ll777du Privacy Policy – How We Handle Your Data

ll777du ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all users ("you," "your," or "Player") who access and use the ll777du online gaming platform at https://ll777du.app. This Privacy Policy sets out in clear and transparent terms how ll777du collects, uses, stores, shares, and protects your personal data in connection with your use of the Platform.

This Privacy Policy should be read alongside the ll777du Terms & Conditions and Responsible Gaming Policy, which together form the complete set of agreements governing your relationship with ll777du.

By creating an account, making a deposit, or using any service on the ll777du platform, you acknowledge that you have read this Privacy Policy and consent to the collection, processing, and use of your personal data as described herein. If you do not agree with any part of this Privacy Policy, you must not use the Platform.

ll777du is the data controller responsible for the personal data processed under this Privacy Policy. For purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, ll777du determines the purposes and means of processing personal data collected through the Platform.

ll777du has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data privacy laws. You may contact the DPO through the ll777du support channel using the contact information provided in Section 15 of this Policy.

ll777du collects the following categories of personal data in the course of providing its services to Filipino players:

3.1 Registration and Identity Data:

• Philippine mobile number (used as your account identifier and for SMS OTP verification)
• Full legal name (collected during KYC verification)
• Date of birth (to verify the 21+ age requirement mandated by PAGCOR)
• Government-issued Philippine photo identification (UMID, PhilSys National ID, driver's license, or passport) — image and extracted data
• Residential address in the Philippines

3.2 Financial and Transaction Data:

• GCash mobile number, PayMaya account details, or bank account information (BDO, BPI, Metrobank, or other supported Philippine banks)
• Deposit amounts, withdrawal requests, and transaction history in Philippine Peso (PHP)
• Bonus and promotional activity records

3.3 Gaming Activity Data:

• Game session history, bet records, wager amounts, and game outcomes across all ll777du game categories
• Responsible gaming tool usage (deposit limits set, self-exclusion periods, session time limits)

3.4 Technical and Device Data:

• IP address and approximate geolocation
• Device type, operating system, and browser type
• Session timestamps and duration
• Cookie identifiers and similar tracking technology data (see Section 10)

3.5 Communications Data:

• Records of your communications with ll777du support via live chat or email
• Feedback, complaint, and dispute records

ll777du collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or use responsible gaming tools.
• Automatically — through cookies, web analytics tools, and server logs when you access and navigate the ll777du Platform.
• From third-party payment processors — when you make a GCash, PayMaya, or bank transfer transaction, relevant transaction confirmation data is received from the payment processor.
• From identity verification services — ll777du may use third-party KYC verification services to validate government-issued Philippine ID documents submitted during account verification.
• From regulatory bodies — ll777du may receive data from PAGCOR or law enforcement authorities as required by applicable Philippine law.

ll777du processes your personal data for the following purposes:

• Account management: Creating, maintaining, and securing your ll777du account; processing your ll777du login authentication including 2FA OTP delivery.
• Identity and age verification: Confirming that you are a Philippine resident aged 21 or older, as required by PAGCOR regulations. No account withdrawal access is granted prior to successful KYC completion.
• Payment processing: Processing GCash deposits and withdrawals, bank transfers, and maintaining transaction records in PHP.
• Game provision: Operating the ll777du Casino game lobby, recording game outcomes, and maintaining bet history for dispute resolution and audit purposes.
• Regulatory compliance: Fulfilling obligations under the Philippine Data Privacy Act (RA 10173), PAGCOR licensing requirements, and the Anti-Money Laundering Act (RA 9160) and its amendments.
• Responsible gaming: Monitoring gaming activity to identify potential problem gambling indicators and enabling the use of responsible gaming tools including deposit limits and self-exclusion.
• Customer support: Responding to inquiries, resolving disputes, and improving service quality.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to players who have not opted out of marketing communications. You may opt out at any time via your account settings or by contacting support.
• Platform security and fraud prevention: Detecting and preventing fraudulent activity, account takeover attempts, money laundering, and other prohibited conduct described in the ll777du Terms & Conditions.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the ll777du platform, game selection, and player experience.

