Privacy Policy — penas77

1. Introduction

penas77 ("penas77," "we," "us," "our") is committed to protecting the privacy and personal data of all players, visitors, and users of the penas77 Platform at penas77.com. This Privacy Policy ("Policy") describes our practices for collecting, using, storing, disclosing, and protecting personal data in connection with your use of the Platform.

This Policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 of the Republic of the Philippines ("DPA"), and its Implementing Rules and Regulations. By registering an account with penas77 or otherwise using the Platform, you acknowledge that you have read, understood, and consent to the data practices described in this Policy.

2. Data Controller

For the purposes of applicable data privacy law, penas77 acts as the personal information controller in respect of the personal data it collects from Players and visitors. All inquiries regarding the processing of personal data should be directed to the penas77 Data Protection Officer (DPO) via the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

penas77 collects only the personal data necessary to fulfil the purposes described in this Policy. The categories of personal data we may collect include:

• Identity Data: Full legal name, date of birth, nationality, and government-issued identification document details (e.g., PhilSys ID, passport, driver's licence, UMID).
• Contact Data: Registered mobile number (including Philippine mobile network subscriber details where applicable), email address, and residential address.
• Account Data: Username, encrypted password credentials, account preferences, responsible gaming settings, and communication preferences.
• Financial Data: GCash account details, PayMaya account details, bank account numbers (BPI, BDO, Metrobank, or other supported banks), transaction history, deposit and withdrawal records.
• Gaming Data: Game session logs, wagering history, bet records, win/loss data, bonus usage, and gameplay preferences.
• Technical Data: IP address, device type, browser type and version, operating system, session duration, and access timestamps.
• Verification Data: Source-of-funds documentation, proof of address, and other identity verification materials submitted during account verification or enhanced due diligence procedures.

4. How We Collect Your Data

penas77 collects personal data through the following means:

• Direct collection: Information you provide when registering your penas77 account, completing identity verification, making deposits or withdrawal requests, contacting support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, server logs, and session tracking technologies.
• Third-party sources: Identity verification data from PAGCOR-approved KYC (Know Your Customer) providers, fraud detection services, and payment processors where necessary for regulatory compliance.

5. Purposes of Processing

penas77 processes your personal data for the following purposes:

• To create, maintain, and administer your penas77 account.
• To verify your identity and age (21+) in compliance with PAGCOR regulations and applicable AML requirements.
• To process deposits and withdrawals through GCash, PayMaya, and supported Philippine banking channels.
• To deliver the games, betting markets, and other Platform features to which you have subscribed or which you access.
• To administer bonuses, promotions, and VIP program benefits.
• To provide 24/7 customer support and respond to your inquiries.
• To detect, investigate, and prevent fraudulent activity, bonus abuse, money laundering, and other prohibited conduct.
• To comply with legal and regulatory obligations under Philippine law, including PAGCOR compliance requirements and the Data Privacy Act.
• To send you transactional communications, including deposit confirmations, withdrawal notifications, and account security alerts.
• To send promotional communications where you have opted in to receiving such communications from penas77.
• To improve the Platform, analyse usage patterns, and develop new features and services.

6. Legal Basis for Processing

penas77 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our obligations under the Terms and Conditions governing your penas77 account, including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine law, PAGCOR regulations, anti-money laundering obligations, and tax reporting requirements.
• Legitimate interests: Processing for fraud prevention, security monitoring, and Platform improvement where these interests are not overridden by your data privacy rights.
• Consent: Processing for marketing communications and non-essential cookies where you have provided explicit consent. You may withdraw this consent at any time by contacting penas77 support.

7. Data Sharing & Disclosure

penas77 does not sell, rent, or trade your personal data to third parties for their independent marketing purposes. penas77 may share your personal data with the following categories of recipients only as necessary:

• Payment processors: GCash (Mynt/Globe Fintech Innovations), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, and other payment service providers for the purpose of processing transactions.
• Game providers: Third-party software providers whose games are hosted on the penas77 Platform. These providers receive only the technical data necessary to operate the game session.
• Identity verification providers: PAGCOR-approved KYC and AML service providers for identity verification and compliance screening.
• Regulatory authorities: PAGCOR, the National Privacy Commission of the Philippines, law enforcement agencies, and other competent authorities where disclosure is required by law, court order, or regulatory directive.
• Professional advisers: Lawyers, auditors, and compliance consultants bound by confidentiality obligations.
• Technology service providers: Cloud hosting, security monitoring, and analytics providers operating under data processing agreements with appropriate data protection obligations.

