Privacy Policy — 78phpearl

This Privacy Policy applies to all personal data processed by 78phpearl ("we," "us," "our," or "the Company") in connection with the operation of the 78phpearl online casino and sports betting platform, accessible at 78phpearl.vip and any associated mobile applications or software ("the Platform").

78phpearl acts as the Data Controller in respect of personal data collected directly from players and site visitors. Where 78phpearl engages third-party service providers to process personal data on its behalf, those parties act as Data Processors under written agreements that obligate them to handle data in accordance with this Policy and applicable Philippine law.

This Policy governs the personal data of all individuals who:

• Visit or browse the 78phpearl website without registering an account.
• Register a player account on the 78phpearl platform.
• Make use of 78phpearl's gaming, betting, or financial services.
• Contact 78phpearl through customer support, live chat, or email.
• Participate in 78phpearl promotional activities or loyalty programs.

78phpearl collects personal data through multiple channels: directly from you during registration and account use, automatically through platform technologies, and from third parties where permitted by law. The categories of data collected include:

78phpearl does not collect sensitive personal information — such as health data, religious beliefs, or political opinions — except where such data is incidentally disclosed in the context of responsible gaming assessments or account dispute investigations, and only to the extent strictly necessary for those purposes.

78phpearl uses your personal data for clearly defined purposes, all of which are necessary for the lawful operation of the platform and compliance with our regulatory obligations under PAGCOR:

• Account creation and management: Creating and maintaining your 78phpearl player account, authenticating your identity at login, and managing account settings and preferences.
• KYC verification and age confirmation: Verifying that you are at least 21 years of age and that your identity is genuine, as required by PAGCOR's responsible gaming framework and applicable law.
• Payment processing: Processing deposits and withdrawals through your chosen payment method (GCash, Maya, BPI, BDO, etc.), detecting payment fraud, and maintaining transaction records.
• Gaming services: Delivering access to casino games, sports betting, and other platform features; maintaining game history and bet records for fairness purposes.
• Bonus and promotion administration: Validating your eligibility for promotional offers, tracking wagering progress, and preventing bonus abuse.
• Regulatory compliance: Fulfilling our obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the National Privacy Commission's guidelines, including mandatory transaction reporting where legally required.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviors; administering deposit limits, cool-off periods, and self-exclusion orders; and complying with PAGCOR's responsible gaming mandates.
• Customer support: Responding to your inquiries, complaints, and formal disputes submitted through 78phpearl support channels.
• Security and fraud prevention: Detecting and investigating unauthorized account access, fraudulent transactions, collusion, and other prohibited activities.
• Platform improvement: Analyzing aggregated usage data to improve platform performance, user experience, and game selection. This analysis uses de-identified or aggregated data wherever possible.
• Marketing communications: Sending promotional emails, SMS notifications, or in-platform messages about 78phpearl offers and new features — only where you have provided consent or where permitted under applicable Philippine law. You may opt out at any time.

Under the Data Privacy Act of 2012, 78phpearl processes personal data on the following lawful grounds:

• Contractual Necessity: Processing is necessary to perform the contract between you and 78phpearl — specifically, to create and maintain your player account, process transactions, and deliver gaming services. Without this processing, 78phpearl cannot provide you with a functional platform.
• Legal Obligation: Processing is required to comply with PAGCOR licensing conditions, AMLA reporting obligations, National Privacy Commission requirements, and other applicable Philippine statutory duties. 78phpearl cannot waive these obligations.
• Legitimate Interests: Processing is necessary for 78phpearl's legitimate interests in operating a secure, fair, and commercially sustainable gaming platform — including fraud detection, security monitoring, and platform analytics — where those interests are not overridden by your fundamental data privacy rights.
• Consent: Where processing is not covered by the above grounds, 78phpearl will seek your explicit consent. In particular, consent is the primary basis for sending direct marketing communications. You have the right to withdraw consent at any time without affecting the lawfulness of prior processing.

78phpearl does not sell, rent, or trade your personal data. We share personal data with third parties only in the following limited circumstances:

• Payment service providers: GCash (Mynt), Maya (PayMaya Philippines Inc.), BPI, BDO, Metrobank, Coins.ph, and cryptocurrency processing partners receive financial data strictly necessary to process your transactions. These providers are subject to their own data protection obligations under Philippine law.
• KYC and identity verification partners: Licensed third-party identity verification services receive copies of your identification documents and selfie images solely for the purpose of confirming your identity and age.
• Game content providers: Licensed game studios and aggregators may receive your player account identifier and gaming activity data to deliver their game content and maintain game integrity records. Game providers do not receive your full identity or financial data.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement authorities with lawful jurisdiction may receive personal data when required by applicable Philippine law, court order, or regulatory directive.
• IT and security service providers: Cloud hosting, cybersecurity monitoring, and platform infrastructure providers may process technical and operational data under strict confidentiality agreements.
• Professional advisors: Legal counsel, auditors, and compliance consultants may access personal data on a need-to-know basis, subject to professional confidentiality obligations.

78phpearl retains personal data for as long as necessary to fulfill the purposes described in this Policy and to comply with applicable legal retention obligations. The following general retention periods apply:

• Active account data: Retained for the duration of the player's account and for a period of five (5) years following permanent account closure, unless a longer period is required by law.
• KYC and identity verification documents: Retained for a minimum of five (5) years from account closure, in compliance with PAGCOR's record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA record-keeping requirements applicable to covered institutions.
• Gaming activity logs: Retained for a minimum of three (3) years, used for dispute resolution, game integrity audits, and regulatory reviews.
• Customer support records: Retained for three (3) years from the date of the last interaction, or longer if related to an unresolved dispute or regulatory inquiry.
• Marketing consent records: Retained for as long as the consent remains active, plus one (1) year following withdrawal of consent as evidence of the consent having been given.

