Privacy Policy — 777link Platform

01 Policy Overview

This Privacy Policy ("Policy") is issued by 777link ("777link", "we", "us", "our"), the operator of the online gaming platform accessible at 777link.net and all associated subdomains and mobile interfaces (the "Platform"). This Policy applies to all personal data collected from individuals who access or use the Platform, whether as registered players, prospective registrants, or visitors browsing the Platform without an account.

777link is committed to protecting the privacy and personal data of all users in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC") of the Philippines. We also observe applicable PAGCOR data governance requirements in our capacity as a regulated gaming operator.

By accessing or using the 777link 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. If you do not agree with this Policy, you must discontinue use of the Platform immediately.

02 Data Controller

For the purposes of the Data Privacy Act of 2012, 777link acts as the Personal Information Controller (PIC) in respect of all personal data collected through the Platform. As PIC, 777link determines the purposes for which and the means by which your personal data is processed.

777link has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the DPA and this Policy. The DPO may be contacted via the details provided in Section 14 of this Policy. All data privacy concerns, requests to exercise data subject rights, and breach notifications should be directed to the DPO in the first instance.

03 Personal Data We Collect

777link collects personal data across three broad categories depending on how you interact with the Platform:

3.1 Registration & Account Data

When you register an account on 777link, we collect the following information:

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify that you are 21 years of age or older);
• Gender;
• Nationality and country of residence;
• Residential address, including barangay, city or municipality, and province;
• Mobile number and email address;
• Username and encrypted password;
• Government-issued identification number (e.g., PhilSys National ID, Passport, Driver's License, SSS/GSIS ID, Voter's ID).

3.2 Financial & Transaction Data

To process deposits, withdrawals, and comply with anti-money laundering obligations, we collect:

• Payment method details (e.g., GCash account number, PayMaya account, BPI, BDO, or Metrobank account details sufficient to process transactions);
• Transaction history, including deposit amounts, withdrawal amounts, dates, and payment references;
• Source of funds documentation, where required for KYC or AML compliance;
• Bonus and promotion redemption records.

3.3 Technical & Usage Data

When you access the Platform, our systems automatically collect certain technical information:

• IP address and approximate geolocation derived therefrom;
• Device type, operating system, and browser type and version;
• Session logs, including login timestamps, session duration, and pages visited;
• Game play history, wagering activity, and betting patterns;
• Cookie identifiers and similar tracking technologies (see Section 9).

3.4 Communications Data

If you contact our support team, participate in surveys, or engage with 777link through any channel, we may retain:

• The content of support chat transcripts, emails, and Messenger or Viber messages;
• Records of complaints and dispute resolution outcomes;
• Survey responses and feedback submitted through the Platform.

04 Purpose of Processing

777link processes your personal data for the following specific, legitimate purposes:

777link does not use your personal data for any purpose that is incompatible with the purposes listed above without obtaining your prior consent or unless otherwise required by law.

05 Legal Basis for Processing

Under the Data Privacy Act of 2012, 777link relies on the following legal bases for processing your personal data:

• Consent: For marketing communications and any processing not otherwise covered by the bases below. You may withdraw consent at any time without affecting the lawfulness of prior processing;
• Contractual Necessity: Processing required to perform the contract between you and 777link, including account management and payment processing;
• Legal Obligation: Processing necessary to comply with applicable laws, including KYC verification requirements, PAGCOR regulations, the Anti-Money Laundering Act, and National Privacy Commission reporting obligations;
• Legitimate Interest: Processing necessary for fraud detection, platform security, and internal analytics, where these interests are not overridden by your privacy rights.

06 Data Sharing & Disclosure

777link may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements where required:

• PAGCOR and Regulatory Authorities: We are legally required to share player information with PAGCOR and, where applicable, the Anti-Money Laundering Council (AMLC) upon lawful request or as part of regular regulatory reporting;
• Payment Processors: Your financial data is shared with our payment partners (including GCash, PayMaya, BPI, BDO, and Metrobank) solely to process your transactions;
• KYC and Identity Verification Providers: Third-party identity verification services that assist 777link in fulfilling KYC obligations under applicable law;
• IT Infrastructure and Hosting Providers: Technology vendors who provide server hosting, database management, and cybersecurity services for the Platform, subject to strict confidentiality obligations;
• Customer Support Platforms: Tools used to manage live chat, email, and messaging support channels;
• Law Enforcement and Courts: Where we are compelled by a valid court order, subpoena, or lawful request from a Philippine law enforcement authority;
• Professional Advisers: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third parties with whom 777link shares personal data are required to maintain appropriate technical and organisational safeguards and to process your data only for the specific purposes for which it was shared.

07 Data Retention

777link 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. The following general retention periods apply:

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymised in accordance with 777link's data disposal procedures. Where data must be retained beyond standard periods due to ongoing legal proceedings or regulatory investigations, we will notify you where legally permitted to do so.

