1. Introduction
q77 ("q77," "we," "us," or "our") operates the online gaming platform accessible at q77.lat (the "Platform"), which provides slots, live casino, bingo, fishing games, and sports betting services to registered players in the Philippines. q77 is committed to protecting the privacy of all users of the Platform ("Player," "you," or "your") in accordance with applicable Philippine data protection legislation, including the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations.
This Privacy Policy ("Policy") explains in clear terms what personal information q77 collects from you, why we collect it, how we use and store it, who we share it with, and what rights you have in relation to your personal data. This Policy should be read in conjunction with q77's Terms & Conditions.
By registering an account on q77, making a deposit, or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and 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 discontinue use of the Platform immediately.
2. Personal Data We Collect
q77 collects personal data from you directly โ when you register an account, make transactions, contact support, or interact with Platform features โ and automatically, through your use of the Platform. The categories of personal data we collect include:
| Category | Examples | Collection Method |
|---|---|---|
| Identity Data | Full legal name, date of birth, government ID number, ID document scan (SSS, UMID, driver's license, passport) | Account registration & KYC verification |
| Contact Data | Philippine mobile number, email address, city of residence | Account registration |
| Financial Data | GCash account number, Maya wallet reference, bank account details (BPI, BDO), transaction history in PHP | Deposit & withdrawal processing |
| Gaming Data | Game history, bet amounts, session duration, win/loss records, bonus usage, responsible gaming settings | Automated โ Platform activity |
| Technical Data | IP address, device type, browser type, operating system, session tokens | Automated โ server logs & cookies |
| Communication Data | Support chat transcripts, email correspondence, complaint records | Customer support interactions |
q77 does not intentionally collect special categories of personal data (such as health information, political opinions, or religious beliefs). If any such data is inadvertently provided, it will be deleted without use.
3. How We Use Your Personal Data
q77 uses your personal data solely for legitimate, specified purposes directly connected to the operation of the Platform and the provision of gaming services to Filipino players. Specifically, we use your data to:
- Register and manage your account โ including identity verification, account authentication, and maintenance of your account profile.
- Process financial transactions โ including GCash, Maya, BPI, and BDO deposits and withdrawals in Philippine Peso, and compliance with anti-money laundering (AML) obligations under Philippine law.
- Provide gaming services โ enabling access to all q77 game categories, recording game results, applying bonus credits, and maintaining your VIP status and loyalty point balance.
- Comply with legal and regulatory obligations โ including PAGCOR-related reporting requirements, AML/KYC obligations, and age verification (minimum 21 years).
- Deliver customer support โ responding to your queries, resolving disputes, and processing responsible gaming requests such as self-exclusion.
- Prevent fraud and ensure Platform security โ detecting suspicious activity, preventing multi-accounting, and protecting the integrity of games and financial transactions.
- Send service communications โ notifying you of account activity, promotional offers relevant to your gaming history, and important Platform updates. You may manage your communication preferences in your account settings.
- Improve the Platform โ analyzing aggregated, anonymized usage data to optimize game selection, user interface, payment processing, and responsible gaming features for Filipino players.
q77 does not sell, rent, or trade your personal data to third parties for their independent marketing purposes.
4. Legal Basis for Processing
q77 processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012 and applicable Philippine regulations:
- Consent โ Where you have given your explicit consent to the processing of your personal data for a specific purpose (e.g., receiving promotional communications). You may withdraw consent at any time by contacting support, noting that withdrawal does not affect the lawfulness of prior processing.
- Performance of a Contract โ Processing necessary to fulfill q77's obligations to you under the Terms & Conditions, including account management and payment processing.
- Compliance with a Legal Obligation โ Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing conditions, AML laws, and tax reporting obligations.
- Legitimate Interests โ Processing necessary for q77's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights and interests.
5. Sharing Your Personal Data
q77 does not share your personal data with third parties except in the following limited circumstances:
- Payment processors โ GCash (GXI), Maya (Voyager Innovations), BPI, BDO, and other payment service providers receive only the financial data necessary to process your deposit or withdrawal transaction.
- Game content providers โ Licensed third-party game studios (e.g., Pragmatic Play, PG Soft, Jili) may receive anonymized or pseudonymized gaming session data required to run their games on the q77 Platform. No directly identifying information is shared with game providers.
- Identity verification services โ Third-party KYC providers may process your government ID and facial verification data solely for the purpose of confirming your identity and age in compliance with Philippine regulatory requirements.
- Regulatory and law enforcement authorities โ q77 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), or other competent Philippine government authorities where required by law, court order, or regulatory direction.
- Professional advisors โ Legal, accounting, and auditing professionals engaged by q77 may access personal data on a strictly confidential and need-to-know basis.
All third parties with whom q77 shares personal data are required to process that data in accordance with applicable Philippine data protection law and q77's data processing standards. q77 does not transfer personal data to countries outside the Philippines unless adequate safeguards are in place.
