nnn7 Privacy Policy

1 Data Controller

nnn7 ("the Company," "we," "us," or "our") is the data controller responsible for the personal data collected through the nnn7 Platform at nnn7.app. As data controller, nnn7 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

For all data privacy inquiries, you may contact our Data Protection Officer (DPO) at: [email protected]

2 Data We Collect

nnn7 collects the following categories of personal data:

2.1 Identity Data: Full legal name, date of birth, nationality, and government-issued ID details (e.g., PhilSys ID number, passport number, driver's license number) collected during account registration and KYC verification.

2.2 Contact Data: Philippine mobile number, email address, and residential address.

2.3 Financial Data: GCash mobile number, PayMaya account details, bank account name and number (BPI, BDO, Metrobank), and transaction history on the nnn7 Platform. nnn7 does not store full card numbers or online banking passwords.

2.4 Account Data: Username, account balance, betting history, bonus usage, session logs, and responsible gaming settings.

2.5 Technical Data: IP address, device type, browser type and version, operating system, and cookies. This data is collected automatically when you access the nnn7 Platform.

2.6 Communications Data: Records of your interactions with nnn7 support, including live chat transcripts and email correspondence.

3 How We Collect Data

nnn7 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical data collected automatically through cookies, server logs, and similar technologies when you access the nnn7 Platform.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment confirmation data from GCash, PayMaya, and banking partners.

4 How We Use Your Data

nnn7 uses your personal data for the following purposes:

• To create, verify, and manage your nnn7 Account;
• To process deposits, withdrawals, and other financial transactions in Philippine Peso;
• To verify your identity and age (21+) in compliance with PAGCOR regulations;
• To detect and prevent fraud, money laundering, and other prohibited activities;
• To provide customer support and respond to your inquiries;
• To administer bonuses, promotions, and loyalty programs;
• To send transactional communications (e.g., deposit confirmations, withdrawal notifications, security alerts);
• To send promotional communications, where you have consented to receive them;
• To comply with applicable Philippine laws, PAGCOR regulations, and regulatory directives;
• To improve the nnn7 Platform through analysis of aggregated, anonymized usage data.

5 Legal Basis for Processing

nnn7 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to fulfill our obligations under the nnn7 Terms and Conditions, including account management and payment processing;
• Legal obligation: Processing required to comply with PAGCOR regulations, AML laws, and other applicable Philippine legal requirements;
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent.

6 Data Sharing and Disclosure

nnn7 does not sell your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and InstaPay partners, solely to process your financial transactions;
• KYC and identity verification providers: Third-party services used to verify your identity and age in compliance with PAGCOR requirements;
• AML and fraud screening services: Compliance partners used to detect and prevent money laundering and fraudulent activity;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where required by law or regulatory directive;
• IT and platform service providers: Cloud hosting, security, and analytics vendors who process data on our behalf under strict data processing agreements;
• Legal and professional advisors: Lawyers, auditors, and consultants bound by professional confidentiality obligations.

All third-party service providers engaged by nnn7 are required to implement appropriate technical and organizational measures to protect your personal data.

7 Cookies and Tracking

7.1 What We Use. nnn7 uses the following types of cookies on the Platform:

• Strictly necessary cookies: Required for the Platform to function, including session authentication and security tokens. These cannot be disabled.
• Performance cookies: Collect anonymized data on how players use the Platform (e.g., pages visited, time on site) to help us improve performance. No personally identifiable information is collected.
• Functional cookies: Remember your preferences such as language settings and responsible gaming limits.

7.2 What We Do Not Use. nnn7 does not use third-party advertising or tracking cookies. We do not participate in cross-site behavioral advertising networks.

7.3 Managing Cookies. You can manage or disable non-essential cookies through your browser settings. Note that disabling strictly necessary cookies may affect the functionality of the nnn7 Platform.

8 Data Retention

nnn7 retains your personal data for as long as your Account is active and for a period thereafter as required by applicable law. Specifically:

• Account and transaction data: Retained for a minimum of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements and AML regulations;
• KYC documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later;
• Support communications: Retained for two (2) years from the date of the interaction;
• Technical and log data: Retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with nnn7's data disposal procedures.

9 Data Security

nnn7 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the nnn7 Platform;
• Encryption of sensitive data at rest, including financial information and KYC documents;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform;
• Two-factor authentication (2FA) available for all player accounts.

While nnn7 takes all reasonable steps to protect your data, no internet transmission or electronic storage system is completely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, nnn7 will notify the National Privacy Commission and affected players in accordance with the requirements of RA 10173.

10 Your Rights Under RA 10173

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 nnn7:

• Right to be informed: The right to know what personal data nnn7 collects and how it is used — as set out in this Privacy Policy;
• Right of access: The right to request a copy of the personal data nnn7 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 nnn7's legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes;
• 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) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. nnn7 will respond to verified requests within thirty (30) days.

11 Children's Privacy

The nnn7 Platform is strictly intended for individuals aged 21 years and above. nnn7 does not knowingly collect personal data from persons under 21 years of age. If we become aware that personal data has been collected from a person under 21, we will immediately close the associated account and delete all related personal data. If you believe a minor has registered on the nnn7 Platform, please contact us immediately at [email protected].

12 Changes to This Policy

nnn7 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or regulatory guidance. Material changes will be communicated to registered players via email or an in-platform notification at least seven (7) days before taking effect. The "Last updated" date at the top of this page will always reflect the most recent revision. Continued use of the nnn7 Platform after the effective date of any update constitutes acceptance of the revised Privacy Policy.

13 Contact and Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact the nnn7 Data Protection Officer:

• Email: [email protected]
• Live Chat: Available 24/7 through the nnn7 Platform

If you are not satisfied with nnn7's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). nnn7 is committed to working cooperatively with the NPC to resolve any complaints regarding our data processing practices.