gm77 Privacy Policy — How We Handle Your Personal Data

1 Introduction & Scope

1.1 Overview. This Privacy Policy ("Policy") describes how gm77 ("gm77," "we," "us," or "our") collects, processes, stores, shares, and protects the personal information of individuals ("you," "your," or "Player") who register for or use the gm77 online gaming platform accessible at gm77.lat and its associated services.

1.2 Legal Framework. This Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations (IRR), as administered by the National Privacy Commission (NPC) of the Philippines. By using gm77, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

1.3 Scope. This Policy applies to all personal data collected in connection with your use of the gm77 platform, including data collected during account registration, identity verification, payment processing, gameplay, customer support interactions, and your use of gm77's website and any associated mobile-optimized interfaces.

2 Data Controller

2.1 Identity. The data controller responsible for the personal information of gm77 players is the gm77 platform operator. For all data privacy-related matters, you may contact gm77 through the 24/7 live chat support feature available on the platform, or by email at the official contact address published on the platform.

2.2 Data Protection Officer. gm77 has designated a Data Protection Officer (DPO) in accordance with the Philippine Data Privacy Act. The DPO oversees compliance with this Policy and applicable data privacy regulations. Inquiries specifically addressed to the DPO may be submitted via the platform's official contact channels, clearly marked for the attention of the Data Protection Officer.

3 Data We Collect

3.1 Information You Provide Directly. gm77 collects personal information that you actively provide during:

• Account Registration: Full legal name, date of birth, nationality, Philippine residential address, mobile number, and email address.
• Identity Verification (KYC): Copies of government-issued Philippine identification documents (Passport, Driver's License, SSS ID, PhilHealth ID, Voter's ID, Postal ID, or UMID) and any selfie or liveness verification images submitted for KYC compliance.
• Payment Transactions: GCash wallet number, PayMaya account details, BPI/BDO/Metrobank account numbers (last digits only), USDT wallet addresses, and transaction records associated with deposits and withdrawals on gm77.
• Customer Support: Records of all communications with gm77 support staff, including live chat transcripts, submitted complaint details, and any documentation provided in connection with disputes.
• Promotional Participation: Information submitted when entering promotions or claiming bonuses, including survey responses where applicable.

3.2 Information Collected Automatically. When you access gm77, certain technical data is collected automatically:

4 Purpose & Legal Basis for Processing

4.1 Contract Performance. The majority of gm77's data processing is necessary for the performance of the contract between gm77 and the Player — specifically, to operate your account, process deposits and GCash withdrawals, provide access to games, calculate wagering requirements and bonuses, and deliver customer support.

4.2 Legal Obligation. gm77 is subject to Philippine Anti-Money Laundering Act (AMLA) obligations, PAGCOR-aligned regulatory requirements, and tax reporting obligations. Processing your identity, transaction, and gameplay data is required to comply with these mandatory legal obligations. This data may be retained and disclosed to relevant Philippine regulatory authorities as required by law.

4.3 Legitimate Interests. gm77 processes certain data on the basis of legitimate interests, including fraud detection and prevention, platform security, responsible gaming monitoring, and aggregate platform analytics. Where legitimate interests are relied upon, gm77 has assessed that its interests do not override your fundamental privacy rights.

4.4 Consent. Where gm77 sends you direct marketing communications — such as promotional emails, SMS notifications about bonuses, or personalized game recommendations — this is done on the basis of your consent at registration or at a subsequent opt-in point. You may withdraw consent to marketing communications at any time by contacting gm77 support.

5 Data Sharing

5.1 No Sale of Personal Data. gm77 does not sell, rent, or trade your personal information to any third party for commercial purposes. Full stop.

5.2 Service Providers. gm77 shares limited personal data with carefully selected third-party service providers who assist in operating the platform, under contractual obligations requiring them to process data only for specified purposes and in compliance with Philippine data privacy law. These include:

• Payment processors: GCash (GXI), PayMaya (Maya Philippines), BancNet/InstaPay network participants, and USDT payment infrastructure providers — for the purpose of processing player transactions.
• KYC and identity verification providers: Engaged to assist in verifying player identity in compliance with AMLA and regulatory requirements.
• Game software providers: Certain game providers receive limited player session data (e.g., a session token, bet amounts) as technically necessary to deliver real-time game functionality. These providers are contractually prohibited from using this data for independent purposes.
• Cloud infrastructure and security providers: Data hosting, content delivery, and cybersecurity service providers operating under strict data processing agreements.

