Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") explains how fill77 ("we," "us," "our," or "fill77") collects, uses, processes, stores, shares, and protects personal information obtained from users ("you," "your," or "Player") of our online gaming platform accessible at https://fill77.cam and associated services (collectively, the "Services").

fill77 operates under license from the Philippine Amusement and Gaming Corporation (PAGCOR) and complies with the Republic of the Philippines Data Privacy Act of 2012 (RA 10173) and its implementing rules and regulations. We are committed to maintaining the highest standards of data privacy and security to protect the personal information entrusted to us by our players.

By creating an account, accessing our Website, or using fill77 Services, you acknowledge that you have read, understood, and consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy. If you do not agree with any aspect of this Policy, you must not use fill77 Services and should close any existing account immediately.

2. Information We Collect

2.1 Personal Information Provided by You

When you register for a fill77 account, make deposits, request withdrawals, or contact customer support, we collect the following categories of personal information directly from you:

• Identity Information: Full legal name as it appears on government-issued identification documents, date of birth, gender, and nationality;
• Contact Information: Email address, mobile phone number, residential address, city, province, and postal code;
• Account Credentials: Username, password (stored in encrypted hash format), and security questions/answers;
• Financial Information: Bank account details, GCash or Maya mobile numbers, cryptocurrency wallet addresses, payment card information (processed through PCI DSS-compliant payment gateways), transaction history, deposit and withdrawal records, and betting activity;
• Verification Documents: Copies of government-issued identification documents (passport, driver's license, UMID card, PRC ID, SSS ID), proof of address documents (utility bills, bank statements), and selfie photographs for identity verification purposes;
• Communication Records: Correspondence with customer support via live chat, email, or phone, including the content of messages, timestamps, and support ticket histories.

2.2 Information Automatically Collected

When you access or use fill77 Services, we automatically collect certain technical information through cookies, web beacons, and similar tracking technologies:

• Device Information: Device type (mobile phone, tablet, desktop computer), operating system and version, browser type and version, screen resolution, device identifiers (IMEI, advertising ID), and mobile network information;
• Usage Data: IP address, geographic location (country, region, city), pages visited, time spent on pages, games played, bet amounts and frequencies, login times and durations, referral sources, and navigation paths through the Website;
• Session Data: Session identifiers, clickstream data, search queries entered on the Website, and preferences such as language settings and game favorites;
• Performance Data: Technical logs regarding system performance, error reports, page load times, and API response times for quality assurance purposes.

2.3 Information from Third Parties

fill77 may receive information about you from third-party sources including:

• Payment Processors: Transaction confirmation data, payment method verification information, and fraud risk assessments from GCash, Maya, bank partners, and cryptocurrency payment gateways;
• Identity Verification Services: Results of identity verification checks, document authenticity assessments, and sanctions/watchlist screening results from third-party KYC (Know Your Customer) verification providers;
• Marketing Partners: Referral information if you accessed fill77 through an affiliate link or promotional campaign;
• Social Media Platforms: Public profile information if you choose to link your social media accounts to your fill77 account (with your explicit consent).

3. How We Use Your Information

fill77 processes your personal information for the following legitimate purposes:

• Account Management: Creating and maintaining your fill77 account, authenticating your identity during login, processing changes to account settings, and providing customer support services;
• Service Provision: Enabling you to access and use our gaming platform, processing deposits and withdrawals, managing your account balance, recording gameplay activity, and calculating winnings and losses;
• Regulatory Compliance: Verifying your age (21+ requirement), confirming your identity and residential address for KYC purposes, detecting and preventing fraud and money laundering, maintaining gaming activity records as required by PAGCOR, and cooperating with law enforcement investigations when legally compelled;
• Payment Processing: Facilitating secure financial transactions, verifying payment methods, preventing chargebacks and payment fraud, and maintaining transaction records for accounting and auditing purposes;
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behaviors, implementing deposit limits and self-exclusion requests, providing access to responsible gaming tools, and referring players to professional help resources when appropriate;
• Marketing Communications: Sending promotional offers, bonus notifications, tournament announcements, and gaming tips via email, SMS, or push notifications (only with your prior consent, which can be withdrawn at any time);
• Platform Improvement: Analyzing usage patterns to enhance user experience, troubleshooting technical issues, developing new features and games, and conducting security assessments to protect against cyber threats;
• Legal Obligations: Responding to legal processes such as subpoenas and court orders, enforcing our Terms and Conditions, resolving disputes, and protecting the rights, property, and safety of fill77, our users, and the public.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act and applicable regulations, fill77 processes your personal information based on the following legal grounds:

• Consent: You have explicitly consented to the processing of your personal information for specific purposes such as marketing communications or optional features;
• Contract Performance: Processing is necessary to fulfill our contractual obligations to you as set forth in our Terms and Conditions, including account management, payment processing, and service delivery;
• Legal Compliance: Processing is required to comply with legal obligations imposed by Philippine law, PAGCOR regulations, anti-money laundering statutes, and other applicable legislation;
• Legitimate Interests: Processing is necessary for fill77's legitimate business interests, such as fraud prevention, security enhancement, platform improvement, and protection against legal liability, provided such interests do not override your fundamental rights and freedoms.

5. Data Sharing and Disclosure

fill77 does not sell, rent, or trade your personal information to third parties for their marketing purposes. We may share your information with the following categories of recipients under strict confidentiality obligations:

• Service Providers: Third-party vendors who provide essential services on our behalf, including payment processing companies (GCash, Maya, bank partners, cryptocurrency gateways), cloud hosting providers, customer support software vendors, email delivery services, identity verification platforms, and cybersecurity firms. These providers are contractually obligated to use your information only for specified purposes and to maintain appropriate security measures;
• Game Providers: Software developers who supply casino games, live dealer platforms, and sports betting technology integrated into fill77. These providers receive limited information necessary to facilitate gameplay, such as user IDs, bet amounts, and game outcomes;
• Regulatory Authorities: PAGCOR and other government agencies with jurisdiction over online gaming activities in the Philippines. We disclose information as required by licensing conditions, regulatory audits, and official inquiries;
• Law Enforcement: Police, prosecutors, courts, and other legal authorities when we are legally required to disclose information pursuant to subpoenas, court orders, search warrants, or other valid legal processes;
• Professional Advisors: Lawyers, accountants, auditors, and consultants who require access to certain information to provide professional services to fill77;
• Business Transfers: In the event of a merger, acquisition, corporate restructuring, or sale of assets, your personal information may be transferred to the acquiring entity, subject to the same privacy protections outlined in this Policy;
• Fraud Prevention Services: Third-party fraud detection and prevention platforms that help identify suspicious transactions, stolen payment methods, and identity theft attempts.

6. Data Security Measures

fill77 implements comprehensive technical, organizational, and administrative security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

• Encryption: All data transmitted between your device and fill77 servers is encrypted using 256-bit SSL/TLS encryption. Sensitive data at rest, including passwords and payment information, is encrypted using industry-standard algorithms;
• Access Controls: Access to personal information is restricted on a need-to-know basis. Employees and contractors with legitimate business reasons to access data must authenticate using strong passwords and multi-factor authentication;
• Network Security: Our infrastructure is protected by firewalls, intrusion detection systems, DDoS mitigation services, and regular vulnerability scanning. We conduct penetration testing to identify and remediate security weaknesses;
• Data Minimization: We collect and retain only the personal information necessary for identified purposes and securely delete or anonymize data when it is no longer required;
• Employee Training: All fill77 staff members receive regular training on data privacy principles, security best practices, and incident response procedures;
• Incident Response: We maintain an incident response plan to detect, contain, and remediate security breaches. In the event of a data breach affecting your personal information, we will notify you and relevant authorities as required by law.

Despite these measures, no internet-based system can be guaranteed absolutely secure. You acknowledge and accept the inherent risks of transmitting information over the internet and agree to hold fill77 harmless for security breaches beyond our reasonable control.