6. Data Retention
q77 retains your personal data for as long as necessary to fulfill the purposes for which it was collected and to comply with applicable legal, regulatory, and contractual obligations. Specific retention periods include:
- Account and identity data: Retained for the duration of your account relationship with q77, plus a minimum of five (5) years following account closure, in compliance with Philippine AML record-keeping requirements.
- Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction.
- Gaming history data: Retained for a minimum of three (3) years from the relevant session date.
- Support correspondence: Retained for two (2) years from the resolution of the relevant support interaction.
- Technical and log data: Typically retained for twelve (12) months from collection.
Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized. Where data is required for ongoing legal proceedings or regulatory investigations, retention is extended for the duration of such proceedings.
7. Cookies and Tracking Technologies
q77 uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file stored on your device when you visit a website. q77 uses the following categories of cookies:
- Strictly necessary cookies โ Essential for the Platform to function. These include session authentication tokens, account login state cookies, and security cookies. These cannot be disabled.
- Functional cookies โ Enable the Platform to remember your preferences, such as language settings and responsible gaming configurations.
- Performance and analytics cookies โ Help q77 understand how Players use the Platform, which games are most popular, and where technical issues occur. Data collected is aggregated and anonymized.
You may control non-essential cookies through your browser settings. Note that disabling certain cookies may affect Platform functionality. q77 does not use cookies for third-party advertising or cross-site tracking purposes.
8. Data Security
q77 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. These measures include:
- TLS (Transport Layer Security) encryption for all data transmitted between your device and q77 servers.
- Encryption of sensitive data fields (including password hashes and payment credentials) at rest in q77 databases.
- Access controls limiting employee access to personal data on a strict need-to-know basis, with access logs maintained and audited.
- Regular security assessments and penetration testing of Platform infrastructure.
- Incident response procedures for detecting, reporting, and remediating data security incidents in compliance with the Data Privacy Act of 2012.
In the event of a personal data breach that creates a real risk of serious harm to you, q77 will notify you and the National Privacy Commission (NPC) within the timeframes required by applicable Philippine law.
9. Your Data Rights
Under the Data Privacy Act of 2012, registered q77 Players have the following rights with respect to their personal data:
- Right to be Informed โ The right to be told what personal data q77 holds about you and how it is used (this Policy fulfills this right).
- Right of Access โ The right to request a copy of the personal data q77 holds about you.
- Right to Rectification โ The right to have inaccurate or incomplete personal data corrected.
- Right to Erasure โ 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 q77's legal retention obligations.
- Right to Data Portability โ The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
- Right to Object โ The right to object to the processing of your personal data for direct marketing purposes. You may opt out of marketing communications at any time via your q77 account settings.
- Right to Damages โ The right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, or unlawfully obtained personal data.
To exercise any of the above rights, please contact q77's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." q77 will respond within thirty (30) days. You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.
10. Minors and Age Restriction
The q77 Platform is strictly for individuals aged 21 years and above, in accordance with PAGCOR's age restriction requirements for online gaming in the Philippines. q77 does not knowingly collect personal data from individuals under 21 years of age. If q77 discovers that personal data has been collected from an individual who is under the minimum age, that account will be immediately closed and all associated personal data deleted, with any deposited funds returned to the originating payment method following required verification.
Parents and guardians who believe their child may have registered an account on q77 are encouraged to contact q77 immediately at [email protected].
11. Changes to This Privacy Policy
q77 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or Platform features. When material changes are made, q77 will notify registered Players via email or on-platform notification and update the "Last updated" date at the top of this page. We encourage you to review this Policy periodically.
Your continued use of the q77 Platform following any update to this Privacy Policy constitutes your acceptance of the revised Policy.
12. Contact and Data Protection Officer
If you have any questions, concerns, or requests relating to this Privacy Policy or q77's data processing practices, please contact us:
- Email (Data Privacy): [email protected] โ Subject: "Data Privacy Request"
- Platform: q77.lat
- Responsible Gaming support: q77 Responsible Gaming page
For complaints that cannot be resolved directly with q77, you may contact the National Privacy Commission (NPC) of the Philippines, which oversees the enforcement of the Data Privacy Act of 2012.
q77's Privacy Commitments to Filipino Players
q77 processes all personal data in compliance with Republic Act No. 10173 (Data Privacy Act of 2012) and the regulations of the National Privacy Commission of the Philippines.
All data in transit is protected by TLS encryption. Sensitive account data stored in q77 databases is encrypted at rest. Your credentials and financial information are never stored in plain text.
q77 does not sell, rent, or trade your personal data to advertising networks or data brokers. Your information is used only to operate the Platform and fulfill legal obligations.
Access, correct, delete, or port your data โ these are genuine rights under Philippine law. q77 processes all data rights requests within 30 days and provides a dedicated support channel for privacy queries.
GCash, Maya, BPI, and BDO payment data is processed only by the respective licensed payment providers. q77 does not store full payment credentials on its own servers.
q77 collects age verification data specifically to enforce the 21+ requirement. Any account found to belong to an under-21 user is closed immediately and associated data deleted.