pina77 Privacy Policy

Introduction

pina77 ("we", "us", "our", "pina77") respects the privacy of every individual who interacts with our Platform and is committed to protecting the personal data of our players, prospective players, and website visitors in the Philippines and wherever our services are accessed.

This Privacy Policy describes the categories of personal data we collect, the purposes for which that data is processed, the parties with whom it may be shared, the measures we take to keep it secure, and the rights available to you as a data subject under the Republic Act No. 10173 (Data Privacy Act of 2012) and applicable PAGCOR regulatory requirements.

This Policy should be read alongside the pina77 Terms & Conditions and Responsible Gaming Policy, which together govern your use of the Platform.

Data Controller

For the purposes of the Data Privacy Act of 2012 and its implementing rules and regulations, pina77 is the personal information controller in respect of the personal data collected through the Platform.

pina77 operates under the authority and licensing framework of the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to the data protection obligations applicable to PAGCOR-regulated operators in the Philippines.

If you have any questions or concerns about how pina77 handles your personal data, or if you wish to exercise your rights as a data subject, you may contact us at: [email protected]

Personal Data We Collect

pina77 collects personal data through your direct interactions with the Platform, through automated technical means, and from third-party verification services. The categories of data we collect are described in the table below:

pina77 does not knowingly collect sensitive personal information beyond what is strictly necessary for identity verification and regulatory compliance. Where the collection of such information is required (for example, government-issued ID for KYC purposes), it is handled with the highest level of care and stored securely.

How We Use Your Personal Data

pina77 processes your personal data only for the following defined purposes:

• Account Registration and Management: To create, verify, maintain, and administer your pina77 player account, including age verification to confirm you are 21 years of age or older as required by PAGCOR.
• Provision of Gaming Services: To enable you to access and participate in casino games, sports betting markets, bingo, and all other services available on the pina77 Platform.
• Payment Processing: To process your deposits via GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard, and to facilitate your withdrawal requests in Philippine Peso (PHP).
• KYC and Fraud Prevention: To verify your identity, comply with anti-money laundering (AML) obligations under Republic Act No. 9160 and its amendments, and detect and prevent fraudulent, abusive, or otherwise unlawful activity on the Platform.
• Regulatory Compliance: To fulfil pina77's obligations to PAGCOR and other applicable Philippine regulatory authorities, including the submission of required reports and the retention of records for mandated periods.
• Responsible Gaming: To monitor gaming activity patterns for signs of problem gambling and to administer responsible gaming tools such as deposit limits and self-exclusion requests.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform Improvement: To analyse aggregated usage data and improve the functionality, performance, and content of the pina77 Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates where you have provided your consent to receive such communications. You may withdraw this consent at any time through your account settings or by contacting support.

Legal Basis for Processing

pina77 processes your personal data on the following legal bases as recognised under the Data Privacy Act of 2012 and its implementing rules:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and pina77 (i.e., the Terms & Conditions), including providing gaming services, processing payments, and managing your account.
• Legal Obligation: Processing is required for pina77 to comply with applicable Philippine laws and PAGCOR regulations, including KYC requirements, AML obligations, and responsible gaming mandates.
• Legitimate Interests: Processing is necessary for pina77's legitimate interests in operating a secure, fair, and commercially viable gaming platform, including fraud prevention, platform security, and business analytics, provided these interests are not overridden by your rights and interests.
• Consent: Where pina77 relies on your consent as the legal basis for processing (for example, for direct marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before the withdrawal.

Cookies & Tracking Technologies

pina77 uses cookies and similar tracking technologies on the Platform to enhance your user experience, maintain your session, and gather analytics data. Cookies are small text files stored on your device when you visit the Platform.

The types of cookies used by pina77 include:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as account login session management, security token validation, and navigation. These cookies cannot be disabled without impairing Platform functionality.
• Analytical Cookies: These cookies help pina77 understand how players interact with the Platform, including which pages are visited most frequently and where users encounter errors. This data is used in aggregate and anonymised form to improve Platform performance.
• Functional Cookies: These cookies remember your preferences, such as your preferred language or display settings, to provide a more personalised experience on the Platform.
• Marketing Cookies: Where you have provided consent, these cookies track your activity to enable pina77 to deliver relevant promotional content. You may withdraw consent for marketing cookies at any time through your browser settings or account preferences.

You may configure your browser to refuse or delete cookies at any time. Please note that disabling strictly necessary cookies may affect the functionality of the Platform and prevent you from accessing certain features.

Sharing Your Personal Data

pina77 does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment Service Providers: GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard, and other payment processors, for the purpose of facilitating deposits and withdrawals in PHP. These providers act as independent data controllers in respect of the payment transaction data they process.
• KYC and Identity Verification Providers: Third-party identity verification services engaged by pina77 to perform age verification and document authentication as required by PAGCOR.
• Technology and Platform Service Providers: Software vendors, game content providers, cloud hosting services, and IT support providers engaged by pina77 to operate and maintain the Platform. All such providers are bound by data processing agreements requiring them to process personal data only on pina77's instructions.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by applicable law, court order, or regulatory directive.
• Professional Advisers: Lawyers, accountants, and auditors engaged by pina77, subject to professional confidentiality obligations.