5.3 Regulatory Disclosure. gm77 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine government authorities where required to do so by applicable law, court order, or regulatory directive. gm77 will notify affected players of such disclosures to the extent permitted by applicable law.

5.4 Business Transfers. In the event of a merger, acquisition, or transfer of all or a substantial portion of gm77's business or assets, your personal data may form part of the transferred assets. In such circumstances, gm77 will take reasonable steps to ensure that your data continues to be handled in a manner consistent with this Policy and applicable Philippine law.

6 Data Retention

6.1 Active Accounts. gm77 retains your personal data for as long as your account remains active and for a period thereafter as required to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce agreements.

6.2 Post-Closure Retention. Following account closure, gm77 retains certain categories of personal data for the minimum periods required under applicable Philippine law:

• Transaction and financial records: Minimum of 5 years following the date of the last transaction, in compliance with AMLA record-keeping requirements.
• KYC and identity verification records: Minimum of 5 years following account closure or the last transaction, whichever is later.
• Customer support and complaint records: Minimum of 3 years following resolution of the relevant matter.
• General account data: Up to 3 years following account closure unless a longer retention period is required by law.

6.3 Disposal. Upon expiry of applicable retention periods, gm77 will securely dispose of or anonymize personal data such that it can no longer be attributed to any identifiable individual.

7 Security Measures

7.1 Technical Safeguards. gm77 implements the following technical security measures to protect your personal data:

• 256-bit Transport Layer Security (TLS/SSL) encryption on all data transmissions between your device and gm77 servers.
• Encryption at rest for stored sensitive personal data, including KYC documents and financial account references.
• Firewall protection, intrusion detection systems, and DDoS mitigation applied to gm77's server infrastructure.
• Role-based access controls ensuring that only authorized personnel can access specific categories of player data, with all access logged and auditable.
• Two-factor authentication requirements for gm77 staff access to systems holding personal data.

7.2 Organizational Measures. gm77 supplements technical controls with organizational safeguards including privacy training for staff who handle player data, contractual data processing obligations imposed on all third-party service providers, periodic security reviews and penetration testing, and a documented incident response process compliant with NPC notification requirements.

7.3 Data Breach Response. In the event of a personal data breach that poses a real risk to the rights and freedoms of affected players, gm77 will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players within a reasonable time, in accordance with the requirements of the Philippine Data Privacy Act and its IRR.

8 Cookies & Tracking Technologies

8.1 What Cookies Are. Cookies are small text files placed on your device by a website when you visit it. gm77 uses cookies and similar technologies (including local storage and session tokens) to enable core platform functionality, improve your experience, and analyze platform usage.

8.2 Types of Cookies Used.

• Strictly Necessary Cookies: Required for the gm77 platform to function. They maintain your login session, handle secure payment flows, and enable real-time game connectivity. These cookies cannot be disabled without rendering the platform non-functional.
• Functional Cookies: Remember your preferences such as preferred language, game lobby layout, and notification settings. Disabling these may affect your personalized experience.
• Performance and Analytics Cookies: Used to measure how players navigate the gm77 platform, which pages are most visited, and where technical errors occur. Data is processed in aggregate and used to improve platform performance.
• Marketing Cookies (Consent-Based): Used where you have consented to receive personalized promotional content related to gm77 offers and game launches. You may withdraw this consent at any time.

8.3 Managing Cookies. You may manage cookie settings through your browser's privacy or settings menu. Blocking strictly necessary cookies will prevent you from using the gm77 platform. For all other cookie types, gm77 respects your choices. Note that cookie preferences are stored per browser and per device.

