ra77 Privacy Policy

This Privacy Policy ("Policy") describes how ra77 ("ra77," "we," "us," or "our") collects, uses, stores, shares, and protects the personal information of players and visitors ("you" or "your") who access or use the ra77 online gaming platform at ra77.club and any associated mobile applications or services (collectively, the "Platform").

ra77 is committed to protecting your privacy and handling your personal data responsibly. This Policy is designed to give you a clear and honest picture of our data practices so you can make informed decisions about your use of the Platform.

This Policy should be read together with ra77's Terms and Conditions and Responsible Gaming Policy, both of which are incorporated by reference. In the event of any conflict between this Policy and the Terms and Conditions on matters of data privacy, this Policy shall prevail.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, ra77 acts as the Personal Information Controller (PIC) in respect of the personal data collected through the Platform.

As a Personal Information Controller, ra77 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently in accordance with applicable Philippine data protection law.

ra77 has designated a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. You may contact the DPO using the details provided in Section 15 of this Policy.

ra77 collects personal data from you in several ways — directly when you provide it to us, automatically when you use the Platform, and occasionally from third-party sources. The categories of personal data we collect include:

ra77 uses your personal data only for legitimate, specified purposes directly related to the operation of the Platform and our obligations under Philippine law. The primary purposes for which we process your personal data are:

• Account Management: To create, maintain, and administer your ra77 player account, including verifying your identity and eligibility to use the Platform.
• Service Delivery: To provide you with access to ra77's games, promotions, and features, and to process your deposits, withdrawals, and wagers.
• KYC & AML Compliance: To verify your identity, age (21+), and the source of your funds in compliance with Philippine anti-money laundering laws and PAGCOR regulatory requirements.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the Platform and its players.
• Customer Support: To respond to your inquiries, complaints, and support requests in a timely and effective manner.
• Responsible Gaming: To monitor gaming patterns and identify players who may be at risk of problem gambling, and to administer self-exclusion and deposit limit requests.
• Legal & Regulatory Compliance: To comply with applicable Philippine laws, regulations, court orders, and the requirements of regulatory authorities including PAGCOR and the National Privacy Commission.
• Platform Improvement: To analyze usage patterns and technical performance data to improve the functionality, reliability, and user experience of the Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided your consent to receive such communications, which you may withdraw at any time.

ra77 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise permitted by applicable law.

Under the Philippine Data Privacy Act of 2012, ra77 is required to have a lawful basis for each instance of personal data processing. The legal bases on which ra77 relies are:

• Contractual Necessity: Processing is necessary for the performance of the contract between you and ra77 — specifically, to provide you with access to the Platform and its services in accordance with our Terms and Conditions.
• Legal Obligation: Processing is necessary for ra77 to comply with its legal and regulatory obligations under Philippine law, including AML regulations, PAGCOR licensing requirements, and the Data Privacy Act itself.
• Legitimate Interests: Processing is necessary for ra77's legitimate business interests, including fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and interests.
• Consent: For certain processing activities — particularly direct marketing communications — ra77 relies on your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

ra77 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to the extent necessary to process your deposits and withdrawals.
• Game Providers: Third-party game studios and live dealer operators whose games are available on the ra77 Platform, where technically necessary for game delivery and fairness verification.
• Identity Verification Services: Third-party KYC and AML compliance providers engaged to assist ra77 in verifying player identities and screening for financial crime risks.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where required by law or regulatory direction.
• Law Enforcement: Philippine law enforcement agencies, where ra77 is legally required or permitted to disclose personal data in connection with the investigation or prosecution of criminal activity.
• IT & Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers engaged by ra77 to operate and secure the Platform, subject to strict contractual data protection obligations.
• Professional Advisers: Lawyers, auditors, and accountants engaged by ra77, subject to professional confidentiality obligations.

ra77 uses cookies and similar tracking technologies to operate the Platform, remember your preferences, analyze usage patterns, and support our security and fraud prevention measures. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function correctly. These include session authentication cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Used to remember your preferences such as language settings, display preferences, and responsible gaming tool configurations.
• Analytics Cookies: Used to collect aggregated, anonymized data about how players use the Platform, helping ra77 identify areas for improvement. These do not identify you personally.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and other security threats.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. ra77 does not use third-party advertising or behavioral tracking cookies.

