fill77
Privacy Policy

This Privacy Policy ("Policy") is issued by fill77, the online casino and sports betting platform operating at fill77.app ("fill77," "we," "us," or "our"). fill77 is a PAGCOR-regulated gaming platform serving players throughout the Republic of the Philippines.

This Policy describes how fill77 collects, uses, stores, shares, and protects personal data relating to players, registered account holders, website visitors, and any other individuals who interact with the fill77 platform ("you," "your," or "Data Subject").

fill77 is deeply committed to protecting the privacy of its players. We recognize that Filipino players entrust us with sensitive financial and personal information when they register an account, make a GCash deposit, or complete KYC verification. That trust is not taken lightly. Every data practice described in this Policy reflects a deliberate decision about what is necessary to operate a safe, compliant, and high-quality gaming platform — nothing more.

This Policy should be read together with fill77's Terms and Conditions, which govern your overall use of the fill77 platform. By registering an account or using any fill77 service, you acknowledge that you have read and understood this Privacy Policy.

• "Personal Data" — any information that, alone or in combination with other information, identifies or could reasonably identify a natural person. This includes names, mobile numbers, email addresses, financial identifiers, and device identifiers.
• "Sensitive Personal Data" — a subset of Personal Data defined under RA 10173 that warrants heightened protection, including government-issued ID numbers (e.g., PhilSys number), financial account details, and biometric data submitted for KYC purposes.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, use, transfer, disclosure, and deletion.
• "Data Controller" — fill77, which determines the purposes and means of processing your Personal Data.
• "Data Processor" — a third-party entity that processes Personal Data on behalf of fill77 and under fill77's documented instructions (e.g., payment processors, hosting providers).
• "DPO" — fill77's designated Data Protection Officer, responsible for ensuring compliance with RA 10173 and serving as the primary contact for data subject rights requests.
• "NPC" — the National Privacy Commission of the Philippines, the government body responsible for administering and enforcing RA 10173.
• "PAGCOR" — the Philippine Amusement and Gaming Corporation, fill77's gaming regulator.
• "KYC" — Know Your Customer identity verification, as required before processing withdrawals and under PAGCOR and AMLA compliance obligations.

fill77 collects only the Personal Data that is necessary for the specific purposes described in this Policy. The categories of data we collect are as follows:

fill77 collects Personal Data through the following sources and methods:

4.1 Directly From You. The majority of the Personal Data fill77 holds is information you provide directly — during account registration, KYC submission, deposit transactions, customer support interactions, and when updating your Account settings. You are in control of what personal information you share with fill77 at these points.

4.2 Automatically During Platform Use. When you access fill77.app, certain Technical Data is collected automatically through server logs, cookies, and similar tracking technologies. This includes your IP address, device information, and session activity. See Section 11 for full details on cookies and tracking.

4.3 From Payment Processors. When you make a GCash or Maya deposit or withdrawal, fill77 receives a transaction confirmation and reference number from the relevant payment processor. fill77 does not receive or store your full GCash PIN or banking passwords — only the transaction reference sufficient to reconcile your Wallet.

4.4 From KYC Verification Partners. Where fill77 uses accredited third-party identity verification providers to assist with KYC processing, those providers may share verification results and document authenticity assessments with fill77. These providers are contractually bound to process your data solely for this purpose.

4.5 From PAGCOR and Regulatory Sources. fill77 may receive information from PAGCOR related to regulatory compliance matters, including player exclusion database cross-checks and compliance directives.

fill77 uses your Personal Data for the following specific, documented purposes:

• Account Creation and Management: To create your fill77 Account, verify your identity, maintain your Account settings, and provide you access to the platform's Services.
• Service Delivery: To process your bets and game rounds, credit winnings to your Wallet, manage live casino sessions, and provide all gaming services available on fill77 including sabong, slots, live baccarat, and sports betting.
• Payment Processing: To process GCash deposits and withdrawals, BPI/BDO bank transfers, and other payment channel transactions in accordance with your instructions.
• KYC and Identity Verification: To verify your age (21+ requirement), confirm your identity for PAGCOR compliance, and satisfy AMLA due diligence obligations before releasing withdrawal funds.
• Fraud Prevention and Security: To detect, investigate, and prevent unauthorized account access, payment fraud, bonus abuse, money laundering, and other prohibited activities.
• Customer Support: To respond to your support inquiries via live chat, email, Viber, or Messenger in Tagalog and English, and to resolve disputes or complaints.
• Responsible Gaming: To enforce deposit limits, cooling-off periods, self-exclusion requests, and to cross-check against PAGCOR's exclusion database.
• Legal and Regulatory Compliance: To comply with PAGCOR licensing requirements, the Philippine AMLA, RA 10173, and any other applicable Philippine laws and regulations.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates — only to Players who have opted in to receive such communications and only through their stated preferred channels.
• Platform Improvement: To analyze aggregated, anonymized usage patterns to improve fill77's game lobby, payment flows, and overall player experience.