9 Your Privacy Rights

Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by gm77:

• Right to Be Informed: You have the right to be informed of how your personal data is collected, processed, and used — which this Policy fulfills. gm77 will also notify you of material changes to data processing practices.
• Right of Access: You may request a copy of the personal data gm77 holds about you, including transaction history, KYC records, and account data. Requests are processed within a reasonable timeframe, typically within 15 business days of receipt.
• Right to Correction: You may request that inaccurate, incomplete, or outdated personal data be corrected. Some corrections (e.g., changes to your registered mobile number) will require re-verification for security reasons.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to gm77's assessment of overriding grounds.
• Right to Erasure: You may request deletion of your personal data where: (a) it is no longer necessary for the purposes for which it was collected; (b) you withdraw consent and there is no other legal basis for processing; or (c) the processing was unlawful. This right is subject to gm77's legal obligations to retain data under AMLA and other applicable Philippine law.
• Right to Data Portability: You may request a copy of the personal data you provided to gm77 in a structured, commonly used, machine-readable format, where technically feasible and where the legal basis for processing is consent or contract.
• Right to File a Complaint: You have the right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that gm77 has violated your data privacy rights under RA 10173.

To exercise any of these rights, contact gm77's Data Protection Officer through the platform's 24/7 live chat support or the official contact email, stating your account details and the specific right you wish to exercise. gm77 will verify your identity before processing the request.

10 Minors & Age Restriction

10.1 Age Requirement. gm77 is strictly an adults-only platform. Only individuals aged 21 years and older may register for or use any gm77 service. This requirement is enforced at registration and may be re-verified at any time via KYC documentation. gm77 does not knowingly collect or process the personal data of individuals under 21 years of age.

10.2 Discovery of Underage Account. If gm77 discovers or is notified that personal data has been collected from an individual under 21 years of age, gm77 will immediately suspend the relevant account, delete the personal data of the underage individual to the extent not required for legal reporting purposes, and report the matter as required by applicable Philippine law.

10.3 Parental Notification. If you are the parent or guardian of a minor and believe your child has registered on gm77, please contact our support team immediately. gm77 will act promptly to address the matter, including account closure and data deletion where applicable.

11 Cross-Border Data Transfers

11.1 General Principle. gm77 processes the personal data of Filipino players primarily within the Philippines. However, certain technical service providers — including cloud infrastructure, game software, and security services — may process data in data centers located outside the Philippines.

11.2 Safeguards. Where personal data is transferred outside the Philippines, gm77 implements appropriate safeguards to ensure that such transfers comply with the Philippine Data Privacy Act, including contractual clauses requiring recipient organizations to maintain data protection standards equivalent to those required by Philippine law. gm77 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without appropriate contractual safeguards in place.

11.3 Player Consent. By registering for and using gm77, you consent to the transfer, storage, and processing of your personal data in the manner described in this section, subject at all times to the safeguards described herein.

12 Changes to This Policy

12.1 Right to Update. gm77 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, regulatory guidance, or platform features. The date of the most recent revision is stated at the top of this page.

12.2 Notification. Where changes to this Policy are material — meaning they significantly affect how your personal data is processed or your rights in respect of it — gm77 will provide advance notice through a prominent platform notification and/or an email to your registered address, with a reasonable period before the changes take effect.

12.3 Continued Use. Your continued use of gm77 after the effective date of any updated Privacy Policy constitutes your acknowledgment of and agreement to the updated terms. If you do not accept the updated Policy, you should cease using gm77 and request account closure.

13 Contact & Complaints

13.1 Contacting gm77 on Privacy Matters. For any questions, requests, or concerns about this Privacy Policy or the handling of your personal data by gm77, please contact us through:

• Live Chat: 24/7 live chat support accessible directly on the gm77 platform — the fastest route for most inquiries.
• Email: The official gm77 contact email published on the platform. Clearly mark your message "Data Privacy Inquiry" or "Attention: Data Protection Officer" as appropriate.

13.2 Response Timeframe. gm77 will acknowledge receipt of your privacy inquiry within 5 business days and will aim to provide a substantive response within 15 business days. Complex requests — particularly those involving data access or erasure — may require additional time, in which case gm77 will notify you of the extended timeframe.

13.3 National Privacy Commission. If you are unsatisfied with gm77's response to your privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent authority responsible for protecting individual privacy rights under RA 10173 and can be reached through the official NPC website at privacy.gov.ph.