hp77 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how hp77 ("we," "us," or "our") collects, uses, stores, shares, and protects the personal information of individuals ("you," "the Player," or "the Data Subject") who access or use the hp77 platform at hp77.club and any related services.

hp77 operates as a PAGCOR-regulated online gaming platform serving Filipino players. As a personal information controller under the Data Privacy Act of 2012, hp77 is responsible for ensuring that your personal data is processed lawfully, fairly, and transparently, and that it is kept secure at all times.

By registering an account on hp77 or using any of our services, 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 this Policy, please do not use the hp77 platform.

2. Data Controller Information

hp77 acts as the personal information controller for all personal data collected through the hp77 platform. As the controller, hp77 determines the purposes and means of processing your personal data and is responsible for ensuring compliance with the Data Privacy Act of 2012 and all applicable Philippine data protection regulations.

hp77 has appointed a Data Protection Officer (DPO) who is responsible for overseeing data protection strategy and implementation. You may contact the hp77 DPO directly for any privacy-related concerns using the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

3.1 Registration and Identity Data

When you create an hp77 account, we collect the following information:

• Full legal name;
• Date of birth (to verify you are at least 21 years of age);
• Email address;
• Mobile phone number;
• Residential address (city, province, postal code);
• Username and encrypted password.

3.2 Identity Verification (KYC) Data

To comply with PAGCOR regulations and Anti-Money Laundering Act (AMLA) requirements, we may collect:

• Government-issued identification documents (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, UMID);
• Proof of address documents;
• Selfie or facial verification image for identity matching purposes.

3.3 Financial and Transaction Data

We collect information related to your financial transactions on hp77, including:

• Deposit and withdrawal amounts and dates;
• Payment method identifiers (e.g., GCash mobile number, bank account name — not full account numbers);
• Transaction history and account balance records.

3.4 Gaming Activity Data

We collect records of your gaming activity on hp77, including game sessions, bet amounts, game outcomes, and bonus usage. This data is used for regulatory reporting, responsible gaming monitoring, and platform improvement purposes.

3.5 Technical and Usage Data

When you access hp77, we automatically collect certain technical information, including:

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Pages visited, time spent on the platform, and clickstream data;
• Session duration and login timestamps.

3.6 Communications Data

We retain records of communications between you and hp77 support, including live chat transcripts, email correspondence, and any feedback or complaints submitted through the platform.

4. How We Collect Your Data

hp77 collects your personal data through the following means:

• Directly from you: When you register an account, complete identity verification, make deposits or withdrawals, contact support, or participate in promotions;
• Automatically: Through cookies, web beacons, and similar tracking technologies when you access and use the hp77 platform;
• From third parties: From identity verification service providers, payment processors, and fraud prevention services where necessary to verify your identity or process transactions;
• From PAGCOR and regulatory bodies: Where required for regulatory compliance purposes.

5. How We Use Your Personal Data

hp77 uses your personal data for the following purposes:

6. Legal Basis for Processing

hp77 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfill our obligations under the hp77 Terms & Conditions, including account management, payment processing, and service delivery;
• Legal obligation: Processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws;
• Legitimate interests: Processing for fraud prevention, security monitoring, and platform improvement, where such interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing and Disclosure

7.1 Service Providers

hp77 shares personal data with trusted third-party service providers who assist in operating the platform, including payment processors, identity verification providers, cloud hosting providers, and customer support platforms. All service providers are bound by data processing agreements requiring them to protect your data and use it only for the specified purpose.

7.2 Regulatory Authorities

hp77 is required by law to share certain personal data and transaction records with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities upon lawful request or as required by applicable regulations.

7.3 Game Providers

To provide gaming services, hp77 shares limited technical data (such as player session tokens) with licensed game providers. Game providers do not receive your full personal profile and are contractually prohibited from using any shared data for purposes other than game delivery.

