fll777 Privacy Policy

1. Introduction

fll777 ("fll777," "we," "us," or "our") is committed to protecting the privacy and personal data of every Filipino player who uses our online gaming platform at fll777.com and any associated mobile applications or services (collectively, the "Platform"). This Privacy Policy ("Policy") describes how fll777 collects, uses, stores, shares, and protects your personal information when you access or use the Platform.

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as enforced by the National Privacy Commission ("NPC") of the Philippines. By registering an account with fll777 or by continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, which together govern your use of the fll777 Platform.

2. Data Controller Information

For the purposes of the Philippine Data Privacy Act of 2012, the data controller responsible for your personal information is fll777, operating the Platform at fll777.com. Our designated Data Protection Officer ("DPO") can be contacted at:

• Email: [email protected]
• Subject Line: Data Privacy Enquiry / DPO
• Location: Manila, Philippines
• Support Hours: 24/7, Philippine Standard Time (PST, UTC+8)

If you have any questions about how fll777 handles your personal data, or if you wish to exercise any of your rights under the DPA, please contact our DPO using the details above.

3. Personal Data We Collect

fll777 collects the following categories of personal data from players and users of the Platform:

fll777 does not collect sensitive personal information (as defined under the DPA, such as health data, political opinions, or religious beliefs) unless specifically required for regulatory compliance purposes and with your explicit consent.

4. How We Collect Your Data

fll777 collects your personal data through the following means:

• Direct Interactions: When you register an account, complete KYC verification, make a deposit or withdrawal, contact our support team, or participate in a promotion on the fll777 Platform.
• Automated Technologies: When you access the Platform, fll777 automatically collects technical and usage data through cookies, web beacons, server logs, and similar tracking technologies.
• Third-Party Sources: fll777 may receive data about you from payment processors (such as GCash and PayMaya), identity verification service providers, and fraud prevention partners, where necessary for compliance and security purposes.
• KYC Verification: During the Know Your Customer process, you will be asked to submit copies of government-issued identification documents and, in some cases, a live selfie for biometric verification.

5. How We Use Your Data

fll777 uses your personal data for the following purposes:

• To create and manage your fll777 player account and verify your identity and age (21+ requirement).
• To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• To comply with our Anti-Money Laundering (AML) obligations under the Philippine Anti-Money Laundering Act (AMLA) and to report suspicious transactions to the Anti-Money Laundering Council (AMLC) where required.
• To detect, prevent, and investigate fraud, cheating, and other prohibited conduct on the Platform.
• To provide customer support and respond to your enquiries.
• To send you transactional communications, including deposit confirmations, withdrawal notifications, and security alerts.
• To send you marketing communications about fll777 promotions, bonuses, and new games — only where you have given your consent or where permitted by applicable law.
• To monitor your gaming activity for responsible gaming purposes, including identifying signs of problem gambling and applying self-exclusion or deposit limit tools where appropriate.
• To improve the fll777 Platform, personalise your experience, and conduct internal analytics and research.
• To comply with all applicable Philippine laws and regulations, including the DPA, AMLA, and any directives issued by PAGCOR or other relevant regulatory authorities.

6. Legal Basis for Processing

fll777 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Consent: Where you have given fll777 your explicit consent to process your data for a specific purpose, such as receiving marketing communications.
• Contractual Necessity: Where processing is necessary to perform our contract with you — i.e., to operate your fll777 account, process transactions, and provide gaming services.
• Legal Obligation: Where processing is required for fll777 to comply with a legal obligation, including AML reporting, KYC verification, and regulatory compliance.
• Legitimate Interests: Where processing is necessary for fll777's legitimate interests, such as fraud prevention, platform security, and improving our services, provided those interests are not overridden by your rights and freedoms.

