vl777 Privacy Policy

1.1 The vl777 platform, accessible at vl777.co, is operated by the vl777 gaming operator (hereinafter referred to as "vl777," "we," "us," or "the Operator"). For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, the Operator is the Personal Information Controller in respect of all personal data processed in connection with the vl777 platform.

1.2 The Operator processes personal data in compliance with the Data Privacy Act of 2012, the regulations and circulars of the National Privacy Commission (NPC), PAGCOR's licensing conditions, and the Anti-Money Laundering Act (Republic Act No. 9160, as amended).

1.3 For all data privacy enquiries, including the exercise of data subject rights, you may contact our Data Protection Officer (DPO) using the details provided in Section 15 of this Policy.

2.1 This Privacy Policy applies to all personal information collected, used, stored, shared, or otherwise processed by vl777 in connection with:

• Registration and maintenance of a player account on vl777.co;
• Use of any game, feature, promotion, or service offered on the vl777 Platform;
• Deposits, withdrawals, and all financial transactions processed through the Platform;
• Communications between you and vl777, including customer support interactions;
• Participation in vl777 promotions, VIP programs, or surveys.

2.2 This Policy applies to all registered players on the vl777 Platform regardless of the device or method used to access the Platform — desktop browser, mobile browser, or any application. It applies to players located in the Philippines and, to the extent applicable law requires, to players in other jurisdictions.

3.1 vl777 collects personal data that is necessary, relevant, and adequate for the purposes outlined in Section 5. The categories of personal data we collect are described in the table below:

3.2 vl777 does not intentionally collect sensitive personal information as defined under RA 10173 (such as racial or ethnic origin, political opinions, religious beliefs, trade union membership, health data, or sexual orientation) except where strictly required to comply with KYC, anti-money laundering, or responsible gaming obligations — for example, where a Player discloses a gambling disorder in the context of requesting self-exclusion.

3.3 vl777 does not collect or store complete credit or debit card numbers. Card-based transactions are processed through certified PCI-DSS compliant payment gateways that handle all primary card data outside vl777's systems.

4.1 vl777 collects personal data through the following methods:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion;
• Automated technical collection: Device data, IP addresses, session data, and platform interaction data collected automatically as you use the vl777 Platform (see Section 11 for cookie-specific information);
• Transaction records: Deposit and withdrawal data generated and confirmed through your chosen payment method (GCash, Maya, BPI, BDO, etc.);
• Third-party verification services: Identity and age verification data from KYC service providers authorized to assist with PAGCOR compliance;
• PAGCOR and regulatory registries: Information from PAGCOR's National Registry for Excluded Persons (NREP) and other regulatory compliance databases.

5.1 vl777 uses the personal data we collect for the following purposes:

• Account management: Creating, maintaining, securing, and, where applicable, closing your vl777 account;
• Identity and age verification: Verifying that you are at least 21 years of age and confirming your identity in accordance with PAGCOR licensing requirements;
• Platform delivery: Enabling your access to and use of all games, features, and services on the vl777 Platform;
• Transaction processing: Processing deposits and withdrawals in Philippine Peso, reconciling balances, and maintaining transaction records;
• Legal and regulatory compliance: Fulfilling our obligations under PAGCOR conditions, RA 9160 (Anti-Money Laundering Act), RA 10173 (Data Privacy Act), and other applicable Philippine laws;
• Responsible gaming: Operating deposit limits, session reminders, cooling-off periods, and self-exclusion tools; monitoring gaming patterns to identify indicators of problem gambling;
• Fraud prevention and security: Detecting, investigating, and preventing unauthorized account access, bonus abuse, money laundering, and other fraudulent or prohibited activities;
• Customer support: Responding to enquiries, resolving complaints, and providing assistance to registered players;
• Marketing communications: Sending you promotional offers, bonus notifications, and platform updates — but only where you have provided consent or where we have a legitimate interest in communicating with you about your account. You may opt out of marketing communications at any time through your account settings;
• Platform improvement: Analyzing aggregated and anonymized usage data to improve the performance, design, and content of the vl777 Platform.

