af77 Casino — Privacy Policy

Introduction and Scope

This Privacy Policy ("Policy") describes how af77 ("af77," "we," "us," "our") collects, uses, discloses, retains, and protects personal information provided by or collected about users ("you," "Player") of the af77 Casino platform accessible at af77.bio (the "Platform"). This Policy applies to all personal data processed in connection with your use of the Platform, including during account registration, identity verification, deposits and withdrawals, gameplay, promotional participation, and customer support interactions.

af77 is committed to protecting the privacy of its users in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations. By registering an account with af77 or using any part of 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.

Personal Data We Collect

af77 collects the following categories of personal data from or about you in connection with your use of the Platform:

af77 does not knowingly collect special categories of sensitive personal data (e.g., racial or ethnic origin, health information, political opinions, religious beliefs) except where required by applicable law or explicitly consented to by you.

How We Collect Personal Data

af77 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, submitting payment details, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including IP address, device identifiers, browser characteristics, and session activity logs, via cookies, web beacons, and similar tracking technologies.
• Third-party sources: Identity verification data received from KYC service providers; payment transaction data received from GCash, Maya, BPI, BDO, Metrobank, and other payment processors; fraud screening data from risk management services.

Where af77 uses cookies and similar technologies to collect technical data, you will be informed at the time of your first Platform visit. Certain cookies are essential for the operation of the Platform and cannot be disabled without affecting core functionality. Non-essential analytics and marketing cookies may be managed through your browser settings.

How We Use Your Personal Data

af77 processes your personal data only for specific, legitimate purposes. The following table sets out the purposes for which we process each category of personal data and the legal basis for that processing under the Philippine Data Privacy Act:

• Account creation and authentication: To register your account, verify your identity, and authenticate your login sessions. Legal basis: performance of contract; compliance with PAGCOR regulatory requirements.
• KYC and age verification: To confirm your identity and age (21+) as required by PAGCOR regulations and anti-money laundering laws. Legal basis: legal obligation; legitimate interests.
• Payment processing: To process deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, and other supported payment methods. Legal basis: performance of contract.
• Provision of gaming services: To provide access to all games, track your account balance, credit winnings, apply bonuses, and maintain your gameplay history. Legal basis: performance of contract.
• Customer support: To respond to your inquiries, resolve disputes, and assist with account issues. Legal basis: performance of contract; legitimate interests.
• Responsible gaming: To monitor gaming patterns for signs of problem gambling and to administer responsible gaming tools including deposit limits, loss limits, and self-exclusion. Legal basis: legal obligation; legitimate interests.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, account takeovers, money laundering, and other prohibited conduct. Legal basis: legal obligation; legitimate interests.
• Regulatory compliance: To comply with PAGCOR reporting obligations, anti-money laundering requirements, and requests from law enforcement or regulatory authorities. Legal basis: legal obligation.
• Platform improvement: To analyze aggregated, anonymized usage data for the purpose of improving Platform features, game offerings, and user experience. Legal basis: legitimate interests.
• Direct marketing (with consent): To send you promotional offers and news about af77, where you have opted in to receive such communications. You may opt out at any time. Legal basis: consent.

Disclosure of Personal Data to Third Parties

af77 does not sell your personal data to third parties for their own commercial purposes. We disclose personal data to third parties only in the following circumstances:

• Service providers and processors: af77 shares personal data with third-party service providers who process data on our behalf, including KYC identity verification services, payment processors (GCash, Maya, BPI, BDO, Metrobank), fraud detection services, cloud infrastructure providers, and customer support platform operators. All such providers are required by contract to process personal data only as instructed by af77 and in compliance with applicable data protection laws.
• Game providers: Certain technical data and gaming session data may be shared with third-party game providers whose games are accessible through the af77 Platform, to the extent necessary to provide those games and resolve technical disputes.
• Regulatory and law enforcement authorities: af77 will disclose personal data to PAGCOR, the National Privacy Commission, law enforcement agencies, financial intelligence units, or other government authorities when required to do so by applicable Philippine law, court order, or regulatory requirement.
• Business transfers: In the event of a merger, acquisition, restructuring, or sale of all or substantially all of af77's assets, personal data may be transferred to the relevant successor entity, subject to that entity providing equivalent privacy protections.

All third parties to whom af77 discloses personal data are required to maintain confidentiality of that data and to use it only for the specified purpose of disclosure.

