sx77 Privacy Policy – How We Handle Your Data

1Scope & Identity of the Data Controller

This Privacy Policy applies to all personal information collected through the sx77 Platform accessible at sx77.asia, including all games, payment services, account management features, customer support interactions, and promotional communications. It applies to all registered Users, visitors, and any individual whose personal information is processed by sx77 in connection with the Platform's operation in the Philippine market.

For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173), sx77 (referred to herein as "sx77," "we," "us," or "our") acts as the Personal Information Controller (PIC) in respect of personal data collected via sx77.asia. sx77 determines the purposes and means of processing personal information obtained through the Platform.

2Information We Collect

sx77 collects personal information that you provide directly, information generated through your use of the Platform, and in certain cases, information obtained from third-party identity verification services. The categories of personal information collected include:

Information You Provide Directly:

• Full legal name and date of birth
• Email address and mobile phone number
• Residential address (city, province, barangay)
• Government-issued identification documents submitted for KYC verification (e.g., Philippine passport, SSS ID, UMID, driver's license, PhilSys national ID)
• GCash or PayMaya account numbers and bank account details provided for deposit and withdrawal processing
• Any information provided voluntarily in support communications

Information Generated Through Platform Use:

• IP address, device type, operating system, and browser type
• Login timestamps, session duration, and geographic location data (country/city level)
• Game activity records including bets placed, game results, and wagering history
• Transaction records including deposit amounts, withdrawal requests, and bonus redemptions
• Communication records between the User and sx77 support

3Purpose & Legal Basis for Processing

sx77 processes personal information on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

4How We Use Your Information

sx77 uses the personal information we collect for the following specific operational purposes:

• To create, maintain, verify, and administer your sx77 account
• To process financial transactions including PHP deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank
• To verify your identity and age (21+ requirement) in compliance with applicable PAGCOR regulatory frameworks and Philippine AML law
• To detect, investigate, and prevent fraudulent activity, money laundering, account takeover, and other prohibited activities
• To enforce sx77's Terms & Conditions and Responsible Gaming policies, including self-exclusion orders
• To communicate with you regarding your account, transactions, and support requests
• To send promotional communications and bonus offers where you have provided consent via account settings
• To improve the performance, features, and content of the sx77 Platform based on aggregated usage analytics

sx77 does not sell, rent, or trade your personal information to third parties for their own marketing purposes.

5Disclosure of Personal Information

sx77 may disclose your personal information to the following categories of recipients, strictly on a need-to-know basis and for the purposes described in this Policy:

• Payment Service Providers: GCash (G-Xchange Inc.), PayMaya, BPI, BDO, Metrobank, and other financial institutions involved in processing your PHP deposits and withdrawals. These entities receive only the financial data necessary to execute the transaction.
• Identity Verification Services: Third-party KYC providers engaged by sx77 to verify identity documents submitted by Users. These providers act as Personal Information Processors (PIP) under data processing agreements with sx77.
• Regulatory and Law Enforcement Authorities: Philippine government agencies, including the AMLC (Anti-Money Laundering Council) and other competent authorities, where disclosure is required by law or by a lawful order.
• Game Content Providers: Licensed third-party game providers (e.g., live dealer studio operators) receive aggregated, pseudonymized session data necessary to deliver live game streams and RNG game results. These providers do not receive personally identifiable information beyond what is technically necessary for game delivery.
• IT Infrastructure & Security Providers: Hosting, cybersecurity, and CDN providers who process Platform data under contractual obligations consistent with the Data Privacy Act.

sx77 requires all Personal Information Processors engaged by the Platform to maintain confidentiality obligations and data protection standards consistent with RA 10173 and its Implementing Rules.

6Cookies & Tracking Technologies

sx77 uses cookies and similar tracking technologies to maintain session state, enable secure login persistence (where "Remember Me" is selected), and collect anonymized usage analytics to improve Platform performance. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for login session management, authentication tokens, and fraud prevention. These cannot be disabled without impairing Platform functionality.
• Performance & Analytics Cookies: Used to measure page load times, game loading performance, and navigation patterns in aggregate. No personally identifiable information is included in analytics data sets.
• Preference Cookies: Store your language and display preferences across sessions.