When personal data is no longer required for its stated retention period and no legal obligation requires continued retention, 78phpearl will securely delete or anonymize the data in accordance with industry-standard disposal procedures.

78phpearl implements a multi-layered security architecture to protect your personal and financial data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Security measures in place include:

• Encryption in transit: All data transmitted between your device and the 78phpearl platform is encrypted using Transport Layer Security (TLS 1.2 or higher).
• Encryption at rest: Personal data and financial records stored on 78phpearl servers are encrypted using AES-256 encryption.
• Access controls: Access to personal data by 78phpearl employees and contractors is granted on a strict need-to-know basis, enforced through role-based access controls and regular access review processes.
• Two-factor authentication: Player accounts support OTP-based two-factor authentication to prevent unauthorized account access.
• Security monitoring: 78phpearl's platform is continuously monitored for anomalous activity, intrusion attempts, and potential data security incidents.
• Staff training: All 78phpearl employees with access to personal data are trained on data privacy obligations and information security practices.

In the event of a personal data breach that is likely to cause harm to affected individuals, 78phpearl will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, in accordance with the Data Privacy Act of 2012 and NPC Circular No. 16-03. Affected players will also be notified where required.

78phpearl uses cookies, web beacons, and similar tracking technologies to operate the platform securely and improve your experience. The following types of cookies are used:

• Essential cookies: Required for core platform functionality including maintaining your login session, remembering your account preferences, and enabling the secure transmission of payment data. These cannot be disabled without impairing platform access.
• Performance cookies: Collect aggregated, anonymized data about how players navigate the platform — which pages are visited most, where errors occur, and how features are used. This data helps 78phpearl optimize the platform.
• Functional cookies: Remember your preferences such as display language, preferred game categories, and notification settings so you don't need to re-enter them each session.
• Security cookies: Detect fraudulent activity, protect against unauthorized login attempts, and maintain session integrity.

You may manage non-essential cookie preferences through your browser settings. Most modern browsers (Chrome, Safari, Firefox, Edge) allow you to block or delete cookies. Please note that disabling essential cookies may prevent you from accessing certain parts of the 78phpearl platform, including the login and cashier sections.

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by 78phpearl:

To exercise any of these rights, please contact 78phpearl's Data Protection Officer using the contact information in Section 13. 78phpearl will respond to verified requests within thirty (30) days. Where a request requires more time to fulfill, we will notify you within the initial thirty-day period and provide an estimated completion date.

If you believe your data privacy rights have not been adequately addressed, you have the right to lodge a complaint with the National Privacy Commission of the Philippines through the NPC's official channels.

The 78phpearl platform is strictly intended for adults aged 21 years and older in accordance with Philippine law and PAGCOR regulations. 78phpearl does not knowingly collect personal data from individuals under the age of 21.

If 78phpearl discovers or is notified that personal data has been collected from a person under the age of 21, we will immediately take the following steps:

• Permanently close the account and block the associated device and payment methods.
• Delete all personal data associated with the minor's account from our systems, subject to any mandatory regulatory reporting obligations.
• Forfeit and void any balance, bonus, or winnings in the account.
• Report the incident to PAGCOR as required by our licensing obligations.

As a Philippines-based gaming platform, 78phpearl primarily stores and processes personal data within the Philippines. However, certain service providers engaged by 78phpearl — including game content providers, cloud infrastructure partners, and cybersecurity monitoring services — may be located in other jurisdictions.

Where personal data is transferred outside the Philippines, 78phpearl ensures that appropriate safeguards are in place as required by the National Privacy Commission. These safeguards may include:

• Contractual clauses approved by the NPC requiring the receiving party to apply equivalent data protection standards.
• Transfer to jurisdictions with adequacy determinations or equivalent protective frameworks recognized by the NPC.
• Binding corporate rules where data is transferred within a corporate group.

A list of jurisdictions to which personal data may be transferred, along with the applicable safeguards, is available upon written request to 78phpearl's Data Protection Officer.

78phpearl reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or PAGCOR regulatory requirements. When material changes are made, 78phpearl will:

• Update the "Last Updated" and "Effective Date" fields at the top of this document.
• Where the changes are significant, provide notice to active players via platform notification or email at least fourteen (14) days before the changes take effect.

Continued use of the 78phpearl platform after the effective date of an updated Privacy Policy constitutes acceptance of the revised terms. If you do not agree with material changes to the Policy, you should cease using the platform and request account closure prior to the effective date.

We encourage all players to review this Privacy Policy periodically to stay informed about how 78phpearl protects their personal data.

78phpearl has designated a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012 and NPC regulations. The DPO is responsible for overseeing 78phpearl's compliance with data privacy obligations and serving as the primary point of contact for player data privacy inquiries.

To exercise your data subject rights, submit a data privacy complaint, or request information about 78phpearl's data processing practices, please contact us through the following channels:

• Customer Support (General): Available 24/7 via live chat on the 78phpearl platform.
• Data Privacy Inquiries (Email): [email protected] — please include "Data Privacy Request" in the subject line.
• Response Commitment: 78phpearl will acknowledge all privacy requests within five (5) business days and provide a substantive response within thirty (30) days.

If you are not satisfied with our response to a data privacy concern, you have the right to escalate the matter to the National Privacy Commission of the Philippines through the NPC's official complaint process.