International Data Transfers

pina77 is a Philippine-focused platform and processes the majority of personal data within the Philippines. Where the use of certain technology service providers requires personal data to be transferred to servers or personnel outside the Philippines, pina77 ensures that such transfers are carried out in accordance with the requirements of the Data Privacy Act of 2012 and the implementing rules of the National Privacy Commission.

Safeguards applied to international transfers may include contractual clauses requiring the receiving party to maintain data protection standards equivalent to those required under Philippine law, or other mechanisms approved by the NPC from time to time.

If you require further information about the specific safeguards applied to any international transfer of your personal data, please contact us at [email protected].

Data Retention

pina77 retains personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required or permitted by applicable Philippine law and PAGCOR regulations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your active relationship with pina77, plus a period of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and anti-money laundering regulations.
• Financial Transaction Records: Retained for a minimum of five (5) years following the date of each transaction, as required under Republic Act No. 9160 (Anti-Money Laundering Act) and its amendments.
• KYC and Identity Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant verification process.
• Support and Communications Records: Retained for up to three (3) years following the resolution of the relevant inquiry or dispute.
• Technical and Log Data: Retained for up to twelve (12) months from the date of collection, unless a longer retention period is required for security or fraud investigation purposes.
• Marketing Consent Records: Retained until consent is withdrawn and for a period of three (3) years thereafter as evidence of the consent provided.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

Your Data Subject Rights

Under the Data Privacy Act of 2012 and its implementing rules, you have the following rights in respect of your personal data held by pina77:

• Right to be Informed: The right to be informed of how your personal data is being collected and processed, including the purposes and legal basis for processing. This Privacy Policy serves as the primary mechanism for fulfilling this right.
• Right of Access: The right to request a copy of the personal data pina77 holds about you and information about how it is processed.
• Right to Rectification: The right to request the correction of inaccurate or incomplete personal data held by pina77. You may update certain information directly through your account settings.
• Right to Erasure: The right to request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to pina77's legal and regulatory obligations to retain certain data.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes at any time, and to object to other forms of processing based on legitimate interests where your rights and interests override those of pina77.
• Right to Data Portability: The right to receive personal data you have provided to pina77 in a structured, commonly used, and machine-readable format, where technically feasible.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that pina77 has processed your personal data in breach of the Data Privacy Act of 2012.

To exercise any of the above rights, please submit a written request to [email protected]. pina77 will verify your identity before processing any data subject request and will respond within the timeframes required by the Data Privacy Act of 2012. Please note that certain rights are subject to limitations where pina77 is required by law to retain or process the relevant data.

Children and Minors

The pina77 Platform is strictly restricted to individuals who are 21 years of age or older, in accordance with PAGCOR's minimum age requirements for online gaming in the Philippines. pina77 does not knowingly collect personal data from individuals under the age of 21.

pina77 employs age verification procedures at registration to confirm that all players meet the minimum age requirement. Where pina77 discovers or has reason to believe that a registered account is held by an individual under the age of 21, the account will be immediately suspended, all deposits will be refunded (net of any bonuses claimed), and any winnings will be forfeited.

If you believe that a minor may have accessed the Platform using your account or another account, please contact pina77 support immediately at [email protected] so that appropriate action can be taken without delay.

Security Measures

pina77 implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using secure socket layer (SSL/TLS) protocols across all Platform communications.
• Encryption of sensitive data at rest, including financial data and government-issued identification documents.
• Role-based access controls ensuring that pina77 personnel can only access personal data that is necessary for their specific role and responsibilities.
• Regular security assessments and vulnerability testing of the Platform and its underlying infrastructure.
• Two-factor authentication (2FA) options available to players for additional account security.
• Monitoring systems designed to detect and respond to suspicious access attempts, unusual transaction patterns, and other potential security incidents in real time.
• Data breach response procedures, including notification obligations to the National Privacy Commission and affected data subjects as required by the Data Privacy Act of 2012 where a breach is likely to result in serious harm.

While pina77 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. Players are encouraged to use strong, unique passwords for their pina77 accounts and to enable two-factor authentication where available.

Third-Party Links

The pina77 Platform may contain links to third-party websites or services for informational purposes. pina77 does not control and is not responsible for the privacy practices or content of any third-party websites. This Privacy Policy applies solely to the pina77 Platform and the personal data collected by pina77.

pina77 encourages you to read the privacy policies of any third-party websites you visit, as their data practices may differ materially from those described in this Privacy Policy.

Changes to This Privacy Policy

pina77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. Material changes to this Privacy Policy will be communicated to registered players via the email address or mobile number associated with their pina77 account, or by prominent notice on the Platform, prior to the changes taking effect.

The "Last Updated" date displayed at the top of this page indicates when the most recent revision was made. Your continued use of the Platform after any amendment to this Privacy Policy constitutes your acknowledgement of the updated Policy. If you do not agree to the amended Policy, you should discontinue use of the Platform and request account closure.

The current version of this Privacy Policy is always available on the Platform at pina77.net/privacy-policy.

Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way pina77 processes your personal data, please contact our data protection team:

• Email: [email protected]
• Platform: pina77.net

pina77 aims to respond to all privacy-related inquiries within ten (10) business days. If you are not satisfied with pina77's response, or if you believe that pina77 has processed your personal data in breach of the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

For responsible gaming support and concerns, please also visit our Responsible Gaming page.