Privacy Policy — tl777

1 Introduction & Scope

This Privacy Policy ("Policy") governs the collection, use, storage, and disclosure of personal information by tl777 ("tl777," "we," "us," or "our") through the tl777.club website and all associated services, mobile interfaces, applications, and communication channels (collectively, the "Platform").

This Policy applies to all registered players, visitors, and any other natural persons whose personal data is processed by tl777 in connection with the operation of the Platform. By registering an account on tl777 or by continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal information as described herein.

This Policy is to be read in conjunction with the tl777 Terms & Conditions. In the event of any conflict between this Policy and the Terms & Conditions regarding the treatment of personal data, this Policy shall prevail.

2 Data Controller

tl777 is the data controller responsible for your personal information processed under this Policy. As data controller, tl777 determines the purposes and means of processing your personal data and is accountable for ensuring that processing is carried out in accordance with the Philippine Data Privacy Act of 2012 (R.A. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission of the Philippines.

If you have any questions, requests, or concerns regarding the processing of your personal data, please contact our designated Data Protection Officer (DPO) at [email protected]. All privacy-related communications will be acknowledged within three (3) business days.

3 Personal Data We Collect

tl777 collects personal data through multiple channels, including direct input by the user during registration, automated collection through platform usage, and from third-party verification services. The categories of personal data we collect are described in the table below.

Where you choose not to provide mandatory personal data (such as identity and contact information required for KYC), tl777 may be unable to process your registration, verify your identity, or process withdrawal requests.

4 How We Use Your Personal Data

tl777 uses your personal data strictly for the purposes set out below. We do not use your data for any purpose incompatible with the purpose for which it was originally collected without your explicit consent.

• Account creation and management: To register your account, verify your identity, and maintain your profile on the tl777 platform.
• Service delivery: To provide you with access to games, sports betting, bingo, live casino, and sabong services available on tl777.
• Payment processing: To process deposits via GCash, PayMaya, and Philippine banks, and to process withdrawal requests to your verified payment method.
• KYC and AML compliance: To verify your age (21+ requirement), identity, and the source of funds in accordance with Philippine KYC and anti-money laundering regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, bonus abuse, and other prohibited conduct.
• Customer support: To respond to your inquiries, process complaints, and provide assistance to our Filipino support team when resolving account or payment issues.
• Legal and regulatory compliance: To comply with applicable Philippine laws, PAGCOR regulatory requirements, and court or regulatory orders to disclose data.
• Responsible gaming: To monitor gaming patterns, administer self-exclusion and limit settings, and identify players who may require responsible gaming intervention.
• Platform improvement: To analyze aggregated usage data (never individually identifiable in this context) to improve platform performance, game selection, and user experience.
• Marketing communications: With your consent, to send you promotional offers, bonus notifications, and platform updates. You may opt out of marketing communications at any time via your account settings or by contacting support.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, tl777 processes your personal data on the following legal bases:

• Contractual necessity: Processing is necessary for the performance of the contract between you and tl777 (your account registration and the Terms & Conditions you agreed to at sign-up). This covers account management, game access, and payment processing.
• Legal obligation: Processing is required to comply with applicable Philippine laws, including KYC requirements, AML reporting obligations, and PAGCOR regulatory directives.
• Legitimate interests: Processing is in tl777's legitimate business interests, including fraud prevention, platform security, responsible gaming monitoring, and improving service quality — where these interests are not overridden by your privacy rights.
• Consent: For non-essential processing activities such as marketing communications and non-essential cookies, tl777 relies 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

tl777 does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients where necessary and subject to strict data processing agreements:

• Game providers: To the extent necessary to deliver licensed game content (e.g., PG Soft, JILI, Pragmatic Play, Evolution Gaming). Game providers receive only the minimum data required for session management and do not retain identifiable player data beyond the active session.
• Payment processors: GCash, PayMaya, BDO, BPI, Metrobank, and cryptocurrency network service providers — limited to transaction-specific data required to execute deposits and withdrawals.
• KYC and identity verification providers: Third-party identity verification services used to authenticate government IDs and confirm age eligibility. These providers are contractually bound to process data only for verification purposes.
• Regulatory and law enforcement authorities: tl777 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities where required to do so by law, court order, or legitimate regulatory directive.
• Professional advisors: Legal counsel, auditors, and compliance consultants engaged by tl777, under strict confidentiality obligations.

7 International Data Transfers

Some of tl777's game provider partners and technology service providers maintain servers and processing facilities outside of the Philippines. Where your personal data is transferred to a country that does not provide an equivalent level of data protection to the Philippines, tl777 will implement appropriate safeguards, which may include:

• Standard contractual clauses approved by the National Privacy Commission;
• Binding corporate rules where the recipient is part of the same group of companies;
• The recipient's certification under a recognized cross-border data transfer framework.

You may request information about the specific safeguards in place for any particular international transfer by contacting our Data Protection Officer at [email protected].

