q77 Privacy Policy

1. Overview & Scope

This Privacy Policy ("Policy") applies to all personal information collected, processed, and stored by q77 in connection with your use of q77.bio and all related services, features, and communications offered through the platform ("Services"). It covers information you provide directly, information generated by your use of the Services, and information q77 receives from third parties in the course of providing the Services.

By registering an account on q77.bio or otherwise using the Services, you acknowledge that you have read this Policy and consent to the processing of your personal information as described herein, to the extent consent is required as a legal basis under applicable law.

This Policy is to be read together with the q77 Terms & Conditions. In the event of a conflict between this Policy and the Terms & Conditions on matters of data privacy, this Policy shall prevail.

2. Data Controller

The data controller responsible for the personal information you provide through q77.bio is q77 ("q77," "we," "us," or "our"), the operator of q77.bio. As data controller, q77 determines the purposes and means of processing your personal data and is accountable for that processing in accordance with the Philippine Data Privacy Act of 2012 (RA 10173).

q77 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data privacy laws. You may contact the DPO through the email address specified in Section 14 of this Policy.

3. Personal Data We Collect

q77 collects the following categories of personal information:

q77 does not intentionally collect sensitive personal information as defined under RA 10173 (e.g., health data, religious beliefs, sexual orientation) unless it becomes necessary for a specific legal or compliance purpose, in which case explicit consent will be sought separately.

4. How We Collect Personal Data

4.1 Directly from You

The majority of personal data q77 holds is provided directly by you — at registration, during KYC verification, when you contact support, and when you configure your account settings.

4.2 Automatically Through Platform Use

When you access q77.bio, our servers automatically log technical data including your IP address, device identifiers, browser type, pages visited, session duration, and error logs. This data is collected via server logs, cookies, and similar tracking technologies described in Section 10.

4.3 From Third-Party Payment Providers

When you process a GCash, Maya, or bank transfer, the relevant payment provider confirms transaction status to q77. q77 receives confirmation data (transaction reference, amount, status) but does not receive your full GCash PIN, bank password, or equivalent authentication credentials.

4.4 From Identity Verification Services

To comply with KYC and Anti-Money Laundering Act (AMLA) requirements, q77 may use third-party identity verification services that process your ID document and compare it against government-issued identity databases.

5. Purposes of Processing

q77 processes your personal data for the following purposes:

• Account Creation & Management: To register your q77 account, verify your identity, and manage your account settings and preferences.
• Service Delivery: To provide access to games, process deposits and withdrawals, credit bonuses, and deliver all platform features to you.
• Legal & Regulatory Compliance: To fulfill obligations under Philippine gaming regulations, PAGCOR requirements, the Anti-Money Laundering Act (RA 9160 as amended), and the Data Privacy Act (RA 10173).
• Fraud Prevention & Security: To detect and prevent unauthorized account access, identify suspicious transaction patterns, and protect the integrity of the q77 platform.
• Responsible Gaming: To monitor for indicators of problem gambling behavior, enforce deposit and loss limits you have set, and facilitate self-exclusion requests.
• Customer Support: To respond to your inquiries, resolve disputes, and improve the quality of support interactions.
• Platform Improvement: To analyze aggregate usage patterns, identify technical issues, and improve the q77 platform. Analytical processing uses pseudonymized or aggregated data where possible.
• Marketing Communications: To send promotional offers and platform updates to your registered contact details, where you have consented to receive such communications and have not subsequently withdrawn that consent.

6. Legal Basis for Processing

Under the Philippine Data Privacy Act, q77 relies on the following legal bases for processing your personal information:

• Contractual Necessity: Processing required to perform the contract between q77 and you (i.e., the Terms & Conditions) — including account management, payment processing, and game delivery.
• Legal Obligation: Processing required for compliance with Philippine laws — including KYC under AMLA, age verification under gaming regulations, and tax reporting.
• Legitimate Interest: Processing for fraud detection, platform security, and responsible gaming monitoring, where q77's interests do not override your fundamental rights.
• Consent: Processing for marketing communications and certain cookie use, where your consent is obtained at the point of collection and may be withdrawn at any time.

7. Data Sharing & Disclosure

q77 does not sell your personal data to third parties. q77 may share your personal information with:

• Payment Processors: GCash (GXI), Maya (Voyager Innovations), BPI, BDO, Metrobank, and other payment service providers — solely to process your deposit and withdrawal transactions.
• Identity Verification Providers: Third-party KYC and AMLA compliance service providers engaged to verify the authenticity of identity documents you submit.
• Game Content Providers: Licensed game studios that operate live casino streams or supply game software to q77. These providers may process session-level data to deliver game functionality.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, and courts — where q77 is required or permitted by law to disclose.
• Professional Advisors: Legal counsel, auditors, and accountants under professional confidentiality obligations, where necessary for q77's legal and compliance functions.

