat: Available directly within the gl77 platform — fastest response channel for account-specific inquiries;
• Email: [email protected]

For formal data rights requests, DPO inquiries, or data breach notifications, please address your communication to the attention of Data Protection Officer, gl77 through the email address above. Please include "Data Privacy Inquiry" in the subject line to ensure routing to the appropriate team.

gl77 is committed to resolving all privacy-related inquiries and complaints promptly and in good faith. If you are not satisfied with gl77's response to a privacy complaint, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines, which has jurisdiction over data privacy matters under RA 10173.