co77 Privacy Policy

1.Introduction and Scope

co77 ("we", "us", or "the Company") operates the online gaming platform available at co77.app (the "Platform"). We are committed to protecting the privacy and personal data of all users ("you", "Player") who access or use the Platform.

This Privacy Policy describes how co77 collects, uses, stores, shares, and protects your personal data when you visit our website, register an account, make deposits or withdrawals, play games, or interact with our customer support team. It also explains your rights under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, or "DPA") and how to exercise them.

By registering an account on co77 or continuing to use the 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. If you do not agree with this Privacy Policy, please discontinue use of the Platform and contact us to close your account.

2.Data Controller Information

co77 acts as the data controller for personal data collected through the Platform. As data controller, co77 determines the purposes and means of processing your personal data. For all privacy-related enquiries, data subject requests, or complaints, you may contact us at:

• Email: [email protected]
• Subject Line: "Privacy / Data Subject Request"
• Response Time: Within 15 business days for data subject requests

3.Personal Data We Collect

3.1 Registration Data

When you create a co77 account, we collect the following information:

• Full legal name
• Date of birth (to verify you are 21 years of age or older)
• Email address
• Mobile number (used for account verification and GCash/PayMaya linking)
• Residential address (city, province, Philippines)
• Username and encrypted password

3.2 Identity Verification (KYC) Data

To comply with Philippine anti-money laundering regulations and to verify your age and identity, co77 may collect:

• Government-issued ID (Philippine passport, SSS ID, PhilHealth ID, UMID, driver's licence, or voter's ID)
• Selfie or live photo for facial verification
• Proof of address (utility bill, bank statement, or barangay certificate)
• Source of funds documentation for large transactions

3.3 Financial Data

When you make deposits or withdrawals, co77 collects:

• GCash or PayMaya account number (mobile number)
• Bank account details (BPI, BDO, Metrobank) where applicable
• Transaction history, amounts, and timestamps

co77 does not store full card numbers or CVV codes. Payment processing is handled by regulated payment service providers.

3.4 Gaming Activity Data

co77 automatically records your gaming activity on the Platform, including:

• Games played, bet amounts, and game outcomes
• Session duration and login/logout timestamps
• Bonus usage and wagering history
• Responsible gaming tool activations (deposit limits, self-exclusion requests)

3.5 Technical and Device Data

When you access the Platform, we automatically collect certain technical data:

Data Type	Purpose
IP Address	Fraud prevention, geolocation verification, security monitoring
Device Type & OS	Platform optimisation for mobile (Android/iOS) and desktop
Browser Type & Version	Compatibility and performance optimisation
Session Cookies	Maintaining your login session and platform preferences
Referral Source	Understanding how players discover co77 (analytics only)

3.6 Communications Data

When you contact co77 customer support via email or live chat, we retain records of those communications, including the content of your messages, timestamps, and the resolution of your enquiry. This data is used to improve our support quality and to maintain a record of your interactions with co77.

4.How We Use Your Personal Data

co77 uses your personal data for the following purposes:

• Account Management: Creating, maintaining, and securing your co77 account; verifying your identity and age (21+); processing login and authentication.
• Transaction Processing: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank; maintaining accurate financial records in Philippine Peso (PHP).
• Regulatory Compliance: Fulfilling obligations under Philippine anti-money laundering laws, PAGCOR regulations, and the Data Privacy Act of 2012; reporting to regulatory authorities as required by law.
• Fraud Prevention and Security: Detecting and preventing fraudulent activity, unauthorised account access, bonus abuse, and money laundering; monitoring for suspicious transaction patterns.
• Responsible Gaming: Monitoring gaming behaviour to identify signs of problem gambling; enforcing deposit limits, cooling-off periods, and self-exclusion requests; complying with responsible gaming obligations.
• Customer Support: Responding to your enquiries, complaints, and data subject requests; improving the quality of our support services.
• Platform Improvement: Analysing aggregated, anonymised usage data to improve game offerings, website performance, and the overall player experience on co77.
• Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates by email or SMS — only where you have provided consent. You may opt out at any time.