7.4 No Sale of Personal Data

hp77 does not sell, rent, or trade your personal information to any third party for commercial or marketing purposes. Any data sharing is strictly limited to what is necessary for the purposes described in this Policy.

8. Data Retention

hp77 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law :

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR regulations and the Anti-Money Laundering Act;
• Financial and transaction records: Retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLA requirements;
• KYC documents: Retained for a minimum of five (5) years following the end of the business relationship;
• Gaming activity data: Retained for a minimum of three (3) years for responsible gaming monitoring and regulatory reporting purposes;
• Communications data: Retained for two (2) years from the date of the communication, unless a longer period is required for dispute resolution;
• Technical and usage data: Retained for up to twelve (12) months, after which it is anonymized or deleted.

Upon expiry of the applicable retention period, hp77 will securely delete or anonymize your personal data in accordance with its data disposal procedures.

9. Cookies and Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit hp77.club. They help us recognize your device, remember your preferences, and understand how you use our platform. hp77 also uses similar technologies such as web beacons and local storage for comparable purposes.

9.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the platform to function. These include session authentication cookies and security tokens. They cannot be disabled without affecting core platform functionality;
• Functional cookies: Remember your preferences such as language settings, display options, and last-used payment method to improve your experience;
• Analytics cookies: Help us understand how players use hp77 by collecting anonymized usage statistics. This data is used to improve platform performance and user experience;
• Marketing cookies: Used only with your explicit consent to deliver relevant promotional content within the hp77 platform. hp77 does not use third-party advertising networks.

9.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the hp77 platform. Instructions for managing cookies are available in the help documentation of your browser.

10. Security Measures

hp77 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and hp77 servers is encrypted using TLS 1.3. Stored personal data is encrypted using AES-256 encryption;
• Access controls: Access to personal data is restricted to authorized hp77 personnel on a strict need-to-know basis. All staff with access to personal data undergo regular data privacy training;
• Two-factor authentication: Available for all player accounts and mandatory for hp77 administrative systems;
• Regular security audits: hp77 conducts regular penetration testing and security audits of its systems and infrastructure;
• Incident response: hp77 maintains a documented data breach response plan and will notify the NPC and affected players in the event of a qualifying breach, as required by the Data Privacy Act of 2012.

11. Your Data Privacy Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by hp77:

• Right to be informed: The right to be informed of how your personal data is being collected and processed, as described in this Policy;
• Right of access: The right to request a copy of the personal data hp77 holds about you, along with information about how it is being processed;
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data hp77 holds about you;
• Right to erasure: 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 hp77's legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact the hp77 Data Protection Officer using the details in Section 15. hp77 will respond to all data rights requests within fifteen (15) business days of receipt. We may need to verify your identity before processing your request.

12. Children's Privacy and Age Restrictions

hp77 is strictly an adult gaming platform. In accordance with PAGCOR regulations, you must be at least 21 years of age to register and use hp77. hp77 does not knowingly collect personal data from individuals under the age of 21.

If hp77 becomes aware that personal data has been collected from a person under 21 years of age, the account will be immediately suspended, all data will be deleted, and any funds will be returned to the payment source. If you believe a minor has registered on hp77, please contact our support team immediately.

hp77 employs age verification procedures during registration and may request additional documentation to confirm a player's age at any point during the account lifecycle.

13. International Data Transfers

hp77 primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or accessed from locations outside the Philippines — for example, where hp77 uses cloud infrastructure or service providers with operations in other countries.

Where such transfers occur, hp77 ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual clauses, data processing agreements, or transfers to countries recognized as providing adequate data protection.

By using hp77, you consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

14. Changes to This Privacy Policy

hp77 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, hp77 will notify registered players via email or a prominent notice on the platform prior to the changes taking effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how hp77 protects your personal data. Your continued use of hp77 following the publication of a revised Policy constitutes your acceptance of the changes.

15. Contact Us and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by hp77, please contact our Data Protection Officer:

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you believe your data privacy rights have not been adequately addressed by hp77.