fi777 Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how fi777.club ("fi777," "we," "us," or "our") collects, uses, discloses, and protects personal information provided by or relating to individuals ("Members," "Users," or "you") who access or use the fi777 website, mobile applications, and related services (collectively, the "Platform").

fi777 operates in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) ("DPA"), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission ("NPC"). By registering for a fi777 account or using any Platform feature, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy is to be read alongside the fi777 Terms & Conditions. In the event of any conflict, the Terms & Conditions shall prevail with respect to Platform use rules, and this Policy shall govern all matters of personal data processing.

2. Data Controller

The data controller responsible for your personal data is fi777.club, the operator of the fi777 Platform. For all data privacy matters, you may contact our designated Data Protection Officer ("DPO") at the contact details provided in Section 15 of this Policy.

fi777 has registered its data processing activities with the National Privacy Commission of the Philippines as required under the DPA and its implementing rules.

3. Personal Data We Collect

fi777 collects personal data in the following categories:

fi777 does not collect sensitive personal information (as defined under the DPA, including racial or ethnic origin, health information, or political opinions) except where strictly required by law (e.g., AML-related documentation).

4. How We Collect Personal Data

fi777 collects personal data through the following means:

• Direct Provision: Information you enter during account registration, KYC verification, deposit/withdrawal forms, contact forms, and live chat interactions.
• Automated Collection: Technical data collected automatically when you access the Platform, including via cookies, web beacons, and server logs.
• Third-Party Sources: Identity verification data from KYC service providers; payment verification data from GCash, Maya, and other payment processors; fraud detection signals from security partners.
• Regulatory Sources: Data provided by PAGCOR, the Anti-Money Laundering Council ("AMLC"), or law enforcement agencies pursuant to lawful orders or requests.

5. Purpose and Legal Basis for Processing

fi777 processes your personal data for the following purposes and on the following legal bases under the DPA:

• Account Management (Contractual Necessity): Creating and maintaining your fi777 account; processing login and session management; providing customer support.
• Transaction Processing (Contractual Necessity): Processing deposits, withdrawals, and bonus credits; verifying payment source ownership.
• KYC and Age Verification (Legal Obligation): Verifying that Members are 21 years of age or older; complying with PAGCOR licensing requirements and the DPA.
• AML Compliance (Legal Obligation): Monitoring transactions for money laundering indicators; filing suspicious transaction reports with the AMLC as required under RA 9160 as amended.
• Responsible Gaming (Legitimate Interest / Legal Obligation): Monitoring gaming behaviour to identify potential problem gambling; administering self-exclusion and deposit limit programmes.
• Platform Security (Legitimate Interest): Detecting and preventing fraud, account takeovers, bot activity, and other platform abuse.
• Marketing Communications (Consent): Sending promotional offers, bonus notifications, and platform news where you have provided explicit consent. You may withdraw consent at any time via account settings.
• Analytics and Improvement (Legitimate Interest): Analysing aggregated usage patterns to improve Platform performance, game selection, and user experience.

6. Cookies and Tracking Technologies

fi777 uses cookies and similar technologies to operate and improve the Platform. The categories of cookies used include:

• Strictly Necessary Cookies: Required for Platform functionality including session management and login state. Cannot be disabled.
• Performance Cookies: Collect anonymised data on page load times, error rates, and navigation patterns to improve Platform performance.
• Functional Cookies: Remember your language preferences, game lobby settings, and last-visited game category.
• Analytics Cookies: Used to understand aggregate user behaviour on the Platform. Data is anonymised and not linked to individual accounts.

You may manage non-essential cookie preferences through your browser settings. Note that disabling certain cookies may affect Platform functionality. fi777 does not use third-party advertising or behavioural tracking cookies.

7. Data Sharing and Disclosure

fi777 does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients where necessary and lawful:

• Service Providers: KYC verification partners, payment processors (GCash, Maya, BPI, BDO, InstaPay), fraud detection vendors, cloud infrastructure providers, and IT support partners — all operating under data processing agreements with confidentiality and security obligations.
• Game Providers: Licensed game studios (e.g., JILI, PG Soft, Pragmatic Play) receive pseudonymised player identifiers for game outcome verification. Full identity data is not shared with game providers.
• Regulatory Authorities: PAGCOR, the AMLC, the National Privacy Commission, and law enforcement agencies upon receipt of lawful orders or as required by applicable Philippine law.
• Corporate Transactions: In the event of a merger, acquisition, or sale of Platform assets, personal data may be transferred as part of the transaction subject to equivalent privacy protections.