5.Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, co77 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to fulfil our obligations under the Terms & Conditions you agreed to upon registration (e.g., account management, payment processing).
• Legal Obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR licensing requirements, and tax obligations.
• Legitimate Interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6.Sharing Your Personal Data

6.1 Service Providers

co77 shares personal data with carefully selected third-party service providers who assist in operating the Platform. These include payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, game software suppliers, and cloud hosting providers. All service providers are contractually bound to process your data only on co77's instructions and to maintain appropriate security standards.

6.2 Regulatory and Law Enforcement Authorities

co77 may disclose your personal data to Philippine regulatory authorities (including PAGCOR and the Anti-Money Laundering Council), law enforcement agencies, or courts where required by law, court order, or regulatory directive. co77 will notify you of such disclosures where legally permitted to do so.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of co77's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the privacy practices of the new data controller.

6.4 No Sale of Personal Data

co77 does not sell, rent, or trade your personal data to third-party advertisers or data brokers under any circumstances. Your data is not a commercial product.

7.Cookies and Tracking Technologies

co77 uses the following types of cookies on the Platform:

Cookie Type	Purpose	Can Be Disabled?
Essential Cookies	Login session management, security tokens, platform functionality	No — required for the Platform to function
Analytics Cookies	Anonymous usage statistics to improve Platform performance	Yes — via browser settings
Preference Cookies	Remembering your language, display, and game preferences	Yes — via browser settings

co77 does not use third-party advertising or tracking cookies. You can manage or delete cookies through your browser settings at any time. Disabling essential cookies may affect the functionality of the Platform.

8.Data Retention

co77 retains your personal data for as long as your account remains active and for a period thereafter as required by applicable Philippine law. Specifically:

• Account and KYC data: Retained for a minimum of 5 years after account closure, in compliance with Philippine anti-money laundering regulations.
• Transaction records: Retained for a minimum of 5 years from the date of each transaction.
• Gaming activity logs: Retained for 2 years from the date of each session.
• Customer support communications: Retained for 2 years from the date of the last interaction.
• Marketing consent records: Retained until you withdraw consent, plus 1 year thereafter for compliance purposes.

Upon expiry of the applicable retention period, co77 will securely delete or anonymise your personal data in accordance with our internal data disposal procedures.

9.Data Security

co77 implements a comprehensive set of 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 co77 Platform
• Encrypted storage of passwords using industry-standard hashing algorithms
• Role-based access controls limiting employee access to personal data on a need-to-know basis
• Regular security audits and penetration testing of Platform infrastructure
• Intrusion detection and real-time monitoring systems
• Two-factor authentication (2FA) available for all co77 player accounts

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, co77 will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the DPA.

10.Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by co77:

• Right to be Informed: The right to know what personal data co77 collects about you and how it is used — as described in this Privacy Policy.
• Right of Access: The right to request a copy of the personal data co77 holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to co77's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact co77 at [email protected] with the subject line "Data Subject Request". co77 will respond within 15 business days. We may need to verify your identity before processing your request.

11.Children's Privacy

The co77 Platform is strictly intended for adults aged 21 years and older, in accordance with Philippine gambling regulations. co77 does not knowingly collect personal data from individuals under the age of 21. If co77 becomes aware that personal data has been collected from a person under 21, that account will be immediately suspended, the data will be deleted, and any deposits will be returned.

If you are a parent or guardian and believe that your child has registered on co77, please contact us immediately at [email protected] and we will take prompt action.

12.International Data Transfers

co77 primarily stores and processes player data within secure data centres. Where personal data is transferred to service providers located outside the Philippines (for example, cloud infrastructure or game software providers), co77 ensures that appropriate safeguards are in place, including contractual data protection clauses consistent with the requirements of the Philippine DPA and its Implementing Rules and Regulations.

co77 does not transfer your personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate contractual safeguards.

13.Changes to This Privacy Policy

co77 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform features. Material changes will be communicated to registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the Platform after the effective date of any revision constitutes your acceptance of the updated Privacy Policy. We encourage you to review this page periodically.

14.Contact and Data Subject Requests

For all privacy-related enquiries, data subject access requests, consent withdrawals, or complaints regarding co77's data practices, please contact us using the details below:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: "Privacy / Data Subject Request"
• Response Time: Within 15 business days for formal data subject requests; within 24 hours for general privacy enquiries
• Support Hours: 24 hours a day, 7 days a week

If you are not satisfied with co77's response to your privacy complaint, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for enforcing the Data Privacy Act of 2012.