This Privacy Policy explains how fill77 collects, processes, stores, and protects your personal data. fill77 is committed to full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and all applicable PAGCOR data handling requirements.
Before reading the full legal text, here are the six core privacy principles that govern how fill77 handles every Filipino player's personal data.
fill77's data practices are fully governed by Republic Act No. 10173 — the Philippine Data Privacy Act of 2012 — and the Implementing Rules and Regulations issued by the National Privacy Commission (NPC). Every data processing activity at fill77 has a lawful basis under Philippine law.
fill77 collects only the personal data necessary for the specific, legitimate purposes described in this Policy. Your data is never used for purposes beyond those stated here without your explicit consent or a lawful override permitted by Philippine law. We do not build advertising profiles or sell your data to third parties.
fill77 applies 256-bit SSL encryption, access controls, encrypted data storage, and regular security reviews to protect your personal data. Employees with access to personal data are bound by confidentiality obligations and receive regular data protection training. We notify affected players and the NPC in the event of a data breach, as required by law.
fill77 retains your personal data only for as long as required by the purpose for which it was collected, or as mandated by PAGCOR, BSP, AMLC, or other applicable Philippine law. After the applicable retention period, personal data is securely deleted or anonymized in accordance with our data retention schedule.
fill77 tells you clearly what personal data it collects, why it collects it, who it shares it with, and how long it keeps it. This Privacy Policy is written in plain English — not just to satisfy legal requirements, but because Filipino players deserve to understand what happens to their information without needing a lawyer to translate it.
Under the Philippine Data Privacy Act, you have specific, enforceable rights over your personal data held by fill77 — including the right to access, correct, erase, and object to processing. fill77 honors these rights within the response timelines required by law and provides a clear process to exercise each right, described in full in this Policy.
Important Notice: This Privacy Policy ("Policy") is issued by fill77 ("fill77," "we," "us," "our"), the licensed operator of fill77.club, in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations. This Policy applies to all personal data processed by fill77 in connection with the provision of online gaming and related services to registered players in the Philippines. By registering a fill77 account, you acknowledge that you have read and understood this Policy.
1.1 fill77 is the personal information controller ("Controller") responsible for the personal data of registered players and website visitors collected through fill77.club and all related mobile or web applications operated under the fill77 brand.
1.2 fill77 is authorized by the Philippine Amusement and Gaming Corporation (PAGCOR) to operate online gaming services in the Philippines. fill77's data processing activities are subject to PAGCOR data governance requirements in addition to the general obligations of the Data Privacy Act.
1.3 fill77 has designated a Data Protection Officer ("DPO") as required by Section 21 of the DPA Implementing Rules. The DPO oversees fill77's compliance with the DPA, coordinates responses to data subject rights requests, and serves as the primary liaison with the National Privacy Commission (NPC). Contact details for the DPO are provided in Section 15 of this Policy.
2.1 This Policy applies to all personal data collected from: registered fill77 account holders; individuals who have commenced but not completed the fill77 registration process; visitors to fill77.club who have not registered an account; and individuals who contact fill77 customer support via live chat or email.
2.2 This Policy does not apply to the data practices of third-party payment processors (such as GCash, Maya, BPI, or BDO), game content providers, or any other third-party services linked to or integrated with fill77. Each such third party is an independent data controller with its own privacy policy, which you should review separately.
2.3 This Policy should be read together with fill77's Terms & Conditions and Responsible Gaming Policy, both of which contain additional provisions relevant to the processing of personal data in the context of specific services.
