em77 Privacy Policy

em77 ("em77," "we," "us," "our") respects the privacy of every Filipino player who uses the em77.biz platform. This Privacy Policy describes in detail how we collect, use, store, disclose, and protect your personal information when you register an account, access games, make deposits or withdrawals, or otherwise interact with any part of the em77 Platform.

This Policy applies to all em77 players whether you are based in Metro Manila, Cebu, Davao, Quezon City, Iloilo, or any other part of the Philippines. It applies to data collected through our website, live dealer platform, sports betting interface, customer support system, and any other digital service operated under the em77.biz domain.

em77 is committed to handling your personal data with transparency, fairness, and in strict accordance with Republic Act No. 10173, the Philippine Data Privacy Act of 2012, and its Implementing Rules and Regulations (IRR). We process your data only for legitimate, specified purposes and only to the extent necessary for those purposes.

For the purposes of the Philippine Data Privacy Act, em77 acts as the Personal Information Controller (PIC) with respect to the personal data of all registered players. As a PAGCOR-regulated operator, em77 is subject to both the National Privacy Commission's oversight under RA 10173 and PAGCOR's anti-money laundering (AML) and player data requirements.

em77's designated Data Protection Officer (DPO) is responsible for overseeing compliance with this Privacy Policy and applicable data privacy laws. Players may direct privacy-related inquiries or exercise their data subject rights by contacting the em77 DPO through the contact details specified in Section 14 of this Policy.

em77 collects and processes the following categories of personal data from players. The specific data collected at each stage is proportionate to the purpose for which it is required:

em77 does not collect or process sensitive personal information as defined under RA 10173 (such as race, ethnicity, health data, or political beliefs) unless legally required to do so for regulatory compliance purposes, in which case such processing is explicitly disclosed to the relevant player.

em77 uses the personal data we collect for the following specific, legitimate purposes:

• Account Creation and Management: To register your em77 account, verify your identity, authenticate your logins, and maintain your account profile and settings.
• Service Delivery: To provide you with access to em77's casino games, live dealer tables (WM Live, WL Live), Bingo, Slot, and sports betting services, and to process your bets and game results.
• Financial Transactions: To process deposits via GCash, Maya, and other approved Philippine payment methods, and to process withdrawal requests to your registered payment accounts in Philippine Peso.
• Identity and Age Verification (KYC): To verify that you are at least 21 years of age as required by PAGCOR, and to confirm your identity in compliance with Philippine Anti-Money Laundering Act (AMLA) obligations.
• Fraud Prevention and Security: To detect and prevent unauthorized account access, payment fraud, bonus abuse, money laundering, and other prohibited activity on the em77 Platform.
• Regulatory Compliance: To fulfill em77's reporting obligations to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies as required by law.
• Responsible Gaming: To monitor player gaming patterns for indicators of problem gambling, to enforce voluntary self-exclusion requests, and to administer deposit and session limits set by players in their account settings.
• Customer Support: To respond to player inquiries, process complaints, and provide technical assistance through em77's live chat and email support channels.
• Marketing Communications (Consent-Based): To send promotional offers, new game announcements, and bonus notifications to players who have expressly opted in to receive such communications. This is always optional and reversible.
• Platform Improvement: To analyze aggregated, anonymized usage data to improve the performance, security, and user experience of the em77 Platform.

Under the Philippine Data Privacy Act, em77 processes your personal data on the following legal grounds, which correspond to the lawful criteria for processing established under Section 12 of RA 10173:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and em77 — specifically, to provide the gaming services, process transactions, and maintain your account as agreed under em77's Terms and Conditions.
• Legal Obligation: Processing is required to comply with em77's legal obligations under PAGCOR regulations, the Anti-Money Laundering Act (RA 9160 as amended), the Data Privacy Act (RA 10173), and other applicable Philippine laws.
• Legitimate Interest: Processing is necessary for em77's legitimate interests in fraud prevention, platform security, responsible gaming enforcement, and platform improvement, provided such interests do not override your fundamental rights and freedoms.
• Consent: For marketing communications and any optional data processing not covered by the above bases, em77 relies on your freely given, specific, and informed consent, which you may withdraw at any time.