7. Data Retention

fill77 retains your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Active Accounts: Personal information associated with active accounts is retained for the duration of your relationship with fill77 plus applicable legal retention periods;
• Closed Accounts: After account closure, we retain identification documents, transacti I'm Claude Code, Anthropic's official CLI for Claude; the underlying model is Claude by Anthropic. I don't have a reliable way to see the exact model version, so I won't guess. What can I help you with? on records, financial documents, and gameplay history for 5 years after closure to comply with PAGCOR record-keeping requirements and potential audit or investigation needs;
• Marketing Data: If you opt out of marketing communications, we will retain a record of your opt-out preference indefinitely to ensure we do not contact you in the future;
• Legal Claims: Information related to legal disputes, regulatory investigations, or enforcement actions is retained until the matter is fully resolved and any applicable statute of limitations has expired.

After the applicable retention period expires, personal information is securely deleted or anonymized such that it can no longer be associated with you individually.

8. Your Rights Under Philippine Law

Under the Philippine Data Privacy Act, you have the following rights regarding your personal information:

• Right to be Informed: You have the right to be informed whether personal information pertaining to you is being processed, including the purposes of processing and your rights as a data subject;
• Right to Access: You have the right to reasonable access to your personal information held by fill77, including the right to obtain copies of your data in a structured, commonly used, and machine-readable format;
• Right to Rectification: You have the right to dispute inaccurate or incomplete personal information and to have fill77 correct such information without undue delay;
• Right to Erasure/Deletion: You have the right to request deletion of your personal information when it is no longer necessary for the purposes for which it was collected, subject to legal retention obligations;
• Right to Object: You have the right to object to processing of your personal information for direct marketing purposes or when processing is based on legitimate interests;
• Right to Data Portability: You have the right to obtain your personal information in a portable format and to transmit it to another service provider where technically feasible;
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing based on consent before withdrawal.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within 15 business days as required by law. Please note that certain requests may be subject to verification of your identity and may be limited by legal obligations or legitimate business needs.

9. Cookies and Tracking Technologies

fill77 uses cookies, web beacons, pixel tags, and similar tracking technologies to enhance user experience, analyze platform usage, and deliver personalized content. Cookies are small text files stored on your device that allow us to recognize your browser and remember certain information.

We use the following types of cookies:

• Essential Cookies: Necessary for the Website to function properly, including session management, authentication, security features, and load balancing. These cookies cannot be disabled without impairing core functionality;
• Functional Cookies: Enable enhanced features such as remembering your language preference, game favorites, and display settings;
• Analytics Cookies: Collect aggregated information about how visitors use our Website, including pages visited, time spent, and navigation patterns. This data helps us improve platform performance and user experience;
• Marketing Cookies: Track your browsing activity to deliver personalized advertisements and measure the effectiveness of marketing campaigns (only used with your consent).

You can control cookie settings through your browser preferences. Most browsers allow you to refuse cookies or delete existing cookies. However, disabling essential cookies may prevent you from using certain features of the fill77 platform.

10. International Data Transfers

fill77 primarily stores and processes personal information within the Philippines using local data centers and cloud infrastructure. However, some of our service providers and technology partners may be located in other countries, which may result in the transfer of your personal information outside the Philippines.

When we transfer personal information internationally, we ensure that appropriate safeguards are in place to protect your data in accordance with this Privacy Policy and Philippine data protection laws. These safeguards may include standard contractual clauses, adequacy determinations, or other legally recognized transfer mechanisms.

11. Children's Privacy

fill77 Services are strictly intended for individuals aged 21 years and older. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have inadvertently collected information from a minor, we will take immediate steps to delete such information and terminate the associated account.

If you believe that a minor has created an account or provided personal information to fill77, please contact us immediately at [email protected] so that we can take appropriate action.

12. Changes to This Privacy Policy

fill77 reserves the right to modify, update, or replace this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes to this Policy, we will notify you by updating the "Last Updated" date at the top of this page and may provide additional notice through email or prominent announcements on the Website.

Your continued use of fill77 Services following the posting of changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your personal information.

13. Contact Information

If you have questions, concerns, or complaints regarding this Privacy Policy or fill77's data processing practices, please contact us through the following channels:

• Data Protection Officer Email: [email protected]
• Customer Support Live Chat: Available 24/7 through the fill77 Website
• Customer Support Hours: 24 hours a day, 7 days a week

For complaints regarding potential violations of the Philippine Data Privacy Act, you may also file a complaint with the National Privacy Commission of the Philippines through their official website or contact channels.