lll77 Privacy Policy

lll77 ("lll77," "we," "us," or "our") operates the online gaming platform accessible at lll77.cam (the "Platform"). We respect your privacy and are committed to protecting the personal data you share with us when you register, play, deposit, or otherwise interact with the lll77 Platform.

This Privacy Policy describes the types of personal information lll77 collects from users of the Platform ("you," "your," or "Player"), the purposes for which that information is processed, the parties with whom it may be shared, the security measures we apply to protect it, and the rights you have over your own data.

This Policy is published in compliance with the Republic of the Philippines' Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, administered by the National Privacy Commission (NPC). By registering or using the lll77 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

For the purposes of the Data Privacy Act of 2012 and this Policy, the data controller responsible for your personal information is lll77, the operator of the Platform at lll77.cam.

All enquiries relating to the collection, processing, or handling of your personal data — including requests to exercise your data subject rights — should be directed to the lll77 Data Privacy Officer via the contact details set out in Section 15 of this Policy.

lll77 collects different categories of personal data depending on how you interact with the Platform. The main categories are described below.

3.1 Identity & Registration Data

• Full legal name (as it appears on your government-issued ID);
• Date of birth;
• Gender (optional);
• Nationality; and
• Government-issued identification document details (e.g., Philippine National ID, Passport, Driver's License, UMID, SSS ID) — collected during KYC verification.

3.2 Contact Data

• Registered Philippine mobile phone number (e.g., +63XXXXXXXXXX);
• Email address; and
• Residential address (for full KYC verification).

3.3 Financial & Transaction Data

• GCash or Maya account number linked to your lll77 account;
• Bank account details (BDO, BPI, Metrobank, UnionBank, or other Philippine banks) where used for deposits or withdrawals;
• Deposit and withdrawal history, amounts, dates, and payment method used; and
• Account balance and transaction records.

3.4 Gaming & Behavioural Data

• Games played, bet amounts, game duration, and win/loss records;
• Sports bets placed, events selected, and outcomes;
• Bonus claims, wagering activity, and promotional participation;
• Session timestamps, session duration, and login history; and
• Responsible gaming tool usage (e.g., deposit limits set, cooling-off periods activated).

3.5 Technical & Device Data

• IP address;
• Device type, model, and operating system;
• Browser type and version;
• Mobile network provider (e.g., Globe, Smart, DITO); and
• Platform access logs and error reports.

3.6 Communications Data

• Live chat transcripts with lll77 support agents;
• Email correspondence with lll77; and
• Responses to surveys, feedback forms, or promotional campaigns.

lll77 collects personal data through the following methods:

• Direct collection: Information you provide when you register an account, complete KYC verification, make deposits or withdrawals, contact support, or participate in promotions;
• Automated collection: Technical and behavioural data collected automatically when you access and use the Platform, including through cookies and similar tracking technologies (see Section 8);
• Third-party sources: Identity verification data from KYC service providers; payment and transaction data from GCash, Maya, BDO, BPI, and other payment processors; and fraud screening data from risk management service providers; and
• Publicly available sources: Where necessary for fraud prevention or regulatory compliance, lll77 may verify information against publicly available records.

lll77 uses your personal data for the following purposes:

lll77 does not sell your personal data to third parties for their own marketing purposes.

Under the Data Privacy Act of 2012, lll77 processes your personal data on the following legal bases:

• Performance of a contract: Processing necessary to create and manage your lll77 account, process transactions, and deliver the gaming services you have requested;
• Legal obligation: Processing required to comply with Philippine laws and regulations, including KYC, AML (Anti-Money Laundering Act), and PAGCOR reporting obligations;
• Legitimate interest: Processing for fraud prevention, platform security, responsible gaming monitoring, and service improvement — where such interests are not overridden by your rights; and
• Consent: For optional marketing communications, certain cookie categories, and any processing not covered by the bases above. You may withdraw consent at any time by contacting lll77 support.

lll77 may share your personal data with the following categories of third parties, strictly for the purposes described in this Policy:

• Payment processors: GCash, Maya, BDO, BPI, Metrobank, and other payment service providers, for the purpose of processing deposits and withdrawals;
• KYC and identity verification providers: Third-party services that assist lll77 in verifying player identity and age in compliance with applicable regulations;
• Game software providers: Third-party game suppliers (e.g., Pragmatic Play, PG Soft, Jili, Evolution) who provide the game engines and content available on the Platform. These providers operate their own servers and may process limited gaming-related data;
• Fraud prevention and AML service providers: Specialist firms that assist lll77 in detecting and preventing fraud, money laundering, and other financial crimes;
• Technology and hosting providers: Cloud infrastructure and IT service providers who host and maintain the lll77 Platform;
• Regulatory authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities where disclosure is required by law, court order, or regulatory directive; and
• Professional advisors: Legal counsel, auditors, and accountants, under obligations of confidentiality, where necessary to conduct lll77's business affairs.

