Privacy Policy – sm77 Philippines

1. About This Privacy Policy

This Privacy Policy ("Policy") is issued by sm77 ("sm77," "we," "our," or "us") and governs the collection, use, storage, and disclosure of personal data provided by users ("Player," "you," or "your") of the sm77 website located at sm77.asia and all related services.

sm77 is committed to protecting the privacy of all Filipino players in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations. By registering an account or using any sm77 service, you consent to the practices described in this Policy.

This Policy should be read together with the sm77 Terms & Conditions, which govern the overall use of the sm77 platform.

2. Personal Data We Collect

sm77 collects the following categories of personal data from players:

Identity and Contact Data:

• Full name as it appears on a valid Philippine government-issued ID;
• Date of birth (for age verification — players must be 21 or older);
• Philippine mobile number (primary account identifier);
• Email address (if provided during registration or communications);
• Residential address.

Identity Verification Data (KYC):

• Government-issued ID document images (e.g., PhilSys ID, passport, driver's licence, SSS/GSIS ID, PRC ID, voter's ID);
• Selfie photograph for live identity verification;
• Source of funds documentation where required by Philippine anti-money laundering regulations.

Financial Data:

• GCash or Maya account reference number;
• Bank account details (for bank transfer withdrawals — BPI, BDO, Metrobank, UnionBank);
• Transaction history including deposits, withdrawals, and wager records.

Technical and Usage Data:

• IP address and approximate geolocation;
• Device type, browser type, and operating system;
• Session duration, pages visited, and game activity logs;
• Login history and device identifiers.

3. How We Collect Your Data

sm77 collects personal data through the following means:

• Account Registration: When you create your sm77 account, you provide identity and contact information directly;
• KYC Verification: When you submit identification documents for account verification prior to withdrawal;
• Transactions: When you make deposits or request withdrawals via GCash, Maya, BPI, BDO, or other supported Philippine payment channels;
• Platform Use: Automatically as you navigate and interact with sm77 games, including through cookies and server logs;
• Communications: When you contact sm77 customer support via live chat or email;
• Third-Party Payment Processors: Transaction confirmation data from GCash, Maya, and integrated banking channels.

4. How We Use Your Personal Data

sm77 uses the personal data collected for the following purposes:

• Account Management: To create, maintain, and secure your sm77 player account;
• Age and Identity Verification: To confirm that you meet the minimum age requirement of 21 years, in compliance with PAGCOR regulations and Philippine gaming laws;
• Payment Processing: To facilitate GCash, Maya, and bank transfer deposits and withdrawals in Philippine Peso;
• Legal Compliance: To meet our obligations under the Philippine Data Privacy Act, Anti-Money Laundering Act (AMLA), and PAGCOR regulatory requirements;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and abuse of platform terms;
• Customer Support: To respond to your inquiries and resolve disputes through the sm77 24/7 live chat support system;
• Responsible Gaming: To monitor gaming activity patterns and identify players who may need responsible gaming interventions or support;
• Platform Improvement: To analyze usage data and improve the sm77 platform experience for all Filipino players;
• Promotional Communications: To send relevant promotional offers and updates, where you have provided consent — you may withdraw consent at any time through your account settings.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, sm77 processes your personal data on the following legal grounds:

• Contractual Necessity: Processing required to fulfil the sm77 Terms & Conditions and provide the services you have registered for;
• Legal Obligation: Processing required to comply with Philippine laws including the AMLA, PAGCOR regulations, and the Data Privacy Act itself;
• Legitimate Interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your privacy rights;
• Consent: Processing for direct marketing communications, where you have explicitly consented.

6. Sharing Your Personal Data

sm77 may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash (G-Xchange, Inc.), Maya (Voyager Innovations), BPI, BDO, Metrobank, UnionBank, and other Philippine payment service providers, for the purpose of processing your financial transactions;
• KYC and Identity Verification Partners: Third-party identity verification providers engaged to assist with document authentication;
• Regulatory Authorities: The Philippine National Privacy Commission (NPC), PAGCOR, the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where required by law;
• IT and Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers operating under strict data processing agreements;
• Legal and Compliance Advisors: In connection with legal proceedings, dispute resolution, or regulatory investigations.

