hph77 Privacy Policy

hph77 ("hph77", "we", "us", or "our") operates the online casino and sports betting platform accessible at hph77.net (the "Platform"). hph77 is regulated by the Philippine Amusement and Gaming Corporation (PAGCOR) and is committed to protecting the privacy and personal data of all individuals who interact with our Platform, including registered Players, prospective Players, and visitors to our website.

This Privacy Policy ("Policy") is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations issued by the National Privacy Commission ("NPC"). It applies to all personal data collected, processed, stored, and shared by hph77 in connection with the operation of the Platform and the provision of our gaming services to Filipino players across the Philippines, including those in Metro Manila, Cebu, Davao, Quezon City, Makati, and beyond.

By registering an Account on hph77 or by continuing to use the Platform, you acknowledge that you have read, understood, and accepted the data processing practices described in this Policy. If you do not agree with this Policy, you must discontinue use of the Platform and contact our support team to request closure of your Account.

hph77 collects the following categories of personal data from Players and Platform visitors. The specific data collected depends on how you interact with the Platform and the stage of your relationship with hph77.

hph77 collects personal data through the following means:

• Directly from You. When you register an Account, complete KYC verification, make a deposit or withdrawal, contact customer support, respond to a survey, or set responsible gaming preferences within your Account, you provide personal data directly to hph77.
• Automatically. When you visit or use the Platform, hph77's servers and analytics systems automatically collect Technical Data and Usage Data, including your IP address, device identifiers, and browsing behavior within the Platform. This collection occurs through server logs, cookies, and similar technologies described in Section 7 below.
• From Payment Providers. When you process a GCash, PayMaya, BPI, BDO, Metrobank, or Instapay transaction, the relevant payment service provider may share transaction confirmation data with hph77 to facilitate deposit crediting and withdrawal processing.
• From Identity Verification Services. hph77 may use third-party identity verification providers to assist with KYC processing. These providers check the authenticity of documents submitted by Players against relevant databases and return a verification result to hph77.
• From Fraud Prevention and Anti-Money Laundering Systems. hph77 uses automated monitoring systems that analyze transaction patterns and gameplay behavior to identify indicators of money laundering, fraud, or match-fixing activity, as required under Republic Act No. 9160 (Anti-Money Laundering Act) and PAGCOR compliance requirements.

hph77 processes your personal data only for specified, legitimate, and proportionate purposes. The following table sets out the primary purposes for which hph77 processes personal data and the corresponding legal basis under the Data Privacy Act of 2012:

Where hph77 relies on your consent as the legal basis for processing, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. To withdraw consent, update your communication preferences within your hph77 Account settings or contact our Data Protection Officer at the address provided in Section 13.

hph77 does not sell, rent, or trade your personal data to third parties for their independent marketing or commercial purposes. We share personal data only in the following circumstances and with the following categories of recipients:

• Payment Service Providers. GCash (Mynt), PayMaya (Maya Bank), BPI, BDO, Metrobank, and Instapay-connected financial institutions receive the minimum personal and financial data necessary to process your deposit and withdrawal transactions. Each provider is subject to Bangko Sentral ng Pilipinas (BSP) regulation and applicable data privacy obligations.
• Identity Verification Partners. Third-party KYC service providers receive the identity documents you submit for verification. These providers act as personal information processors under contracts that bind them to DPA-equivalent data protection standards.
• Game Content Providers. Licensed game studios (including but not limited to Evolution Gaming, Pragmatic Play, and similar providers) whose games are integrated into the hph77 Platform may receive session tokens and anonymous player identifiers necessary for game delivery. These providers do not receive your full identity or financial data.
• PAGCOR and Regulatory Authorities. hph77 is required by law to report certain information to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities. We comply with all lawful regulatory requests and court orders.
• IT and Platform Infrastructure Providers. Cloud hosting, cybersecurity, and platform infrastructure vendors may process technical data in the course of providing infrastructure services to hph77. These vendors are engaged under data processing agreements that prohibit use of hph77 player data for any independent purpose.
• Professional Advisors. Lawyers, auditors, and accountants engaged by hph77 may access player account data to the extent necessary for the provision of their professional services, subject to strict confidentiality obligations.

hph77 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and Identity Data. Retained for the duration of your active Account and for a minimum period of five (5) years following Account closure, in compliance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• Financial Transaction Records. Deposit, withdrawal, and wallet balance records are retained for a minimum of five (5) years following the date of each transaction, as required under RA 9160 and applicable PAGCOR regulations.
• KYC Documents. Copies of government-issued identity documents submitted for verification are retained for the period required by PAGCOR and AMLC regulations, and deleted or securely destroyed once the retention period has expired.
• Gaming History. Records of bets, game sessions, and outcomes are retained for five (5) years following Account closure for regulatory audit purposes.
• Customer Support Communications. Support ticket and chat records are retained for three (3) years from the date of the interaction, unless they are relevant to an ongoing dispute or investigation.
• Marketing Data. Where consent is the legal basis for marketing communications, data used for marketing purposes is retained until you withdraw your consent or your Account is closed, whichever is earlier.
• Technical and Usage Data. Server logs and anonymized analytics data are retained for up to twelve (12) months and then deleted or fully anonymized.

Where personal data is no longer required for any lawful purpose, hph77 will securely delete or anonymize it in accordance with its internal data disposal procedures.

hph77 uses cookies and similar tracking technologies on the Platform for the purposes described below. A cookie is a small data file placed on your device when you visit a website. Cookies do not give hph77 access to your device beyond the data they themselves contain.