Data Retention

af77 retains personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable Philippine law and regulation. The following retention periods apply:

• Account data and KYC documents: Retained for the duration of your active account plus a minimum of five (5) years following account closure, as required by PAGCOR regulations and anti-money laundering legislation.
• Transaction and financial data: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLC (Anti-Money Laundering Council) record-keeping requirements.
• Gaming history: Retained for the duration of your active account plus three (3) years following account closure, for dispute resolution and regulatory audit purposes.
• Customer support communications: Retained for two (2) years from the date of the communication, unless related to an unresolved dispute or regulatory matter.
• Technical and log data: Retained for twelve (12) months for security monitoring and fraud detection purposes.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized in accordance with af77's data disposal procedures.

Your Data Subject 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 af77:

• Right to be informed: You have the right to be informed about the personal data we collect about you and the purposes for which it is processed. This Privacy Policy fulfills that obligation.
• Right of access: You have the right to request a copy of the personal data af77 holds about you and information about how it is being processed.
• Right to rectification: You have the right to request correction of inaccurate or incomplete personal data. For basic account information, you may update data directly through your af77 account settings.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to af77's legal obligations to retain certain data under PAGCOR and AMLC requirements.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format, and to request transfer of that data to another controller where technically feasible.
• 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 other forms of processing where af77 relies on legitimate interests as the legal basis, subject to af77's overriding legitimate grounds.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe af77 has processed your personal data in violation of the DPA.

To exercise any of these rights, please contact af77's Data Privacy Officer at [email protected]. Requests will be acknowledged within 3 business days and fulfilled within 30 calendar days, subject to identity verification. af77 does not charge a fee for legitimate data subject requests.

Data Security Measures

af77 implements the following technical and organizational measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction:

• Encryption: All data transmitted between your device and the af77 Platform is encrypted using 256-bit SSL/TLS. Sensitive data fields in our databases (including identity document details and payment information) are encrypted at rest.
• Access controls: Access to personal data within af77's systems is restricted to authorized personnel on a need-to-know basis. All staff with access to personal data are bound by confidentiality obligations.
• Two-factor authentication: All af77 staff accounts with access to production systems and player data require multi-factor authentication. Player accounts support SMS-based 2FA on unrecognized device logins.
• Security monitoring: af77 conducts continuous monitoring of platform access logs for anomalous activity, and performs regular security assessments of its systems and infrastructure.
• Incident response: In the event of a personal data breach that is likely to result in harm to affected data subjects, af77 will notify the National Privacy Commission within 72 hours of discovery, and will notify affected players without undue delay, as required by the DPA.

While af77 takes all reasonable precautions to protect your personal data, no security system is perfectly impenetrable. You are also responsible for maintaining the security of your af77 account credentials and the device you use to access the Platform.

Cookies and Tracking Technologies

af77 uses cookies and similar tracking technologies (including web beacons and pixel tags) to operate the Platform, authenticate user sessions, prevent fraud, and analyze Platform performance. The following categories of cookies are used:

• Strictly necessary cookies: Required for basic Platform functionality, including session authentication, load balancing, and fraud prevention. These cookies cannot be disabled without impairing Platform operation.
• Performance and analytics cookies: Used to collect anonymized data about how users interact with the Platform, which pages are visited most frequently, and where errors occur. This data helps af77 improve the Platform experience.
• Functionality cookies: Used to remember your Platform preferences, such as language settings and game display options.

You can manage cookie preferences through your browser settings. However, disabling strictly necessary cookies may prevent you from accessing certain features of the af77 Platform, including the ability to log in and place bets.

Changes to This Privacy Policy

af77 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. When material changes are made, af77 will notify registered account holders by posting a notice on the Platform and, where feasible, by sending notification to your registered email address or mobile number at least 14 days before the amended Policy takes effect.

Your continued use of the af77 Platform following the effective date of any amended Privacy Policy constitutes your acceptance of the updated Policy. If you do not accept the amended Policy, you should close your account and request deletion of your personal data before the effective date.

The date at the top of this Privacy Policy reflects when it was last reviewed and updated. We encourage you to review this Policy periodically, even in the absence of a notification, to stay informed about how af77 protects your personal information.

Contact — Data Privacy Officer

If you have questions, concerns, or requests relating to this Privacy Policy or af77's data processing practices, please contact our Data Privacy Officer:

• Email: [email protected] — please include "Data Privacy" in your subject line
• Live Chat: Available 24/7 through the af77 Platform — request connection to the Data Privacy team
• Languages: Filipino and English

If you are not satisfied with af77's response to your privacy concern, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph. af77 fully cooperates with NPC investigations and will provide all requested information in response to a valid NPC inquiry.