8 Data Retention

tl777 retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or for as long as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with Philippine AML record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act.
• Customer support records: Retained for three (3) years from the date of the final communication.
• Technical and usage data: Server log data retained for up to twelve (12) months; anonymized aggregated usage analytics retained indefinitely.
• Marketing consent records: Retained for the duration of your account or until you withdraw consent, plus one (1) year as evidence of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with tl777's data disposal procedures.

9 Cookies & Tracking Technologies

tl777 uses cookies and similar tracking technologies on the Platform to support core functionality, maintain session security, and improve user experience. The categories of cookies used by tl777 are as follows:

• Strictly necessary cookies: Required for the Platform to function. These include authentication tokens, session identifiers, and security cookies. These cannot be disabled without breaking Platform functionality.
• Functional cookies: Store your preferences such as language settings, preferred payment method, and responsible gaming limit configuration so these do not need to be re-entered on each visit.
• Analytics cookies: Collect aggregated, anonymized information about how players use the Platform — which games are most popular, typical session lengths, and navigation patterns — to help tl777 improve the service. These are activated only with your consent.
• Marketing cookies: Used to deliver promotional content relevant to your interests and to measure the effectiveness of tl777's marketing campaigns. These are activated only with your explicit consent.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to log in and use tl777 services.

10 Your Data Subject Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by tl777. To exercise any of these rights, contact our Data Protection Officer at [email protected]. We will respond within fifteen (15) business days.

• Right to be informed: You have the right to be informed of the existence of processing, the purposes, the recipients, and your rights — as provided by this Policy.
• Right to access: You may request a copy of the personal data tl777 holds about you, together with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data held by tl777. You may update most account information directly in your tl777 account settings.
• Right to erasure ("right to be forgotten"): You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to tl777's legal obligations to retain certain records (e.g., AML and tax records).
• Right to object: You may object to the processing of your personal data for direct marketing purposes. You may also object to processing based on legitimate interests where you have grounds specific to your personal situation.
• Right to data portability: You may request a copy of your personal data in a structured, commonly used, machine-readable format, and have that data transmitted directly to another controller where technically feasible.
• Right to lodge a complaint: If you believe tl777 has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Details of how to file a complaint are available on the NPC's official website.

11 Children's Privacy — 21+ Only

tl777 is strictly an adults-only platform. Registration and use of the tl777 Platform is prohibited for any person under the age of twenty-one (21) years, as required by PAGCOR regulations governing online gambling in the Philippines.

tl777 does not knowingly collect or process personal data from individuals under 21 years of age. If tl777 becomes aware that personal data has been collected from an individual who does not meet the minimum age requirement, such data will be deleted immediately and the account will be closed without recourse.

If you are a parent or guardian and believe that a person under 21 has registered on tl777 using false information, please contact [email protected] immediately. We will investigate and take appropriate action within 24 hours of notification.

12 Data Security Measures

tl777 implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Encryption in transit: All data transmitted between your device and tl777 servers is encrypted using 256-bit TLS (Transport Layer Security) — the same standard used by BSP-licensed Philippine banks and GCash.
• Encryption at rest: Sensitive personal data, including identity documents and financial information, is encrypted at rest in tl777's database systems using AES-256 encryption.
• Access controls: Access to systems containing personal data is restricted to authorized tl777 personnel on a strictly need-to-know basis, protected by multi-factor authentication.
• Password security: Player passwords are stored using bcrypt hashing with per-account salts. tl777 staff cannot retrieve your password — only a reset is possible.
• Penetration testing: tl777's systems undergo regular independent security assessments and penetration tests by qualified cybersecurity professionals.
• Incident response: In the event of a data security incident that is likely to result in risk to your rights, tl777 will notify the National Privacy Commission within 72 hours and affected data subjects without undue delay, in accordance with the Data Privacy Act breach notification requirements.

13 Third-Party Links

The tl777 Platform may contain links to third-party websites operated by game providers or payment partners. This Policy applies only to the tl777 Platform and does not govern the data practices of any third-party websites. tl777 is not responsible for the privacy practices of third-party sites and recommends that you review their respective privacy policies before providing any personal information.

14 Changes to This Privacy Policy

tl777 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. Material changes to this Policy will be communicated to registered players via the email address on file at least 14 days before the change takes effect.

The "Last Updated" date at the top of this Policy reflects the most recent revision. Your continued use of the tl777 Platform after any revised Policy takes effect constitutes your acceptance of the updated terms. If you do not agree to the revised Policy, you must discontinue use of the Platform and contact support to arrange account closure.

15 Contact & Complaints

For any questions, data access requests, or privacy-related complaints, please contact the tl777 Data Protection Officer through the following channels:

• Email: [email protected] — mark the subject line "Privacy Request" or "DPO." Responses within 3 business days.
• Live Chat: Available 24/7 within the tl777 Platform. Filipino-speaking agents are on hand at all hours to assist with initial inquiries and to escalate privacy matters to the DPO.

If you are not satisfied with tl777's response to a privacy complaint, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC), the supervisory authority responsible for data protection in the Philippines. Information on filing a complaint with the NPC is available through official Philippine government channels.

tl777 serves Filipino players across Metro Manila, Cebu, Davao, Quezon City, Makati, and all regions of the Philippines — and takes its obligations to every one of those players under the Data Privacy Act seriously.