5.2 vl777 will not use your personal data for any purpose incompatible with the purposes listed above without obtaining your prior consent, except where required or permitted by law.

6.1 vl777 processes personal data only where at least one of the following legal bases under the Data Privacy Act of 2012 applies:

7.1 vl777 does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. Personal data is shared with third parties only to the extent necessary for the operation of the Platform, compliance with legal obligations, or protection of vl777's legitimate interests. The categories of recipients with whom vl777 shares personal data are as follows:

• Payment processors and e-wallet providers: GCash, Maya, BPI, BDO, UnionBank, Metrobank, Coins.ph, and other approved payment partners — to process deposits and withdrawals. These providers receive only the transaction data necessary to execute and confirm the relevant payment.
• Game studios and content providers: Pragmatic Play, JILI Gaming, PG Soft, Evolution Gaming, and other licensed game providers may receive session and wagering data where necessary to operate their games and settle results on the vl777 Platform. These providers are contractually required to process player data solely for platform delivery purposes.
• KYC and identity verification providers: Third-party service providers engaged to assist vl777 in fulfilling its identity verification and age-checking obligations under PAGCOR licensing conditions.
• PAGCOR and regulatory authorities: As required by PAGCOR licensing conditions, player data may be disclosed to PAGCOR for audit, compliance review, and dispute resolution purposes.
• Anti-Money Laundering Council (AMLC): In accordance with Republic Act No. 9160 and its amendments, vl777 is required to report covered and suspicious transactions to the AMLC. Such reports are made under legal compulsion and do not require your consent.
• Law enforcement and government authorities: vl777 will disclose personal data to Philippine law enforcement agencies, courts, or other government bodies where required by a valid legal order, subpoena, or mandatory regulatory process.
• IT and infrastructure service providers: Cloud hosting, data storage, and cybersecurity service providers operating under data processing agreements that contractually bind them to process personal data only on vl777's instructions and in accordance with applicable privacy law.

8.1 Some of vl777's service providers — including certain game studios, cloud infrastructure providers, and KYC service providers — are located or operate servers outside the Philippines. Where personal data is transferred to a recipient in a foreign country, vl777 ensures that appropriate safeguards are in place in accordance with Section 21 of the Data Privacy Act and the NPC's guidelines on cross-border transfers.

8.2 Safeguards for cross-border transfers include:

• Binding contractual arrangements with recipient entities incorporating data protection obligations equivalent to those required under Philippine law;
• Transfers to jurisdictions with an adequate level of data protection as recognized by the National Privacy Commission;
• Binding corporate rules where the recipient is a member of the same corporate group as the Operator.

8.3 You may request information about the specific safeguards in place for any cross-border transfer of your personal data by contacting the vl777 Data Protection Officer at the details provided in Section 15.

9.1 vl777 retains personal data for no longer than is necessary to fulfil the purposes for which it was collected, or as required by applicable law. The following retention schedules apply:

9.2 Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymized in accordance with vl777's data destruction procedures. Anonymized data (from which it is not possible to identify any individual) may be retained indefinitely for statistical and analytical purposes.

10.1 vl777 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• Encryption at rest and in transit: All personal data stored in vl777's systems is encrypted using industry-standard encryption. All data transmissions between your device and vl777's servers are protected by TLS 1.2 or higher;
• Access controls: Personal data is accessible only to vl777 personnel and authorized service providers who require access for legitimate operational purposes, on a need-to-know basis;
• Two-factor authentication: All administrative access to systems containing personal data requires multi-factor authentication;
• Regular security audits: vl777's information security practices are subject to periodic internal review and third-party security assessments;
• Employee training: All vl777 personnel with access to personal data receive regular data protection and security training;
• Incident response procedures: vl777 maintains documented data breach response procedures including obligations to notify affected data subjects and the National Privacy Commission where required by RA 10173 and NPC Circular No. 16-03.