em77 does not sell or rent your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly for the purposes identified in Section 4, and subject to appropriate data protection agreements:

• Payment Service Providers: GCash (G-Xchange Inc.), Maya (Voyager Innovations Inc.), BPI, BDO, UnionBank, and other licensed Philippine payment partners — for the purpose of processing deposits and withdrawals.
• Game Technology Providers: JILI, WM Live, WL Live, Pragmatic Play, and other licensed game studios whose games are available on em77 — for the purpose of game delivery, RNG certification, and technical operations. Game providers receive only the minimum technical data required to deliver their services.
• KYC and Identity Verification Services: Third-party identity verification providers engaged to assist em77 in verifying player identities and age in compliance with PAGCOR and AMLA requirements.
• Philippine Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies — when disclosure is required by law, court order, or regulatory directive.
• Cloud and Infrastructure Service Providers: Hosting, database, and IT infrastructure providers engaged by em77 who process data on em77's behalf under strict data processing agreements consistent with RA 10173.
• Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by em77, who are bound by professional confidentiality obligations.

em77 uses cookies and similar tracking technologies to enhance your experience on the Platform, maintain your session state, and collect aggregate usage analytics. Cookies are small text files stored on your device when you visit em77.biz.

• Essential Cookies: Required for core platform functionality including user authentication, session management, and security validation. These cannot be disabled without impairing your ability to use em77.
• Functional Cookies: Used to remember your language preferences, display settings, and game lobby preferences across sessions. These improve your experience but are not strictly necessary.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players navigate and use the em77 Platform. This helps em77 improve page performance, game load times, and overall user experience.
• Security Cookies: Used to detect and prevent fraudulent login attempts, unauthorized access, and bot activity on the Platform.

You may manage cookie preferences through your browser settings. Note that disabling essential cookies will prevent you from logging in to your em77 account. em77 does not use third-party advertising cookies or behavioral tracking cookies for advertising network purposes.

em77 retains personal data for the minimum period necessary to fulfill the purposes for which it was collected, subject to the longer retention periods required by Philippine law and PAGCOR regulatory requirements.

• Active Account Data: Retained for the full duration of your active em77 account, plus an additional five (5) years after account closure — as required by AMLA and PAGCOR record-keeping obligations.
• Transaction Records: Financial transaction data (deposits, withdrawals, bet history) is retained for a minimum of five (5) years in compliance with AMLA requirements applicable to covered persons under Philippine law.
• KYC and Identity Documents: Retained for five (5) years after account closure or the completion of any related investigation, whichever is later.
• Support Communications: Live chat logs and email correspondence are retained for two (2) years from the date of the interaction, unless related to an active dispute or regulatory investigation.
• Technical Logs: Server logs, IP records, and session data are retained for ninety (90) days under normal circumstances, and up to two (2) years when flagged for security review.
• Marketing Consent Records: Consent records (opt-in and opt-out history) are retained for the duration of the account and for three (3) years thereafter as evidence of lawful marketing communication.

Upon expiration of the applicable retention period, em77 will securely delete or anonymize personal data in accordance with NPC-recommended data disposal standards.

em77 implements a comprehensive set of technical, administrative, and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction. These measures are designed to meet or exceed the security standards required by NPC Circular 16-03 and PAGCOR's data security requirements.