8. International Data Transfers

Some fi777 service providers and game providers are located outside the Philippines. Where personal data is transferred internationally, fi777 ensures that adequate protections are in place, including contractual clauses requiring the recipient to maintain data protection standards equivalent to those required by the Philippine DPA. fi777 does not transfer data to jurisdictions that do not provide adequate data protection safeguards without implementing appropriate supplemental measures.

9. Data Retention

fi777 retains personal data for as long as necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and Transaction Records: 5 years from account closure or last transaction, as required by PAGCOR and AMLC regulations.
• KYC Documentation: 5 years from the date of verification, or longer if required by regulatory direction.
• Gaming and Session Logs: 2 years from the date of each session.
• Support Communications: 2 years from the date of the interaction.
• Marketing Consent Records: Until consent is withdrawn, plus 1 year for audit purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with fi777's data destruction procedures.

10. Your Rights Under the Philippine Data Privacy Act

As a data subject under the DPA, you have the following rights with respect to your personal data held by fi777:

• Right to be Informed: The right to know that your personal data is being collected and processed, and the purposes for which it is processed — as set out in this Policy.
• Right of Access: The right to request a copy of the personal data fi777 holds about you.
• Right to Rectification: The right to correct inaccurate or incomplete personal data.
• Right to Erasure / Right to be Forgotten: The right to request deletion of your personal data where processing is no longer necessary, subject to fi777's legal obligations to retain certain records.
• 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 a copy of your personal data in a structured, machine-readable format.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe fi777 has processed your personal data in violation of the DPA.

To exercise any of these rights, contact fi777's Data Protection Officer at the details in Section 15.

11. Security Measures

fi777 implements organisational, technical, and physical security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and fi777 servers;
• Encrypted storage of passwords using industry-standard hashing algorithms;
• Role-based access controls limiting staff access to personal data to those with a legitimate operational need;
• Regular penetration testing and vulnerability assessments of Platform infrastructure;
• 24/7 automated anomaly detection on login and transaction systems;
• Mandatory data privacy training for all fi777 staff with access to personal data.

While fi777 takes all reasonable precautions, no system is entirely immune to security risks. In the event of a personal data breach that is likely to result in a real risk to your rights, fi777 will notify affected Members and the National Privacy Commission within the timeframes required by the DPA.

12. Children's Privacy

The fi777 Platform is strictly restricted to individuals aged 21 years and above. fi777 does not knowingly collect personal data from individuals under 21. If fi777 becomes aware that an account has been registered by a person under the minimum age, the account will be immediately suspended, all personal data associated with that account will be deleted, and any funds held may be returned via the original payment method following verification.

Parents and guardians who believe a minor has registered a fi777 account should contact our support team immediately via the contact details in Section 15.

13. Third-Party Links

The fi777 Platform may contain links to third-party websites or services — including payment provider portals and game provider pages. fi777 is not responsible for the privacy practices of third-party sites and recommends that you review the privacy policies of any third-party site you visit. This Policy applies exclusively to data processed by fi777 in connection with the Platform.

14. Policy Updates

fi777 may update this Privacy Policy from time to time to reflect changes in our data processing practices, regulatory requirements, or Platform features. The most current version of this Policy is always available at fi777.club/privacy-policy. For material changes, fi777 will notify affected Members via their registered email address or a prominent Platform notification at least 14 days before the changes take effect. Continued use of the Platform after the effective date of any update constitutes acceptance of the revised Policy.

15. Contact & Complaints

For all data privacy enquiries, requests to exercise your data subject rights, or complaints regarding fi777's handling of your personal data, please contact our Data Protection Officer:

• Email (DPO): [email protected] (Subject line: "Data Privacy Request")
• Live Chat: Available 24/7 for logged-in Members via the fi777 Platform
• Response Time: fi777 will acknowledge data privacy requests within 3 business days and provide a substantive response within 30 calendar days, consistent with NPC guidelines.

If you are not satisfied with fi777's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (privacy.gov.ph). You may also seek assistance from PAGCOR's Player Protection unit where your concern relates to gaming data.