3.1 fill77 collects the following categories of personal data in connection with providing its services:
| Data Category | Specific Data Points | Collection Stage |
|---|---|---|
| Identity Data | Full legal name, date of birth, nationality, gender | Registration & KYC |
| Contact Data | Philippine mobile number, email address, residential address | Registration |
| Government ID Data | ID document type, ID number, ID expiry date, ID photograph | KYC Verification |
| Biometric-Adjacent Data | KYC selfie photograph (for facial matching against ID document only) | KYC Verification |
| Financial Data | GCash / Maya account numbers, bank account numbers (for withdrawals), deposit and withdrawal history, transaction records | Deposit / Withdrawal |
| Gaming Activity Data | Game session logs, bet history, win/loss records, bonus usage, session duration | During Play |
| Technical Data | IP address, device identifier, browser type, operating system, connection type | On Access |
| Communications Data | Live chat transcripts, email correspondence, support ticket records | Customer Support |
| Preference Data | Responsible gaming limit settings, marketing consent preferences, notification preferences | Account Settings |
Sensitive Personal Information: KYC selfie photographs and government ID data constitute sensitive personal information under Section 3(l) of the Philippine Data Privacy Act. fill77 processes this data exclusively for identity verification and fraud prevention purposes under the lawful basis of legal obligation (PAGCOR KYC requirements) and legitimate interests. This data is subject to heightened security controls and stricter access restrictions than other personal data categories.
4.1 fill77 collects personal data through the following channels and mechanisms:
5.1 Under Section 12 of the Philippine Data Privacy Act, personal data may be processed only when one of the following lawful criteria is satisfied. fill77's data processing activities are based on the following lawful criteria:
6.1 fill77 uses your personal data for the following specific purposes, each associated with a defined lawful basis:
What fill77 Does Not Do: fill77 does not sell, rent, or trade your personal data to third-party marketers. fill77 does not use your personal data to build advertising profiles for any external advertising network. fill77 does not share your individual gaming history with other players or publicly disclose any personally identifiable account data.
7.1 fill77.club uses cookies and similar browser-based storage technologies to enable essential platform functions and improve your experience. fill77 uses the following categories of cookies:
7.2 fill77 does not use third-party advertising cookies or allow external advertising networks to set cookies on fill77.club. You can manage or delete cookies using your browser settings, though disabling strictly necessary cookies will prevent proper platform function including the fill77 login.
8.1 fill77 shares personal data only in the limited circumstances described below. All third parties that receive personal data from fill77 are required to handle it in compliance with the Philippine Data Privacy Act and in accordance with a data processing agreement executed with fill77.
8.2 fill77 does not share personal data with any entity not listed in Section 8.1 without your prior explicit consent, unless required by law.
9.1 fill77 implements the following technical and organizational security measures to protect personal data against unauthorized access, accidental loss, destruction, or disclosure:
Security Note for Players: fill77's security measures protect data on fill77's systems. The security of your fill77 account also depends on your own behavior — including using a strong, unique password, enabling 2FA, and never sharing your credentials. fill77 support will never ask for your password or OTP. If you believe your account has been compromised, contact fill77 live chat immediately.
10.1 fill77 retains personal data for the minimum period necessary to fulfill the purpose for which it was collected, or for such longer period as may be required by Philippine law. The following retention periods apply:
| Data Category | Retention Period | Legal Basis for Retention |
|---|---|---|
| Account & KYC identity data | 5 years after account closure | PAGCOR regulations; AMLA record-keeping requirements |
| Transaction records | 5 years from transaction date | AMLA; BIR requirements; PAGCOR audit requirements |
| KYC documents (ID + selfie) | 5 years after account closure | PAGCOR KYC; AMLA record-keeping |
| Gaming activity logs | 3 years from session date | PAGCOR audit requirements; dispute resolution |
| Customer support records | 3 years from interaction date | Legitimate interests (dispute resolution) |
| Marketing consent records | Until consent withdrawn + 1 year | DPA consent documentation requirement |
| Technical / IP log data | 90 days | Security and fraud prevention (legitimate interests) |
10.2 After the applicable retention period expires, personal data is securely deleted from fill77's systems or, where deletion is not technically feasible (for example, in backup archives), anonymized so that it can no longer be linked to an identifiable individual.
11.1 Under the Philippine Data Privacy Act, you have the following rights in relation to personal data held by fill77. You may exercise any of these rights by contacting fill77's Data Protection Officer using the contact details in Section 15.
You have the right to be informed whether fill77 holds any personal data about you and, if so, to be provided with a description of that data and the purposes for which it is processed. This Privacy Policy constitutes part of fill77's discharge of this right.