Under the Philippine Data Privacy Act of 2012, ll777du processes your personal data on the following legal bases:

• Consent: For marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
• Contractual necessity: For account creation, payment processing, game provision, and customer support — processing necessary to perform the contract between you and ll777du as set out in the Terms & Conditions.
• Legal obligation: For KYC identity verification, age verification, AML compliance reporting, and data sharing with PAGCOR or law enforcement as required by applicable Philippine law.
• Legitimate interests: For fraud detection, platform security, and aggregated analytics, where ll777du's legitimate interest in operating a secure and compliant gaming platform does not override your privacy rights.

ll777du does not sell, rent, or trade your personal data to third parties for marketing purposes. We share your data only in the following circumstances and only to the extent necessary:

• Payment processors: GCash (G-Xchange Inc.), PayMaya, BDO, BPI, Metrobank, and other Philippine payment service providers receive the transaction data necessary to process your deposits and withdrawals.
• KYC verification providers: Third-party identity verification services receive your government-issued ID image and associated data for the purpose of verifying your identity and age.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies may receive player data where required by law, court order, or regulatory mandate.
• Technology service providers: Cloud infrastructure, platform hosting, analytics, and customer support software providers may process data on our behalf as data processors, subject to binding data processing agreements.
• Group companies: ll777du may share data with affiliated entities within the same corporate group for operational and compliance purposes, subject to equivalent data protection standards.

All third parties with whom ll777du shares personal data are required to handle it in accordance with applicable privacy laws and are prohibited from using it for any purpose beyond the scope of their service to ll777du.

ll777du retains personal data for as long as necessary to fulfil the purposes for which it was collected, and in any event for as long as required by applicable Philippine law:

• Active account data: Retained for the duration of the account relationship and for a minimum of five (5) years following account closure, as required by AML regulations.
• Transaction and betting records: Retained for a minimum of five (5) years in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Support communications: Retained for three (3) years from the date of the relevant interaction.
• Marketing data: Retained until you withdraw consent or opt out of marketing communications, and deleted within 30 days of a valid opt-out request.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymised in a manner that makes re-identification impossible.

ll777du implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the ll777du platform.
• Encryption of sensitive data fields (including payment details and government ID data) at rest in our database systems.
• Role-based access controls limiting internal access to personal data to authorised personnel on a need-to-know basis.
• Multi-factor authentication requirements for all ll777du administrative systems.
• Regular security audits and penetration testing of platform infrastructure.
• Incident response procedures for detecting, investigating, and notifying affected players and the National Privacy Commission (NPC) of any data breach within 72 hours of discovery, as required by the Data Privacy Act.

While ll777du takes all reasonable steps to protect your data, no internet transmission or digital storage system is completely secure. You are responsible for maintaining the confidentiality of your ll777du account credentials and for promptly notifying us of any suspected unauthorised access.

ll777du uses cookies and similar tracking technologies on the Platform for the following purposes:

• Strictly necessary cookies: Essential for platform functionality — including session management, login authentication, and security. These cannot be disabled without impairing Platform use.
• Functional cookies: Remember your preferences such as language settings and login status ("remember me" feature) to improve your experience on return visits.
• Analytics cookies: Collect aggregated, anonymised data about how players navigate and use the Platform, used to improve performance and game selection. Analytics data does not identify you personally.

You may control cookie settings through your browser's privacy settings. Please note that disabling strictly necessary cookies will impair your ability to use the ll777du platform, including the ll777du login functionality.

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ll777du:

• Right to be informed: The right to know whether ll777du holds personal data about you and to receive a copy of this Privacy Policy.
• Right of access: The right to request a copy of the personal data ll777du holds about you and information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data held about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to ll777du's legal retention obligations.
• Right to object: The right to object to the processing of your personal data for marketing purposes. You may exercise this right at any time via your account settings or by contacting support.
• Right to data portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, contact ll777du support via live chat or email at support@ll777du.app (plain text — not a clickable link). ll777du will respond to valid data subject requests within fifteen (15) business days.

The ll777du platform is strictly for persons aged 21 years and above. ll777du does not knowingly collect personal data from individuals under the age of 21. If it comes to our attention that personal data has been collected from a person below this age threshold, we will immediately close the relevant account, delete all associated data, and return any deposits made.

If you believe a minor has registered on the ll777du platform, please contact support immediately so that appropriate action can be taken.

ll777du's primary data processing infrastructure is located within or serves the Philippine market. Where personal data is transferred outside the Philippines — for example, to cloud infrastructure providers or KYC verification services operating internationally — ll777du ensures that such transfers are subject to appropriate safeguards in accordance with the Data Privacy Act of 2012 and NPC guidelines, including data processing agreements with equivalent privacy protections to those required under Philippine law.

ll777du may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, or regulatory requirements. When material changes are made, we will notify registered players by SMS to their registered Philippine mobile number and/or by displaying a prominent notice on the Platform.

The date of the most recent revision is displayed at the top of this Privacy Policy. Continued use of the ll777du platform following publication of an updated Privacy Policy constitutes your acceptance of the revised terms.

For any questions, concerns, or requests relating to this Privacy Policy or your personal data held by ll777du, you may contact us through the following channels:

• Live Chat: Available 24/7 through the ll777du platform support interface.
• Email: support@ll777du.app (plain text — this is not a clickable link)

ll777du is committed to responding to all privacy-related inquiries within fifteen (15) business days. If you are unsatisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.