10.2 While vl777 takes all reasonable steps to protect your personal data, no online system is entirely secure. You are responsible for maintaining the security of your own account credentials, as described in vl777's Terms and Conditions.

11.1 vl777 uses cookies and similar tracking technologies on the Platform for the purposes described below. A cookie is a small text file placed on your device by a web server when you visit a website. Cookies do not access other data on your device.

• Strictly Necessary Cookies: Required for the operation of the Platform. These include session management cookies that keep you logged in during your visit and security cookies that help prevent cross-site request forgery (CSRF) attacks. These cookies cannot be disabled.
• Functional Cookies: Remember your preferences — such as your preferred language, game lobby view, and responsible gaming settings — so you do not have to re-enter them on each visit.
• Performance and Analytics Cookies: Collect aggregated, anonymized information about how players use the Platform — pages visited, time spent, navigation paths, and error messages — to help vl777 improve platform performance and user experience.
• Session Security Cookies: Support fraud detection and account security by maintaining session integrity and detecting anomalous access patterns.

11.2 You can manage non-essential cookies through your browser settings. Disabling functional or analytics cookies will not prevent you from using the Platform, but may affect your user experience. Disabling strictly necessary cookies may prevent you from logging in or using certain Platform features.

11.3 vl777 does not use cookies to serve third-party advertising on the Platform, and does not share cookie data with advertising networks.

12.1 Under Republic Act No. 10173 (Data Privacy Act of 2012), you have the following rights as a data subject. vl777 will respond to requests to exercise these rights within thirty (30) days of receipt, subject to identity verification and any applicable exceptions under Philippine law.

12.2 To exercise any of the above rights, please submit a written request to the vl777 Data Protection Officer using the contact details in Section 15. vl777 will require you to verify your identity before processing any request to protect against unauthorized access to your data.

12.3 Please note that certain rights are subject to limitations. In particular, vl777 may be unable to delete personal data that it is required to retain by PAGCOR, AMLC, or other applicable legal obligations. In such cases, vl777 will inform you of the specific legal basis for the retention.

12.4 If you are not satisfied with vl777's response to a data subject rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

13.1 The vl777 Platform is strictly restricted to individuals aged 21 years and above, in accordance with PAGCOR's minimum age requirements for online gaming in the Philippines. vl777 does not knowingly collect or process the personal data of any individual under the age of 21.

13.2 Age verification is conducted at the point of registration and, where required, through documentary KYC processes. Any account found to have been registered by an individual under 21 will be immediately closed, all personal data associated with the account will be securely deleted to the extent permitted by law, and any account balance will be dealt with in accordance with PAGCOR's regulatory requirements.

13.3 If you have reason to believe that an individual under 21 has registered on vl777, please notify the Data Protection Officer immediately using the contact details in Section 15.

14.1 vl777 may update or amend this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or the features available on the Platform. The updated Policy will be published on the vl777 Platform, and the "Last reviewed" date at the top of this document will be updated accordingly.

14.2 Where an amendment materially affects your rights or the way in which your personal data is processed, vl777 will provide advance notice by notifying registered players via their registered contact details before the amended Policy takes effect. For minor amendments — such as clarifications that do not alter the substance of the Policy — the updated document may be published without prior notice.

14.3 Continued use of the vl777 Platform after the effective date of an amended Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree with any material change, you should close your account before the effective date.

15.1 For all data privacy enquiries, requests to exercise data subject rights, and reports of suspected privacy breaches, please contact vl777's Data Protection Officer:

15.2 Please mark all privacy-related communications with the subject line "Data Privacy Request – [Your Account Username]" to ensure prompt routing to the Data Protection Officer's queue. Include a description of your request and, where applicable, documentary evidence of your identity.

15.3 If you are dissatisfied with vl777's response to a privacy complaint or data subject rights request, you may escalate the matter to the National Privacy Commission (NPC) of the Philippines. The NPC is the independent authority responsible for the administration and enforcement of RA 10173.