ll777d Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") describes how ll777d ("we," "us," or "our") collects, uses, stores, and discloses personal information about individuals ("you," "User," or "Player") who access or use the ll777d online gaming platform available at ll777d.app and any related mobile applications, features, or services (collectively, the "Platform").

This Policy applies to all personal data processed by ll777d in connection with the Platform, regardless of whether you are a registered player, a visitor browsing the Platform, or a person who contacts our support team. By using the Platform, you acknowledge that you have read and understood this Policy.

This Policy should be read together with our Terms & Conditions and our Responsible Gaming Policy, both of which are incorporated herein by reference. In the event of any conflict between this Policy and the Terms & Conditions with respect to data privacy matters, this Policy shall prevail.

2 Data Controller

ll777d is the data controller responsible for the personal data collected through the Platform. As data controller, ll777d determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

If you have any questions about how ll777d handles your personal data, or if you wish to exercise any of your data subject rights, you may contact our Data Protection Officer at:

• Email: [email protected]
• Subject Line: Data Privacy Inquiry
• Response Time: Within fifteen (15) business days of receipt

3 Data We Collect

ll777d collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of data we collect include:

ll777d does not intentionally collect sensitive personal information beyond what is required for identity verification and regulatory compliance. We do not collect data about your racial or ethnic origin, political opinions, religious beliefs, or health information unless specifically required by law.

4 How We Use Your Data

ll777d uses the personal data we collect for the following purposes:

• Account Management: To create, verify, and maintain your ll777d player account, including identity verification (KYC) as required by applicable regulations.
• Service Delivery: To provide access to games, process deposits and withdrawals, credit bonuses, and deliver all features of the ll777d Platform.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, money laundering, unauthorized account access, and other illegal activities.
• Regulatory Compliance: To comply with our obligations under Philippine gaming regulations, anti-money laundering laws, and data privacy legislation, including reporting obligations to relevant authorities.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our 24/7 Filipino support team.
• Responsible Gaming: To monitor gaming patterns, enforce self-exclusion requests, apply deposit limits, and identify players who may be at risk of problem gambling.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the performance, features, and user experience of the ll777d Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided consent or where we have a legitimate interest to do so. You may opt out at any time.

5 Legal Basis for Processing

ll777d processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform our contract with you — i.e., to provide the ll777d gaming services you have registered for.
• Legal Obligation: Processing is required to comply with applicable laws, including anti-money laundering regulations, gaming licensing requirements, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for ll777d's legitimate interests, such as fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

6 Data Sharing & Disclosure

ll777d does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers require certain financial and identity data to process your deposits and withdrawals securely.
• Identity Verification Providers: Third-party KYC service providers assist us in verifying your identity and age as required by Philippine gaming regulations.
• Game Software Providers: Licensed game studios and platform providers may receive anonymized or pseudonymized gaming data necessary to deliver their games on the ll777d Platform.
• Regulatory Authorities: We may be required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other government bodies pursuant to applicable law or a valid legal order.
• IT & Security Service Providers: Cloud hosting, cybersecurity, and analytics vendors who process data on our behalf under strict data processing agreements that prohibit independent use of your data.
• Professional Advisors: Lawyers, auditors, and accountants who are bound by professional confidentiality obligations.

Any third party with whom ll777d shares personal data is required to handle that data in accordance with applicable privacy laws and ll777d's data protection standards.

7 Cookies & Tracking

ll777d uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how the Platform is used.

We use the following types of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication tokens and security cookies. They cannot be disabled without affecting Platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and game lobby filters to personalize your experience.
• Analytics Cookies: Help us understand how players navigate the Platform, which games are most popular, and where technical issues occur. Data collected is aggregated and anonymized.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of our campaigns. These are only set with your consent.

You may manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the ll777d Platform. Your consent to non-essential cookies is requested when you first visit the Platform and can be updated at any time through your account settings.

8 Data Retention

ll777d retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account Data: Retained for the duration of your active account plus five (5) years after account closure, in compliance with anti-money laundering record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• KYC Documents: Retained for five (5) years after the end of the business relationship, or longer if required by a regulatory authority.
• Support Communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for dispute resolution.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years to demonstrate compliance.

When personal data is no longer required, ll777d will securely delete or anonymize it in accordance with our data destruction procedures.

9 Data Security

ll777d implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encryption of sensitive data at rest, including financial records and identity documents.
• Multi-factor authentication requirements for account access and administrative systems.
• Regular penetration testing and vulnerability assessments conducted by independent security firms.
• Strict access controls ensuring that only authorized personnel can access personal data, on a need-to-know basis.
• 24/7 security monitoring and automated threat detection systems.
• Regular staff training on data protection and information security best practices.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ll777d will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, as required by the Data Privacy Act of 2012.

10 Your Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ll777d:

• Right to be Informed: The right to be informed about how your personal data is collected and processed — which this Policy fulfills.
• Right of Access: The right to request a copy of the personal data ll777d holds about you, along with information about how it is being used.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• 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 your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." We will respond within fifteen (15) business days. We may need to verify your identity before processing your request.

11 Children's Privacy

The ll777d Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. ll777d does not knowingly collect personal data from anyone under the age of 21.

If we become aware that we have inadvertently collected personal data from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the ll777d Platform, please contact us immediately at [email protected].

Parents and guardians are encouraged to use parental control tools and to monitor their children's online activity to prevent underage access to gambling platforms.

12 Changes to This Policy

ll777d reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or Platform features. When material changes are made, we will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically to stay informed about how ll777d protects your personal data. Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the changes.

13 Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or ll777d's data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: Privacy Policy Inquiry
• Support Hours: 24 hours a day, 7 days a week
• Response Time: Within fifteen (15) business days

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.

For responsible gaming concerns, please also visit our Responsible Gaming page, where you can find tools to manage your gaming activity and links to support resources.