• Strictly Necessary Cookies. These cookies are essential for the Platform to function. They maintain your login session, remember your language and display preferences, and enable secure access to your Account. These cookies cannot be disabled without impairing Platform functionality.
• Performance and Analytics Cookies. hph77 uses anonymized analytics to understand how Players navigate the Platform — which game categories are most visited, where drop-offs occur in the registration flow, and how the mobile experience compares to desktop. This data is used in aggregate and is not linked to your personal identity.
• Functionality Cookies. These cookies remember choices you have made — such as your preferred deposit method or your responsible gaming display settings — so you do not need to reconfigure them on each visit.
• Security Cookies. hph77 sets security-related cookies to detect unusual login patterns, multiple simultaneous sessions, or indicators of account compromise. These form part of our fraud prevention system.

You may configure your browser to block or delete cookies at any time. Please note that disabling strictly necessary cookies will prevent you from logging in to your hph77 Account and using the Platform's core features. hph77 does not use third-party advertising cookies or behavioral retargeting technologies.

hph77 implements technical, organizational, and administrative security measures appropriate to the nature of the personal data we process and the risks associated with its unauthorized disclosure, alteration, or destruction. Our security framework includes:

• Encryption. All data transmitted between your device and the hph77 Platform is encrypted using TLS (Transport Layer Security). Passwords are stored using industry-standard one-way cryptographic hashing — hph77 staff cannot read your password.
• Access Controls. Access to personal data held by hph77 is restricted on a strict need-to-know basis. Customer support agents, compliance staff, and technical teams are granted access only to the categories of data necessary for their specific role. Access logs are maintained and reviewed regularly.
• Infrastructure Security. The hph77 Platform is hosted on secure cloud infrastructure with firewalls, intrusion detection systems, and regular vulnerability assessments. Server environments are isolated and access-controlled.
• KYC Document Security. Identity documents submitted for verification are stored in encrypted form in a segregated document management system, accessible only to authorized KYC and compliance personnel.
• Incident Response. hph77 maintains a data breach response procedure. In the event of a personal data breach that poses a real risk to data subjects, hph77 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected Players without undue delay, in accordance with NPC Circular No. 16-03.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by hph77. These rights are available to all registered Players and to visitors who have submitted personal data through the Platform:

To exercise any of the above rights, submit a written request to hph77's Data Protection Officer at the contact details provided in Section 13. hph77 will acknowledge your request within three (3) business days and provide a substantive response within fifteen (15) business days, as required by NPC regulations. Where the complexity or volume of requests requires additional time, hph77 will notify you of the extension and the reason for it.

The hph77 Platform is strictly restricted to individuals who are at least twenty-one (21) years of age, in compliance with PAGCOR regulations and Philippine gaming law. hph77 does not knowingly collect personal data from individuals under the age of 21.

As part of the registration and KYC verification process, hph77 requires all Players to confirm their date of birth and to submit government-issued identification documents that confirm their age. Any Account found to be held by a person under the age of 21 will be immediately suspended, all pending transactions will be frozen pending review, and the matter may be referred to PAGCOR.

If you are a parent or guardian and you believe that a minor has registered an Account on hph77 or submitted personal data to our Platform without your knowledge, please contact our Data Protection Officer immediately at the address in Section 13. hph77 will promptly investigate and take appropriate action, including deletion of any personal data collected from the minor.

hph77 primarily processes personal data within the Philippines. However, in the course of operating the Platform, some personal data may be transmitted to or processed by third-party service providers — such as game content studios, cloud infrastructure vendors, or identity verification providers — whose infrastructure is located outside the Philippines.

Where such cross-border transfers occur, hph77 ensures that appropriate safeguards are in place to protect your personal data, including:

• Contractual data processing agreements that impose data protection obligations equivalent to those under the Philippine Data Privacy Act of 2012;
• Transfer only to jurisdictions recognized by the NPC as providing an adequate level of data protection, where applicable; and
• Transfer limited strictly to the minimum data necessary for the specific service being provided by the recipient.

hph77 does not transfer personal data to recipients located in jurisdictions that have not implemented adequate personal data protection frameworks without putting in place appropriate contractual safeguards first.

hph77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, NPC guidance, or PAGCOR regulatory requirements. The date of the most recent revision is displayed at the top of this page.

Where a material change is made to this Policy — meaning a change that significantly affects your rights or the way hph77 processes your personal data — hph77 will notify registered Players by email and by displaying a prominent notice on the Platform at least fourteen (14) days before the change takes effect. Your continued use of the Platform after the effective date of a material amendment constitutes your acceptance of the updated Policy.

Minor updates, such as corrections of typographical errors or clarifications that do not alter the substance of the Policy, may be made without prior notice. The current version of this Privacy Policy is always available at hph77.net/privacy-policy.

In compliance with the Data Privacy Act of 2012 and NPC Circular No. 16-01, hph77 has designated a Data Protection Officer (DPO) responsible for overseeing the implementation of this Privacy Policy and handling data subject rights requests and privacy-related inquiries.

• Data Protection Officer: hph77 Privacy & Compliance Team
• Email: [email protected] — please include "Privacy / DPO Request" in your subject line
• Response Time: Acknowledgment within three (3) business days; substantive response within fifteen (15) business days
• Live Support: Our Filipino-English customer support agents are available 24/7 via live chat on the Platform and can direct privacy-related inquiries to the DPO

If you are not satisfied with hph77's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission:

• National Privacy Commission (NPC) — the independent Philippine government authority responsible for administering and enforcing the Data Privacy Act of 2012
• Website: privacy.gov.ph (plain text — not a link)