08 Data Security

777link implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, destruction, or accidental loss. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and the 777link Platform is encrypted using industry-standard TLS protocols;
• Password Hashing: Account passwords are stored using strong cryptographic hashing algorithms and are never stored in plaintext;
• Access Controls: Access to personal data by 777link staff is strictly limited on a role-based, need-to-know basis, with all access logged and audited;
• Firewall and Intrusion Detection: The Platform is protected by enterprise-grade firewalls and continuous intrusion detection and prevention systems;
• Regular Security Audits: 777link conducts periodic vulnerability assessments and penetration testing of its systems;
• Data Breach Response: 777link maintains a documented data breach response plan and will notify affected data subjects and the National Privacy Commission within 72 hours of becoming aware of a breach that poses risk to your rights and freedoms, as required by the DPA IRR.

While 777link takes all reasonable steps to protect your data, no online system can be guaranteed to be entirely secure. You are also responsible for maintaining the security of your own account by keeping your password confidential and logging out from shared devices.

09 Cookies & Tracking Technologies

777link 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. We use the following categories of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session management cookies that keep you logged in and security cookies that help protect the Platform. These cannot be disabled;
• Functional Cookies: Remember your preferences such as language settings, responsible gaming limits, and display preferences to personalise your experience;
• Analytics Cookies: Help us understand how players use the Platform by collecting anonymised information about pages visited, session duration, and navigation paths. This data is used exclusively to improve the Platform;
• Marketing Cookies: Used only where you have given explicit consent to receive personalised promotional content. You may withdraw this consent at any time by updating your account preferences.

You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies may impair the functionality of the Platform. 777link does not use third-party advertising network cookies that track you across unrelated websites.

10 Your Data Subject Rights

Under the Data Privacy Act of 2012 and the regulations of the National Privacy Commission, you have the following rights with respect to your personal data held by 777link. To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14.

• Right to Be Informed

  You have the right to be informed that your personal data is being collected and processed, for what purposes, and on what legal basis — as described in this Policy.
• Right to Access

  You have the right to request a copy of the personal data that 777link holds about you, along with information about how it is processed. We will respond to verified access requests within 15 business days.
• Right to Rectification

  You have the right to request correction of inaccurate or incomplete personal data. You can update most account details directly from your account settings. For identity document corrections, please contact our DPO.
• Right to Erasure

  You have the right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you withdraw consent, or where processing is unlawful. This right is subject to 777link's legal retention obligations.
• Right to Object

  You have the right to object to processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interest grounds, subject to 777link demonstrating compelling legitimate grounds.
• Right to Data Portability

  You have the right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible and where processing is based on consent or contract.
• Right to Lodge a Complaint

  If you believe 777link has not handled your personal data in accordance with the DPA, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.

11 Minors & Age Policy

777link implements age verification checks at the point of registration and during KYC review to ensure compliance with Philippine gaming law. If 777link becomes aware that personal data has been collected from an individual under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and report the matter to PAGCOR as required by our operating licence conditions.

If you are a parent or guardian and believe that a minor under your care has registered an account on 777link, please contact our Data Protection Officer immediately at the details listed in Section 14. We take underage gambling extremely seriously and will act promptly on any such report.

12 Cross-Border Data Transfers

777link primarily processes personal data within the Philippines. Where it becomes necessary to transfer your personal data to service providers or infrastructure located outside the Philippines — for example, in the context of cloud hosting services or international payment processing partners — 777link will ensure that such transfers are conducted in compliance with Section 21 of the Data Privacy Act of 2012 and the relevant NPC guidelines on cross-border data transfers.

Such transfers will only occur where: (a) the recipient country provides an adequate level of protection for personal data as determined by the NPC; (b) appropriate contractual safeguards are in place, such as standard contractual clauses approved by the NPC; or (c) you have provided explicit informed consent to the transfer.

You may request information about specific cross-border transfer arrangements by contacting our Data Protection Officer.

13 Amendments to This Policy

777link reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or the features and functionality of the Platform. When material changes are made, we will notify you via the email address associated with your account and display a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy will be revised each time an amendment is made. Your continued use of the Platform following the effective date of any amendment constitutes your acknowledgment of the updated Policy. We encourage you to review this Policy periodically to stay informed of how 777link protects your personal data.

14 Contact the Data Protection Officer

For all data privacy enquiries, requests to exercise your data subject rights, or concerns regarding 777link's handling of your personal data, please contact our Data Protection Officer through the following channels:

777link will acknowledge your request within five (5) business days and will endeavour to resolve all data subject rights requests within fifteen (15) business days of receiving sufficient information to process the request. For complex requests, this period may be extended by a further fifteen (15) business days with written notification to you.

If you are not satisfied with how 777link has handled your privacy concern, you may escalate your complaint to the National Privacy Commission of the Philippines. Information on how to file a complaint is available through the NPC's official channels.