Your privacy is important to us. This Privacy Policy explains how top 77 collects, uses, stores, shares, and protects your personal information when you use the top 77 platform at top77.asia. Please read this policy carefully before registering an account or submitting any personal data.
1.1 This Privacy Policy applies to all personal data processed by top 77 in connection with the operation of the top 77 online gaming platform accessible at top77.asia ("the Platform"). It covers all Members, registered users, and visitors to the Platform, wherever located.
1.2 This policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission of the Philippines.
1.3 By registering an account, depositing funds, or using any feature of the top 77 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.
1.4 This Privacy Policy should be read together with the top 77 Terms & Conditions, which are available at top77.asia/terms-conditions and which are incorporated herein by reference.
top 77 is the data controller for all personal data collected on the Platform. Questions about this policy may be directed to our Data Privacy Officer at [email protected].
2.1 Registration Data. When you create a top 77 account, we collect: full legal name, date of birth, residential address in the Philippines, email address, mobile phone number, and a username selected by you. This information is mandatory — accounts cannot be created without it.
2.2 Identity Verification (KYC) Data. To comply with applicable regulations and process withdrawals, top 77 collects copies of government-issued identity documents (such as PhilSys national ID, passport, LTO driver's licence, or UMID), selfie photographs for identity matching, and proof of address documents where required.
2.3 Financial Data. We collect information about deposits, withdrawals, and transaction history on your account. We receive confirmation data from GCash, PayMaya, BPI, BDO, and Metrobank regarding the processing of your transactions. We do not store full payment account credentials — these are held by the relevant payment service provider.
2.4 Gaming Activity Data. We collect records of all games played, bets placed, wagers settled, bonus funds claimed, and gaming session durations associated with your account. This data is required for the provision of the service and for regulatory compliance.
2.5 Technical Data. We automatically collect: IP address, device type and operating system, browser type and version, access times and dates, pages visited, session duration, and referring URL. This data is collected via cookies and server logs.
2.6 Communications Data. We retain records of all communications between you and top 77, including live chat transcripts, Messenger exchanges, Viber messages, and emails, for quality assurance, dispute resolution, and regulatory compliance purposes.
2.7 Responsible Gaming Data. Where you use top 77's responsible gaming tools (deposit limits, self-exclusion, cooling-off periods), we record and retain details of those elections to ensure effective enforcement.
3.1 Directly from You. The majority of your personal data is collected directly from you — during account registration, KYC submission, deposit and withdrawal requests, completion of responsible gaming questionnaires, and communications with our support team.
3.2 Automatically. Technical data is collected automatically when you access the top 77 Platform via cookies, web beacons, pixel tags, and server-side logging systems. See Section 7 for details on cookies.
3.3 From Payment Processors. When you make a deposit or withdrawal via GCash, PayMaya, or a bank transfer, we receive transaction confirmation data from the relevant payment service provider, including transaction reference numbers and amounts.
3.4 From Identity Verification Services. top 77 may use third-party identity verification service providers to assist with KYC processing. These providers compare the data you submit against databases and verify document authenticity.
3.5 From Fraud Prevention Services. top 77 uses third-party fraud detection and risk assessment services that may provide us with information about known fraudulent actors, device fingerprints, and risk scores associated with certain transactions or access patterns.
4.1 top 77 uses your personal data for the following purposes:
5.1 top 77 processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:
6.1 top 77 does not sell your personal data to third parties. We share your personal data only in the following circumstances:
6.2 All third-party service providers to whom top 77 discloses personal data are required by contract to maintain the confidentiality and security of that data and to process it only for the specific purposes for which it was disclosed.
7.1 top 77 uses cookies and similar tracking technologies on the Platform. Cookies are small text files placed on your device by your browser when you access the Platform. They enable the Platform to recognise your device, maintain your login session, and remember your preferences.
7.2 top 77 uses the following categories of cookies:
7.3 You may manage your cookie preferences through your browser settings. Note that disabling strictly necessary cookies will impair your ability to log in and use the Platform. For marketing cookies, you may withdraw consent at any time via your account settings.
8.1 top 77 retains your personal data for as long as your account remains active and for such additional periods as are required by applicable law or regulation. Specifically:
8.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.
9.1 top 77 implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:
9.2 In the event of a personal data breach that is likely to result in high risk to your rights and freedoms, top 77 will notify you and the National Privacy Commission as required by the Philippine Data Privacy Act of 2012 and NPC Circular No. 16-03.
9.3 While top 77 takes every reasonable precaution to protect your data, no internet transmission is completely secure. You acknowledge this inherent risk when using any online service.
10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by top 77:
10.2 To exercise any of the above rights, contact top 77's Data Privacy Officer via email at [email protected]. top 77 will respond to valid requests within thirty (30) days, which may be extended by a further thirty (30) days in complex cases with written notice to you.
11.1 The top 77 Platform is strictly for individuals who are 21 years of age or older. top 77 does not knowingly collect personal data from persons under 21. Where top 77 discovers or has reason to believe that a person under 21 has registered an account, that account will be immediately closed, all personal data associated with the account will be securely deleted (subject to any legal retention obligations), and any deposited funds will be returned to the funding source.
11.2 If you are a parent or guardian and believe that a minor in your care has created a top 77 account, please contact our support team immediately via live chat or email at [email protected].
12.1 Some of top 77's service providers and technology partners are located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to the Philippines, top 77 implements appropriate safeguards — including contractual data processing agreements based on applicable standard contractual clauses — to ensure that your data receives an adequate level of protection regardless of where it is processed.
12.2 By using the top 77 Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described in this section.
13.1 For any questions, concerns, or requests relating to this Privacy Policy or top 77's processing of your personal data, please contact top 77's Data Privacy Officer:
13.2 If you are not satisfied with top 77's response to a privacy complaint, you have the right to escalate your complaint to the National Privacy Commission of the Philippines at privacy.gov.ph.
14.1 top 77 may update this Privacy Policy from time to time to reflect changes in applicable law, regulatory requirements, or the way we operate the Platform. Material changes will be communicated to registered Members via email or a prominent notice on the Platform at least seven (7) days before they take effect.
14.2 The "Last Updated" date at the top of this page indicates when this Privacy Policy was most recently revised. Your continued use of the top 77 Platform following the effective date of any revised Privacy Policy constitutes your acceptance of the changes.
14.3 The current version of this Privacy Policy is always accessible at top77.asia/privacy-policy.
Six ways we safeguard your personal data on the top 77 platform
Every page of the top 77 platform — including the login page, deposit flow, and account settings — is served over HTTPS with SSL/TLS encryption. Your credentials and financial data are never transmitted in plain text.
top 77 does not sell, rent, or trade your personal information to third-party marketers or data brokers. Your data is used solely for the purposes described in this Privacy Policy — nothing more.
Access to Member personal data within top 77's internal systems is strictly controlled. Only team members with a legitimate operational need can access your data, and all access is logged and audited.
top 77 operates in full compliance with Republic Act No. 10173, the Philippine Data Privacy Act of 2012. We have a registered Data Privacy Officer and adhere to NPC guidelines for data processing and breach notification.
Your data is not kept indefinitely. top 77 applies defined retention schedules to all categories of personal data, after which data is securely deleted or anonymised. We keep only what the law requires us to keep.
Access, correction, deletion, portability — your data rights under the Data Privacy Act are fully honoured at top 77. Submit a request to our Data Privacy Officer and receive a response within 30 days, guaranteed.
Play with confidence knowing your personal data is protected by industry-grade security and Philippine law. Join 500,000+ Filipino members who trust top 77 with their gaming experience.
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