ra77 retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

Upon expiry of the applicable retention period, ra77 will securely delete or anonymize your personal data in accordance with our data disposal procedures. Where anonymization is not technically feasible, data will be securely destroyed.

ra77 implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and ra77's servers.
• Encryption of sensitive data at rest, including financial data and identity documents, using industry-standard encryption algorithms.
• Multi-factor authentication requirements for access to ra77's internal systems by authorized personnel.
• Regular penetration testing and vulnerability assessments conducted by independent cybersecurity specialists.
• Strict role-based access controls ensuring that personal data is accessible only to personnel with a legitimate need.
• Comprehensive audit logging of all access to personal data by ra77 personnel.
• Regular staff training on data protection obligations and security best practices.
• An incident response plan for the detection, containment, and notification of personal data breaches in accordance with NPC requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ra77 will notify the National Privacy Commission and affected players in accordance with the timelines and requirements prescribed by the Data Privacy Act and NPC regulations.

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ra77. These rights are subject to certain limitations and exceptions as provided by applicable law.

To exercise any of these rights, please contact ra77's Data Protection Officer using the contact details in Section 15. ra77 will respond to all verified data subject requests within fifteen (15) calendar days of receipt, or within such extended period as permitted by applicable law where the request is complex or numerous.

ra77 may need to verify your identity before processing a data subject request to ensure that personal data is not disclosed to unauthorized parties. We will not charge a fee for processing reasonable requests.

The ra77 Platform is strictly intended for use by persons who are 21 years of age or older, in accordance with Philippine gaming regulations applicable to casino-style gaming activities. ra77 does not knowingly collect personal data from persons under the age of 21.

ra77 employs age verification procedures during the registration process and may request additional documentation to confirm a player's age at any point. Providing false information about your age constitutes a material breach of ra77's Terms and Conditions.

In the course of operating the Platform, ra77 may transfer your personal data to service providers or partners located outside the Philippines — for example, cloud infrastructure providers or international game studios. Where such transfers occur, ra77 ensures that appropriate safeguards are in place to protect your personal data in accordance with the Data Privacy Act of 2012 and NPC regulations.

Safeguards for cross-border transfers may include:

• Contractual clauses requiring the recipient to process personal data to a standard equivalent to that required under Philippine law.
• Transfers only to countries or organizations that the NPC has determined provide an adequate level of data protection.
• Binding corporate rules where data is transferred within a corporate group.

You may request further information about the safeguards applicable to any specific cross-border transfer by contacting ra77's Data Protection Officer.

The ra77 Platform may contain references to or integrations with third-party services — such as payment gateways and game providers — that operate under their own privacy policies. ra77 is not responsible for the privacy practices of these third parties and encourages you to review their respective privacy policies before providing any personal data directly to them.

ra77 does not control the content, data practices, or security measures of any third-party service and accepts no liability for any loss or damage arising from your use of or reliance on any third-party service accessed through or in connection with the Platform.

ra77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When we make material changes to this Policy, we will notify you by posting a prominent notice on the Platform and, where we hold a valid email address for you, by sending you a direct notification.

The updated Policy will take effect from the date indicated in the "Last Updated" notice at the top of this page. Your continued use of the Platform following the effective date of any updated Policy constitutes your acceptance of the revised terms. If you do not agree with the changes, you should discontinue use of the Platform and may request closure of your account.

ra77 recommends that you review this Privacy Policy periodically to stay informed of how we are protecting your personal data. All previous versions of this Policy are available upon request from our Data Protection Officer.

If you have any questions, concerns, or requests relating to this Privacy Policy or ra77's handling of your personal data, please contact our Data Protection Officer using the details below:

ra77 will acknowledge receipt of your inquiry within three (3) business days and will endeavor to resolve your concern within fifteen (15) calendar days. For complex matters, we will keep you informed of progress and provide a final response within thirty (30) calendar days.

If you are not satisfied with ra77's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory authority responsible for administering and enforcing the Data Privacy Act of 2012. Information about how to file a complaint with the NPC is available on the NPC's official website.