You have the right to request a copy of the personal data fill77 holds about you, together with information about the purposes of processing, the categories of data held, and the third parties to whom your data has been disclosed. fill77 will respond within 15 calendar days of receiving a verified access request.
You have the right to request correction of any inaccurate or incomplete personal data fill77 holds about you. Where correction is requested, fill77 will also notify relevant third parties who received the inaccurate data, unless this is impossible or involves disproportionate effort.
You may request erasure of your personal data where: the data is no longer necessary for the purpose for which it was collected; you withdraw consent and no other lawful basis exists; or fill77 has processed the data unlawfully. This right does not apply where fill77 is required to retain the data by Philippine law (e.g., AMLA or PAGCOR retention requirements).
You may object to fill77 processing your personal data on the basis of legitimate interests, where you believe that interest is overridden by your own fundamental rights. You may also withdraw marketing consent at any time, after which fill77 will cease all marketing processing immediately.
Where fill77 processes your personal data on the basis of contract or consent, and the processing is carried out by automated means, you have the right to receive a machine-readable copy of the personal data you provided to fill77, for personal use or for transfer to another service provider.
11.2 To exercise any of the rights above, submit a written request to fill77's Data Protection Officer at the contact details in Section 15, including your full name, registered email address or mobile number, and a description of the specific right you wish to exercise. fill77 may ask for identity verification before processing a rights request.
11.3 If you believe fill77 has failed to respond to your rights request adequately, or that fill77 has otherwise violated the Philippine Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) through NPC's official channels.
12.1 fill77 services are strictly limited to individuals aged 21 years and above, as required by PAGCOR. fill77 does not knowingly collect personal data from any individual under the age of 21 years, and this privacy policy does not apply to any such individual.
12.2 If fill77 discovers that personal data has been collected from an individual under 21 — whether through registration fraud or any other means — fill77 will immediately terminate the relevant account, delete all associated personal data to the extent permitted by applicable record-keeping laws, and report the matter to PAGCOR as required.
12.3 Parents or guardians who believe that a minor under their care may have accessed or registered a fill77 account should contact fill77 customer support immediately via live chat or email at [email protected].
13.1 Some of fill77's third-party processors — including KYC verification providers and game content providers — may process personal data outside the Philippines. Where fill77 transfers personal data outside Philippine territory, fill77 ensures that such transfers comply with Section 21 of the Philippine Data Privacy Act, which requires that the recipient country provides adequate data protection standards, or that fill77 implements appropriate contractual safeguards (such as NPC-approved standard contractual clauses) to protect the transferred data.
13.2 fill77's primary data storage infrastructure is located in the Philippines. Cross-border transfers are limited to what is operationally necessary and are governed by data processing agreements that bind the receiving party to data protection obligations equivalent to those under Philippine law.
14.1 fill77 may update this Privacy Policy from time to time to reflect changes in fill77's data processing practices, changes in Philippine data privacy law or NPC guidance, or changes in PAGCOR requirements. The effective date and last updated date at the top of this document will always reflect the current version.
14.2 Where an update materially affects your rights or the way fill77 processes your personal data, fill77 will notify registered players by email or in-platform notification at least seven (7) days before the updated Policy takes effect. Minor updates (such as clarifications that do not change the substance of data processing) may take effect without prior notification.
14.3 Continued use of fill77 services after an updated Privacy Policy takes effect constitutes your acknowledgment of the updated Policy. The current version of this Policy is always available at fill77.club/privacy-policy.
15.1 If you have any questions, concerns, or requests regarding this Privacy Policy or fill77's data processing practices, please contact fill77's Data Protection Officer through the following channels:
15.2 fill77 targets a response time of 15 calendar days for data subject rights requests and formal privacy complaints, consistent with NPC guidelines. Complex requests may require additional time, in which case fill77 will notify you of the extended timeline within the initial 15-day period.
National Privacy Commission: If you are unsatisfied with fill77's response to a privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. The NPC is the independent government body responsible for enforcing the Data Privacy Act and safeguarding Philippine data subjects' rights. fill77 will cooperate fully with any NPC investigation.