All third-party processors engaged by lll77 are required to handle your personal data in compliance with applicable data protection law and lll77's data processing agreements. lll77 does not share your personal data with third parties for their independent marketing purposes.

lll77 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files placed on your device when you visit lll77.cam. The categories of cookies used are as follows:

• Strictly Necessary Cookies: Required for the Platform to function, including maintaining your login session, processing transactions, and ensuring Platform security. These cannot be disabled without affecting Platform functionality.
• Performance & Analytics Cookies: Used to collect aggregated, anonymised information about how players use the Platform — page visits, session duration, error rates — to help lll77 improve the user experience.
• Functional Cookies: Used to remember your preferences (e.g., language settings, lobby view) to provide a more personalised experience on return visits.
• Marketing & Targeting Cookies: Used (with your consent) to deliver relevant promotional content and measure the effectiveness of lll77's marketing activities. These may be disabled through your browser settings or by withdrawing consent.

lll77 retains your personal data only for as long as is necessary for the purposes described in this Policy, or as required by applicable Philippine law. The following retention periods apply as a general guide:

• Account and KYC records: Retained for a minimum of five (5) years following account closure, in compliance with Anti-Money Laundering Act requirements;
• Financial transaction records: Retained for a minimum of five (5) years following each transaction, as required by applicable financial record-keeping law;
• Gaming activity records: Retained for three (3) years following your last gaming session, or such longer period as required for dispute resolution or regulatory compliance;
• Support communications: Retained for two (2) years following the closure of each support interaction; and
• Marketing consent records: Retained until you withdraw consent and for a reasonable period thereafter for compliance documentation.

After the applicable retention period expires, lll77 will securely delete or anonymise your personal data in a manner that prevents reconstruction or identification.

lll77 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption: All data transmitted between your device and lll77 servers is encrypted in transit using industry-standard SSL/TLS protocols;
• Encrypted data storage: Sensitive data, including financial credentials and identity documents, is encrypted at rest;
• Access controls: Personal data is accessible only to authorised lll77 personnel and third-party processors who require it to perform their defined functions;
• Two-factor authentication: Available to all lll77 account holders as an additional layer of login security;
• Regular security assessments: lll77 conducts periodic security reviews and vulnerability assessments of the Platform; and
• Staff training: lll77 staff who handle personal data receive regular training on data protection obligations and secure data handling practices.

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights regarding your personal data held by lll77:

• Right to be Informed: You have the right to know what personal data lll77 collects, how it is used, and with whom it is shared — as set out in this Privacy Policy;
• Right of Access: You may request a copy of the personal data lll77 holds about you. lll77 will respond to verified access requests within thirty (30) calendar days;
• Right to Rectification: You have the right to request correction of inaccurate, incomplete, or outdated personal data in your lll77 account;
• Right to Erasure or Blocking: You may request that lll77 delete or block your personal data where it is no longer necessary for the purpose it was collected, or where processing is unlawful — subject to lll77's legal retention obligations;
• Right to Data Portability: Where technically feasible and where data has been processed electronically, you may request a structured, machine-readable copy of your personal data;
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interest, subject to lll77's legal and regulatory obligations;
• Right to Lodge a Complaint: If you believe that lll77 has processed your personal data in violation of RA 10173, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines; and
• Right to Damages: You may be entitled to compensation if you have suffered damages as a result of an inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data.

To exercise any of the above rights, please contact lll77's Data Privacy Officer using the details in Section 15. lll77 may require you to verify your identity before processing any data subject request, to prevent unauthorised access to your information.

The lll77 Platform is strictly for adults aged 21 years and above, in compliance with Philippine gambling regulations. lll77 does not knowingly collect personal data from any person under the age of 21.

Age verification is conducted as part of the lll77 registration and KYC process. If lll77 discovers that personal data has been collected from an individual who is under 21 years of age, that account will be immediately suspended, all associated funds will be frozen pending review, and the personal data will be deleted as soon as reasonably practicable.

The lll77 Platform may contain references to or integrations with third-party services, including payment processors (GCash, Maya, BDO) and game software providers. These third parties operate under their own privacy policies and lll77 is not responsible for the data practices of any third-party service you access independently of the lll77 Platform.

lll77 recommends that you review the privacy policies of any third-party service you interact with in connection with your lll77 account — particularly your e-wallet provider and bank — to understand how they process your personal data.

lll77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform features. Where a proposed change is material — meaning it affects your rights or how lll77 uses your personal data in a significant way — lll77 will notify you in advance by posting a notice on lll77.cam, sending an email to your registered address, or displaying a notification upon your next Platform login.

The effective date of this Policy (displayed in the meta bar above) reflects the date of the most recent revision. Your continued use of the lll77 Platform after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

lll77 strongly encourages you to review this Privacy Policy periodically to stay informed about how your data is being handled. The most current version is always available at lll77.cam/privacy-policy.

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by lll77, please contact us through any of the following channels:

• Live Chat: Available 24/7 directly on lll77.cam. This is the fastest way to reach the lll77 team for urgent data or account-related queries.
• Email: [email protected] — please note this address is displayed as plain text and is not a clickable link. Kindly use your email client to compose a message to this address manually.

Please mark the subject line of any email relating to data privacy matters as: "Privacy Policy / Data Subject Request." lll77 will acknowledge your request within five (5) business days and aims to resolve substantive privacy requests within thirty (30) calendar days, as required by the National Privacy Commission.