You may configure your browser to block or delete cookies. Note that disabling strictly necessary cookies will prevent login session persistence and may require you to log in to sx77 on every visit.

7Data Retention

sx77 retains personal information for the period necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods required by Philippine law:

• Account and KYC Records: Retained for a minimum of five (5) years following account closure, consistent with AMLC record-keeping requirements under the Anti-Money Laundering Act (RA 9160 as amended).
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction.
• Communication Records: Customer support communications retained for three (3) years from the date of the interaction.
• Marketing Preferences: Retained until you withdraw consent or close your account, whichever is earlier.

Upon expiration of the applicable retention period, personal information is securely deleted or anonymized so that it can no longer be attributed to an identified or identifiable individual.

8Data Security

sx77 implements technical and organizational security measures appropriate to the sensitivity of the personal information processed. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and sx77 servers
• One-way cryptographic hashing (bcrypt) for stored passwords — sx77 staff cannot access your plain-text password
• Role-based access controls ensuring that employee access to personal data is limited to the minimum necessary for their job function
• Multi-factor authentication on internal administrative systems
• Automated login anomaly detection that flags and alerts on suspicious access patterns, including logins from unrecognized devices or locations outside the Philippines
• Regular security assessments and vulnerability testing

Notwithstanding the measures above, no data transmission over the internet or electronic storage system is completely secure. In the event of a personal data breach that is likely to result in significant harm to Users, sx77 will notify affected individuals and the National Privacy Commission (NPC) within the timeframes required by RA 10173.

9Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, registered Users of sx77 who are Philippine nationals or residents have the following rights with respect to their personal information held by sx77:

• Right to be Informed: The right to know what personal information sx77 holds about you, the purpose for which it is processed, and to whom it has been disclosed.
• Right of Access: The right to request a copy of the personal information sx77 holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal information.
• Right to Erasure or Blocking: The right to request deletion or suspension of processing of your personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. You may withdraw marketing consent at any time via Account Settings.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, contact the sx77 Data Privacy Officer at the email address shown in the footer of this page. Requests will be processed within fifteen (15) business days of receipt.

10Policy on Minors

The sx77 Platform is strictly prohibited for use by individuals under 21 years of age. sx77 does not knowingly collect or process personal information of minors. If sx77 becomes aware that personal information of a person under 21 has been collected, such information will be deleted and the associated account will be permanently closed.

If you believe a minor has registered an account on sx77, please contact support immediately via the email address shown in the footer of this page.

11Cross-Border Data Transfers

Where personal information processed by sx77 is transferred to or stored in servers or processed by third-party service providers located outside the Republic of the Philippines, sx77 ensures that such transfers are conducted in compliance with Section 21 of RA 10173, including the requirement that the receiving jurisdiction provides an adequate level of protection for personal data, or that appropriate contractual safeguards (such as data processing agreements incorporating the NPC-approved standard contractual clauses) are in place prior to any such transfer.

12Changes to This Policy

sx77 reserves the right to update this Privacy Policy at any time to reflect changes in legal requirements, Platform features, or data processing practices. Material changes will be communicated to registered Users via email notification to the address on file. The "Last Updated" date at the top of this page will be revised with each update. Your continued use of the sx77 Platform following notification of a material change constitutes acceptance of the revised Privacy Policy.

We recommend reviewing this Privacy Policy periodically. For previous versions of this Policy, contact the sx77 Data Privacy Officer.

13Contact the Data Privacy Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal information by sx77, please contact the sx77 Data Privacy Officer. Contact details are displayed in the footer of this website. All data subject requests and privacy-related queries will be acknowledged within three (3) business days and responded to within fifteen (15) business days.

For concerns that cannot be resolved directly with sx77, you have the right to file a complaint with the National Privacy Commission of the Philippines at its official website or office in Manila.