Under Republic Act 10173, fill77 is required to identify a lawful basis for each category of Personal Data processing. fill77 relies on the following legal bases:

• Performance of Contract: Processing your Account Data, Financial Data, and Gaming Data is necessary to perform fill77's contractual obligations to you under the fill77 Terms and Conditions — specifically, to provide the gaming services you have registered to use.
• Legal Obligation: Processing your KYC Document Data, certain Financial Data, and transaction records is necessary to comply with fill77's legal obligations under the Philippine AMLA, PAGCOR licensing conditions, and RA 10173 itself.
• Legitimate Interests: Processing Technical Data for fraud detection, security monitoring, and platform integrity purposes is necessary for fill77's legitimate interest in operating a secure and fair gaming environment — an interest that does not override your fundamental privacy rights.
• Consent: Processing your data for direct marketing communications is based on your freely given, specific, and informed consent. You may withdraw this consent at any time through your Account settings or by contacting the DPO without affecting the lawfulness of any processing carried out before withdrawal.

7.1 General Principle. fill77 does not sell, rent, trade, or otherwise disclose your Personal Data to unaffiliated third parties for their own commercial purposes. Sharing of your data is limited to the specific categories of recipients and purposes described in this Section.

7.2 Payment Processors. fill77 shares limited transaction data with licensed Philippine payment processors — including GCash (Globe Fintech Innovations), Maya Philippines, BPI, BDO, UnionBank, and affiliated settlement networks — strictly to process your deposit and withdrawal transactions. These processors are independently regulated by the Bangko Sentral ng Pilipinas (BSP).

7.3 KYC and Identity Verification Providers. fill77 shares government ID images and biometric verification data with accredited KYC service providers for the purpose of identity verification. These providers operate under data processing agreements that restrict their use of your data to verification purposes only.

7.4 Game Content Providers. Game providers whose titles appear on fill77 (such as JILI, PG Soft, Pragmatic Play, and Spadegaming) may receive game session identifiers and anonymized betting data to support game integrity monitoring and RTP auditing. These providers do not receive your name, contact details, or financial information.

7.5 Regulatory and Law Enforcement Authorities. fill77 will disclose Personal Data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), the Bureau of Internal Revenue (BIR), or other competent Philippine government authorities when required to do so by law, court order, or regulatory direction. fill77 will, where legally permitted, notify you of any such disclosure.

7.6 Professional Advisers. fill77 may share data with its legal counsel, auditors, and compliance consultants where necessary for the conduct of their professional services — all of whom are bound by confidentiality obligations.

7.7 Corporate Restructuring. In the event of a merger, acquisition, or transfer of the fill77 business, Personal Data may be transferred to the relevant successor entity, subject to equivalent privacy protections. Players will be notified in advance of any such transfer that materially affects their data rights.

fill77's primary data infrastructure is hosted within the Philippines and in data centers operating under Philippine regulatory oversight. However, certain service providers — including game content providers and technology infrastructure partners — may process data in jurisdictions outside the Philippines.

Where Personal Data is transferred outside the Philippines, fill77 ensures that appropriate safeguards are in place in accordance with Section 21 of RA 10173 and the NPC's guidelines on cross-border data flows. These safeguards include contractual data protection clauses that impose obligations on the receiving party equivalent to those applicable under Philippine law.

fill77 does not transfer your Sensitive Personal Data — including KYC documentation and government ID information — outside the Philippines without your explicit consent or a documented legal obligation requiring the transfer.

fill77 retains Personal Data only for as long as necessary for the purpose for which it was collected, or as required by applicable Philippine law. The following retention standards apply:

• Active Account Data: Retained for the duration of your fill77 Account and for five (5) years following permanent account closure, consistent with PAGCOR licensing and AMLA retention requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years following the transaction date, as required under the Philippine AMLA and BSP regulations applicable to e-money transactions.
• KYC Documents: Retained for the period required by PAGCOR and the AMLC — generally five (5) years following the last transaction processed by the verified Account.
• Gaming Records: Individual game round and bet records are retained for a minimum of three (3) years to support dispute resolution and PAGCOR audit requirements.
• Customer Support Records: Live chat transcripts and email correspondence are retained for two (2) years from the date of the interaction.
• Marketing Consent Records: Records of consent and opt-out status are retained for three (3) years from the date of last interaction, to demonstrate compliance with RA 10173 consent requirements.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymized in accordance with NPC-recognized standards for data destruction.

fill77 implements a layered security architecture to protect Personal Data against unauthorized access, disclosure, alteration, and destruction. Key security measures include:

• Transmission Security: All data exchanged between your browser or device and fill77's servers is encrypted using 256-bit TLS. fill77 enforces HTTPS exclusively and does not permit unencrypted connections.
• Data at Rest Encryption: Sensitive Personal Data and KYC documents stored on fill77 infrastructure are encrypted at rest using AES-256 or equivalent standards.
• Access Controls: Access to Personal Data within fill77's operations is restricted to authorized personnel on a strict need-to-know basis. All internal access is logged and subject to periodic review.
• Authentication Controls: fill77 requires strong passwords for all player accounts and offers optional two-factor authentication (2FA) via SMS OTP or TOTP authenticator app. High-value transactions require additional verification.
• Monitoring and Intrusion Detection: fill77's infrastructure is monitored continuously for anomalous access patterns, unauthorized login attempts, and data exfiltration indicators.
• Vendor Security Assessment: Third-party data processors are subject to security assessments before onboarding and periodic reviews during the engagement.
• Staff Training: All fill77 personnel who handle Personal Data receive training on RA 10173 obligations and fill77's internal data handling policies.

fill77 uses cookies and similar tracking technologies to operate the platform, improve your experience, and fulfill security obligations. The following categories of cookies are used:

• Strictly Necessary Cookies: These cookies are essential for fill77 to function — they maintain your login session, remember your language preference, and protect the platform from cross-site request forgery attacks. These cannot be disabled without breaking core platform functionality.
• Performance and Analytics Cookies: These cookies collect anonymized data about how players navigate fill77 — which game categories are most visited, where drop-offs occur in the deposit flow, and how long sessions last on average. This data is used only to improve fill77's design and performance.
• Security Cookies: Fill77 sets security-specific cookies to support fraud detection and to verify that login sessions are initiated from the same device throughout. These are treated as strictly necessary.
• Marketing Cookies: Where you have consented to receive marketing communications, fill77 may set cookies to track which promotions you have already been shown, to avoid sending duplicate or irrelevant offers.

You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies may prevent certain fill77 features from functioning correctly. To opt out of non-essential cookies, you may update your preferences through the fill77 cookie preference panel, accessible from the platform footer.

Under Republic Act 10173 and its Implementing Rules, you have the following rights regarding your Personal Data held by fill77:

To exercise any of the above rights, submit a written request to fill77's DPO using the contact details in Section 15. fill77 will acknowledge your request within five (5) business days and respond substantively within fifteen (15) business days, consistent with NPC guidelines.

fill77 is strictly a platform for adults aged twenty-one (21) years and over in accordance with Philippine gaming law and PAGCOR regulations. fill77 does not knowingly collect, process, or store Personal Data belonging to individuals under the age of 21.

All player registrations require a declaration of age. Before processing any withdrawal, fill77 requires KYC identity verification that confirms the Account holder is at least 21 years of age. Where fill77 discovers or reasonably suspects that an Account has been registered by or is being accessed by a person under 21, fill77 will immediately suspend the Account, refuse any pending withdrawal, and delete any Personal Data associated with the Account unless retention is required for investigative or legal purposes.

If a parent or legal guardian becomes aware that a minor has submitted Personal Data to fill77 without authorization, they should contact fill77's DPO immediately using the contact details in Section 15. fill77 will act promptly to investigate and remediate.

14.1 Right to Update. fill77 may update this Privacy Policy from time to time to reflect changes in our data practices, changes in applicable Philippine law (including NPC circulars and PAGCOR directives), or changes in the fill77 platform's features.

14.2 Notification of Material Changes. Where fill77 makes material changes to this Policy — meaning changes that significantly affect how your Personal Data is processed or your rights as a Data Subject — fill77 will notify you by email to your registered address, by SMS to your registered Philippine mobile number, or by a prominent notice displayed on the fill77 platform, at least fourteen (14) calendar days before the change takes effect.

14.3 Versioning. Each version of this Policy is identified by a version number and effective date displayed at the top of the document. Prior versions are available on request from the DPO. The version in effect at the time of any data processing activity is the governing version for that activity.

14.4 Continued Use. Your continued use of fill77 following the effective date of an updated Policy constitutes acceptance of the revised terms. If you do not agree with the updated Policy, you should cease using fill77 and may request Account closure as described in the fill77 Terms and Conditions.

For all matters relating to this Privacy Policy, your Personal Data rights under RA 10173, or any privacy concern arising from your use of fill77, please contact fill77's designated Data Protection Officer through the following channels:

• Email (DPO): [email protected] — please use "Data Privacy Request" as the subject line. DPO email inquiries are acknowledged within five (5) business days.
• Live Chat: Available 24/7 via the fill77 platform. Agents in Tagalog and English can initiate a DPO escalation for urgent data privacy matters. Average response time is 3–5 minutes.
• Messenger & Viber: fill77's official support channels on these platforms can accept initial privacy inquiries and route them to the DPO team.

fill77 aims to resolve all data subject rights requests substantively within fifteen (15) business days of identity verification. Where a request requires additional time due to complexity or volume, fill77 will notify you of the extended timeline.

If you are not satisfied with fill77's response to your data privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines through the NPC's official complaint channels.