• Encryption in Transit: All data transmitted between your device and em77.biz is encrypted using Transport Layer Security (TLS 1.2/1.3) with 256-bit AES encryption.
• Encryption at Rest: Sensitive player data stored in em77's databases — including financial details and KYC documents — is encrypted at rest using AES-256 encryption.
• Password Security: Player passwords are never stored in plain text. em77 uses industry-standard cryptographic hashing algorithms (bcrypt or Argon2) to store password credentials securely.
• Two-Factor Authentication (2FA): em77 provides optional 2FA via SMS OTP for all player accounts, adding an additional verification layer beyond password authentication.
• Access Controls: Access to em77's player data systems is restricted to authorized personnel on a strict need-to-know basis, with role-based access controls and multi-factor authentication for administrative accounts.
• Security Monitoring: em77's platform is continuously monitored for intrusion attempts, unusual access patterns, and system anomalies using automated security tools and periodic third-party security audits.

In the event of a personal data security breach that is likely to result in risk to the rights and freedoms of affected players, em77 will notify the affected players and the NPC within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular 16-03.

Under the Philippine Data Privacy Act (RA 10173), you have the following rights with respect to your personal data held by em77. To exercise any of these rights, contact em77's Data Protection Officer as specified in Section 14. em77 will respond to all data subject requests within thirty (30) calendar days of receipt, as required by the Data Privacy Act.

Note that certain rights are subject to limitations where applicable law requires em77 to retain data — for example, AMLA and PAGCOR requirements override erasure requests for financial transaction records within the mandatory retention period.

em77's Platform is strictly prohibited to persons under the age of twenty-one (21) years, consistent with PAGCOR's minimum age requirement for casino and gambling participation in the Philippines. em77 does not knowingly collect personal data from individuals under the age of 21.

If em77 discovers or has reasonable grounds to suspect that a registered player is under the age of 21, em77 will: (a) immediately suspend the account; (b) freeze all associated funds pending age verification; (c) permanently close the account if age misrepresentation is confirmed; and (d) take appropriate steps to delete any personal data collected from the minor, except where retention is required to comply with legal obligations or to investigate the misrepresentation.

Parents or guardians who believe their minor child may have accessed the em77 Platform should contact em77 support immediately at the email address listed in Section 14 of this Policy.

Some of em77's game technology providers and cloud infrastructure partners may operate servers located outside the Philippines. In such cases, your personal data may be transferred to and processed in countries outside the Philippines. Where such transfers occur, em77 ensures that:

• The receiving jurisdiction provides adequate data protection standards, or appropriate safeguards are in place such as contractual clauses consistent with NPC requirements.
• Cross-border data processing agreements with recipients outside the Philippines comply with Section 21 of the Data Privacy Act and relevant NPC circulars governing cross-border transfers.
• Players are informed of the categories of data transferred and the jurisdictions involved, through this Privacy Policy and any supplementary notices provided at the point of consent.

The minimum data required for each cross-border transfer is shared — game providers, for instance, receive only the technical session data necessary to deliver and certify game results, and do not receive full player identity or financial records.

em77 reviews and updates this Privacy Policy periodically to reflect changes in our data practices, applicable Philippine law, NPC guidance, PAGCOR requirements, or the introduction of new platform features. The "Effective Date" at the top of this document indicates when the current version took effect.

For material changes to this Policy — changes that significantly affect how we collect or use your personal data, or that alter your rights as a data subject — em77 will provide advance notice via the Platform's notification system and/or by SMS to your registered Philippine mobile number at least seven (7) days before the changes take effect.

Your continued use of the em77 Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with a material change, you may request account closure and withdrawal of your remaining balance at any time by contacting em77 support.

For any questions, concerns, or formal data subject requests regarding this Privacy Policy or em77's data processing activities, please contact em77's Data Protection Officer (DPO) through the following details. Consistent with em77's platform communication policy, all contact information is presented as plain text — not as clickable links.

em77 commits to acknowledging all data subject requests within seventy-two (72) hours and providing a substantive response within thirty (30) calendar days of receiving a complete request, in accordance with RA 10173 and NPC regulations.

If you believe em77 has failed to address your data privacy concerns adequately, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the competent supervisory authority for data protection matters in the Philippines. Information on how to file a complaint with the NPC is available through the NPC's official channels.