7. Data Sharing & Disclosure

fll777 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. fll777 may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and biometric verification service providers engaged by fll777 to verify your identity and age.
• Fraud Prevention & Security Partners: Service providers that assist fll777 in detecting and preventing fraud, money laundering, and other prohibited activities.
• Regulatory Authorities: The National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), PAGCOR, and other Philippine government authorities, where fll777 is legally required to disclose your data.
• IT & Cloud Service Providers: Providers of hosting, data storage, and platform infrastructure services engaged by fll777, subject to appropriate data processing agreements.
• Professional Advisers: Lawyers, auditors, and other professional advisers engaged by fll777, subject to confidentiality obligations.

All third parties with whom fll777 shares personal data are required to handle that data in accordance with the Philippine Data Privacy Act and fll777's data protection standards.

8. Cookies & Tracking Technologies

fll777 uses cookies and similar tracking technologies on the Platform to enhance your experience and for essential operational purposes. The types of cookies we use include:

• Strictly Necessary Cookies: Required for the Platform to function correctly, including maintaining your login session and processing transactions. These cannot be disabled.
• Performance & Analytics Cookies: Used to collect anonymised information about how players use the fll777 Platform, helping us identify areas for improvement.
• Functional Cookies: Used to remember your preferences, such as language settings and display options, to personalise your experience.
• Security Cookies: Used to detect and prevent fraudulent activity and protect the integrity of your fll777 account.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the fll777 Platform. fll777 does not use cookies to serve third-party advertising.

9. Data Retention

fll777 retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. Our general retention periods are as follows:

• Account Data: Retained for the duration of your active fll777 account, plus a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required under the Philippine AMLA.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by a regulatory authority.
• Support Communications: Retained for two (2) years from the date of the last communication.
• Marketing Preferences: Retained until you withdraw your consent or request deletion.

When your personal data is no longer required, fll777 will securely delete or anonymise it in accordance with our data disposal procedures.

10. Data Security

fll777 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security measures include:

• TLS 1.3 encryption for all data transmitted between your device and the fll777 Platform.
• AES-256 encryption for personal data stored at rest on fll777 servers.
• Multi-factor authentication (MFA) for access to fll777 internal systems containing personal data.
• Regular penetration testing and security audits of the fll777 Platform.
• Strict access controls ensuring that only authorised fll777 personnel can access personal data, on a need-to-know basis.
• Staff training on data privacy and security obligations under the Philippine DPA.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, fll777 will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the DPA.

11. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by fll777:

• Right to be Informed: The right to be informed of how your personal data is being collected and processed — which this Policy fulfils.
• Right of Access: The right to request a copy of the personal data fll777 holds about you.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data fll777 holds about you.
• Right to Erasure: The right to request deletion of your personal data, subject to fll777's 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.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe fll777 has violated your data privacy rights.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." fll777 will respond to your request within thirty (30) days, as required by the DPA.

12. Children's Privacy

The fll777 Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. fll777 does not knowingly collect personal data from individuals under the age of 21. If fll777 becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended, all data will be deleted, and any deposits will be returned to the verified payment source.

If you are a parent or guardian and believe that your child has registered an account with fll777, please contact us immediately at [email protected].

13. Cross-Border Data Transfers

fll777 primarily processes and stores personal data within the Republic of the Philippines. In certain circumstances, personal data may be transferred to and processed in countries outside the Philippines — for example, where fll777 uses cloud infrastructure or service providers with servers located abroad.

Where such transfers occur, fll777 ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that impose data protection obligations equivalent to those under the Philippine DPA. fll777 will not transfer your personal data to a country that does not provide an adequate level of data protection without your explicit consent or without implementing appropriate safeguards.

14. Changes to This Policy

fll777 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When a material change is made to this Policy, fll777 will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the change takes effect.

The "Last Updated" date at the top of this Policy will always reflect the date of the most recent revision. Your continued use of the fll777 Platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

15. Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or fll777's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: Privacy Policy Enquiry / Data Subject Rights
• Support Hours: 24/7, Philippine Standard Time (PST, UTC+8)
• Location: Manila, Philippines

If you are not satisfied with fll777's response to your complaint, you have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines, the independent authority responsible for enforcing the Data Privacy Act of 2012.