All third parties with whom sm77 shares personal data are required to maintain appropriate security standards and may only use the data for the specific purpose for which it was shared.

7. Data Retention

sm77 retains your personal data for as long as your account remains active and for a minimum period thereafter as required by Philippine law:

• Account and transaction records: Retained for a minimum of five (5) years following account closure, in compliance with Philippine AMLA requirements;
• KYC documents: Retained for the duration of your account and for five (5) years after account closure;
• Customer support communications: Retained for two (2) years;
• Technical and usage logs: Retained for twelve (12) months, after which they are anonymized or deleted.

Following the expiry of applicable retention periods, sm77 will securely delete or anonymize your personal data in accordance with our data destruction procedures.

8. Cookies and Tracking Technologies

The sm77 platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and analyze platform usage. The following types of cookies are used:

• Essential Cookies: Required for the sm77 platform to function — these include session authentication cookies and security tokens. These cannot be disabled without affecting platform functionality;
• Analytics Cookies: Used to collect aggregated, anonymized data about how Filipino players navigate the sm77 platform, for the purpose of improving user experience;
• Preference Cookies: Used to remember your language, display, and session preferences between visits.

You may manage cookie preferences through your browser settings. Note that disabling essential cookies may prevent you from logging in to your sm77 account.

9. Data Security

sm77 implements industry-standard technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction:

• All data transmitted between your device and sm77 servers is encrypted using TLS/SSL protocols;
• Account access is protected by password hashing, two-factor authentication, and anomalous login detection;
• Payment data is processed through PCI-DSS compliant payment gateways — sm77 does not store full card numbers;
• Access to personal data within sm77 is restricted to authorized personnel on a strict need-to-know basis;
• Regular security audits and penetration tests are conducted on sm77 infrastructure.

While sm77 employs best-practice security measures, no internet transmission can be guaranteed to be completely secure. In the event of a data breach that is likely to result in a risk to your rights and freedoms, sm77 will notify the Philippine National Privacy Commission and affected players in accordance with the Data Privacy Act.

10. Your Rights as a Data Subject

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by sm77:

• Right to be Informed: The right to know that your personal data is being collected and processed, and for what purposes;
• Right of Access: The right to request a copy of the personal data sm77 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, subject to legal retention obligations;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Object: The right to object to processing of your personal data for direct marketing purposes;
• Right to Lodge a Complaint: The right to file a complaint with the Philippine National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of the above rights, please contact sm77 via the 24/7 live chat on the platform or by email at [email protected]. sm77 will respond to verified data subject requests within fifteen (15) business days.

11. Children's Privacy

The sm77 platform is strictly intended for adults aged 21 years and older only. sm77 does not knowingly collect personal data from individuals under the age of 21. If sm77 becomes aware that a minor has created an account or provided personal data, that account will be immediately suspended and all associated data will be deleted.

Parents or guardians who believe a minor may have accessed sm77 should contact our support team via live chat immediately for prompt action.

12. Changes to This Policy

sm77 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform features. The date of the most recent revision is displayed at the top of this page.

Material changes to this Policy will be communicated to registered sm77 players via a notification on the platform. Your continued use of sm77 following the posting of a revised Privacy Policy constitutes your acceptance of the updated terms.

13. Contact Our Data Protection Officer

For privacy-related inquiries, data subject rights requests, or concerns about how sm77 handles your personal data, please contact our Data Protection Officer:

sm77 Data Protection Officer
Email: [email protected]
Live Chat: Available 24/7 via the sm77 platform

sm77 is committed to resolving all privacy concerns promptly and transparently. You also have the right to escalate unresolved privacy complaints to the Philippine National Privacy Commission (NPC) through their official channels.