All third-party service providers who receive personal data from q77 are contractually bound to process that data only for the specified purpose, to maintain appropriate security standards, and to comply with RA 10173.

8. Data Retention

q77 retains personal data for as long as is necessary to fulfill the purpose for which it was collected, subject to the following minimum retention periods:

• Account Data & Transaction Records: Minimum 5 years from account closure, as required under the Anti-Money Laundering Act.
• KYC Documents: Minimum 5 years from the date of collection or account closure, whichever is later.
• Technical Logs: Up to 12 months from collection, unless retention is required for an ongoing security investigation.
• Support Communications: Up to 3 years from the date of the communication, for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Retained for the period of active marketing and for 1 year after consent is withdrawn, for audit trail purposes.

When personal data is no longer required, q77 will securely delete or anonymize it in accordance with applicable law and internal data disposal standards.

9. Security Measures

q77 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and q77.bio.
• Encryption of sensitive data fields (including financial reference data) at rest using industry-standard encryption protocols.
• Role-based access controls ensuring that q77 staff access personal data only to the extent required for their job function.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Regular security assessments and penetration testing conducted by independent third-party security professionals.
• Incident response procedures that include notification to the National Privacy Commission and affected data subjects in the event of a personal data breach, consistent with NPC requirements.

While q77 implements these measures, no online platform can guarantee absolute security. You are responsible for maintaining the security of your q77 login credentials. Do not share your password with anyone, and use a unique password not used for other services such as GCash or your online banking apps.

10. Cookies & Tracking Technologies

q77.bio uses cookies and similar technologies to support platform functionality, maintain session state, and analyze usage patterns. The categories of cookies used are:

• Essential Cookies: Required for the platform to function — including login session cookies, security tokens, and load balancing cookies. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your preferences (e.g., game language, lobby filters, responsible gaming settings) to improve your experience.
• Analytical Cookies: Collect pseudonymized data about how players use q77.bio — pages visited, session duration, error events — to help q77 improve the platform.
• Marketing Cookies: Used to measure the effectiveness of q77's promotional campaigns. These are deployed only where you have provided consent through the cookie preference panel.

You may manage your cookie preferences through your browser settings. Note that disabling essential cookies will prevent you from logging in to q77. Disabling analytical or marketing cookies will not affect your ability to access games or process payments.

11. Your Privacy Rights Under Philippine Law

As a data subject under the Philippine Data Privacy Act (RA 10173), you have the following rights with respect to your personal data held by q77:

• Right to be Informed: The right to know that q77 is processing your personal data and to be provided with this Privacy Policy.
• Right to Access: The right to request a copy of the personal data q77 holds about you, including the purposes of processing and any third parties to whom it has been disclosed.
• Right to Correction: The right to request correction of inaccurate, incomplete, or outdated personal data in your q77 account.
• Right to Erasure (Right to be Forgotten): The right to request deletion of your personal data where processing is no longer necessary, subject to q77's legal retention obligations under AMLA and gaming regulations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used electronic format where technically feasible.
• Right to Object: The right to object to processing based on legitimate interest — particularly for direct marketing. You may unsubscribe from marketing communications at any time.
• Right to File a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, contact q77 at [email protected]. q77 will respond to verified requests within 30 days. Identity verification will be required before personal data is disclosed or modified.

12. Minors & Age Restriction

If you are a parent or guardian and you believe your minor child has provided personal data to q77, please contact [email protected] immediately with the relevant account details so that q77 can take appropriate action.

13. Updates to This Privacy Policy

q77 reviews this Privacy Policy periodically and may update it to reflect changes in applicable law, regulatory guidance from the National Privacy Commission, or material changes to how q77 processes personal data. When significant changes are made, q77 will post the updated Policy on q77.bio with a revised "Last Updated" date and, where practicable, notify registered players via email or in-platform notification.

Your continued use of q77.bio following the posting of an updated Privacy Policy constitutes your acknowledgment of the changes. If you do not agree to the updated Policy, you must discontinue use of q77.bio and may request account closure.

14. Contact & Complaints

For all privacy-related inquiries, access requests, corrections, or complaints, please contact the q77 Data Protection Officer:

• Email: [email protected]
• Subject Line: "Privacy Request — [Your Registered Mobile Number]"
• Response Time: Within 15 business days for privacy requests; within 72 hours for urgent matters involving suspected data breaches.

If you believe q77 has not addressed your privacy concern adequately, you have the right to escalate the matter to the National Privacy Commission of the Philippines (NPC). Information on how to file a complaint with the NPC is publicly available through official Philippine government channels.