All third parties with whom penas77 shares personal data are required to implement adequate data protection measures consistent with the DPA.

8. Data Retention

penas77 retains your personal data for as long as your account remains active and for such additional periods as required by law or legitimate business necessity. In particular:

• Account and identity verification data is retained for a minimum of five (5) years following account closure, as required by applicable AML and PAGCOR record-keeping obligations.
• Financial transaction records are retained for a minimum of five (5) years in compliance with tax and regulatory requirements.
• Gaming session data and bet records are retained for three (3) years following the date of the transaction.
• Marketing consent records are retained for three (3) years from the date consent was given or withdrawn.

Following the expiry of applicable retention periods, personal data will be securely destroyed or anonymised so that it can no longer be associated with any individual.

9. Security Measures

penas77 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the penas77 Platform.
• Encrypted storage of passwords and sensitive account credentials.
• Role-based access controls limiting internal access to personal data on a need-to-know basis.
• Continuous security monitoring and intrusion detection systems.
• Regular security assessments and vulnerability testing of the Platform.
• Multi-factor authentication options available to all registered Players.

While penas77 takes all reasonable steps to protect your personal data, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying penas77 immediately if you suspect any unauthorised access to your account.

10. Cookies & Tracking Technologies

The penas77 Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, analyse usage patterns, and support fraud prevention. Cookies used by penas77 fall into the following categories:

• Strictly necessary cookies: Essential for the Platform to function. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and login state.
• Analytics cookies: Collect anonymised data about how you use the Platform to help us improve its performance.
• Security cookies: Assist in detecting fraudulent activity and protecting your account session.

You may control non-essential cookies through your browser settings. Disabling certain cookies may affect the functionality of the penas77 Platform.

11. Your Data Privacy 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 penas77:

• Right to be informed: The right to be told how your personal data is being collected and processed, as detailed in this Policy.
• Right of access: The right to request a copy of the personal data penas77 holds about you.
• Right to rectification: The right to have inaccurate or incomplete personal data corrected.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or on grounds relating to your particular situation.
• Right to data portability: The right to receive 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 of the Philippines if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact the penas77 Data Protection Officer using the contact information in Section 15. penas77 will respond to all verified requests within thirty (30) days in accordance with the DPA.

12. Children's Privacy

The penas77 Platform is strictly intended for individuals aged 21 years and above in compliance with PAGCOR's minimum age requirement for online gaming in the Philippines. penas77 does not knowingly collect or process personal data from any individual under the age of 21. If penas77 becomes aware that personal data has been collected from a person under 21 years of age, that data will be deleted immediately and the associated account closed. If you believe a minor has registered on the penas77 Platform, please notify us immediately through our support channels.

13. International Data Transfers

Some of penas77's service providers and game software partners may be located outside the Philippines. Where personal data is transferred to recipients in other countries, penas77 ensures that adequate safeguards are in place as required by the Data Privacy Act, including contractual protections requiring recipients to maintain data protection standards equivalent to those applicable in the Philippines.

14. Amendments to This Policy

penas77 reserves the right to update or amend this Privacy Policy at any time. When material changes are made, penas77 will notify registered Players via their registered email address or mobile number. The "Last Updated" date at the top of this page reflects the most recent revision. Your continued use of the penas77 Platform following notification of any change constitutes your acceptance of the revised Policy. We encourage you to review this Policy periodically.

15. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or penas77's data processing practices, you may contact our Data Protection Officer:

• Via 24/7 live chat available through the penas77 platform dashboard
• By email: [email protected] (subject line: "Privacy / DPO Inquiry")

All privacy-related inquiries will be acknowledged within three (3) business days and resolved within thirty (30) days in compliance with the Data Privacy Act of 2012.