sunny77 Privacy Policy

1 Who We Are

sunny77 is an online casino and sports betting platform operating at https://sunny77.bio, offering Filipino players access to over 3,200 gaming products including live casino games, slots, bingo, sports betting, and e-sabong. sunny77 serves players across the Philippines, including Metro Manila, Cebu, Davao, Quezon City, Makati, and other regions nationwide.

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, sunny77 acts as the Personal Information Controller in respect of data collected through its platform. This means we are responsible for determining the purposes and means of processing your personal data.

If you have any questions about this Policy or wish to exercise your data privacy rights, please contact our designated Data Protection Officer (DPO) using the details provided in Section 13.

2 Data We Collect

sunny77 collects personal data from you in several ways: directly when you register and use the platform, automatically through your use of our website, and occasionally from third-party sources. The categories of data we collect are outlined in the table below:

sunny77 does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where health-related disclosures are made voluntarily by a player in the context of a responsible gaming request (e.g., a self-exclusion request citing gambling addiction).

3 How We Use Your Data

sunny77 uses the personal data it collects for the following specific purposes. We only use your data where we have a lawful basis to do so, as described in Section 4.

• Account Creation and Management: To register your player account, verify your identity, and maintain accurate account records throughout your relationship with sunny77.
• Transaction Processing: To process deposits and withdrawals via GCash, Maya, BPI, BDO, Metrobank, UnionBank, 7-Eleven Cliqq, Coins.ph, and USDT TRC20, and to maintain accurate financial records of all transactions.
• Identity Verification (KYC): To comply with anti-money laundering (AML) obligations and PAGCOR requirements by verifying that all players are who they claim to be, are of legal age (21+), and are located in a permitted jurisdiction.
• Gaming Services: To provide access to all games and betting products available on the sunny77 platform, record gameplay outcomes, and resolve any disputes regarding game results.
• Customer Support: To respond to your queries, complaints, and support requests via live chat and email in a timely and accurate manner.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other illegal conduct on the platform.
• Responsible Gaming: To monitor gameplay patterns that may indicate problem gambling behavior, to apply responsible gaming tools such as deposit limits or self-exclusion, and to fulfill our duty of care obligations to players.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates via email or SMS — but only where you have opted in to receive such communications. You may opt out at any time.
• Platform Improvement: To analyze usage data and improve the functionality, performance, and design of the sunny77 platform for the benefit of all Filipino players.
• Legal and Regulatory Compliance: To meet our obligations under Philippine law, PAGCOR regulations, and any applicable court orders or regulatory requests.

4 Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, sunny77 relies on the following legal bases to process your personal data:

• Contractual Necessity: Processing your identity data, contact data, and financial data is necessary to perform our contract with you — i.e., to operate your account, process payments, and deliver gaming services.
• Legal Obligation: Processing for KYC verification, AML compliance, and PAGCOR regulatory reporting is required by Philippine law. We cannot provide services without fulfilling these requirements.
• Legitimate Interests: Processing technical data, usage data, and gaming data for fraud prevention, platform security, and service improvement is conducted on the basis of sunny77's legitimate business interests, provided these interests are not overridden by your privacy rights.
• Consent: Processing your data for direct marketing communications is based on your explicit opt-in consent. You may withdraw this consent at any time by contacting our support team or using the unsubscribe link in any marketing email.

5 Data Sharing & Third Parties

sunny77 does not sell, rent, or trade your personal data to third parties for commercial gain. We do, however, share your data with carefully selected third parties where necessary to operate the platform. All third-party processors are contractually required to process your data only for the specified purpose and to implement appropriate security measures.

The categories of third parties with whom sunny77 may share your data include:

• Game Providers: Licensed third-party studios such as Pragmatic Play, PG Soft, and Evolution Gaming receive anonymized or pseudonymized session data necessary to deliver games and resolve technical disputes.
• Payment Processors: GCash, Maya, BPI, BDO, Metrobank, UnionBank, 7-Eleven Cliqq, Coins.ph, and USDT TRC20 providers receive the minimum financial data necessary to process your deposit and withdrawal requests.
• KYC and Identity Verification Providers: sunny77 uses certified third-party KYC service providers to verify government-issued IDs and conduct liveness checks. These providers operate under strict data processing agreements.
• Analytics Providers: Anonymized or aggregated usage data may be shared with analytics platforms to help us understand how Filipino players use the sunny77 platform and identify areas for improvement.
• Regulatory and Law Enforcement Authorities: sunny77 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or any competent law enforcement authority where required by law, court order, or regulatory directive.
• Fraud Prevention Networks: sunny77 may share data with industry-wide fraud prevention databases to prevent multi-platform abuse, bonus fraud, and identity fraud.

6 Cookies & Tracking Technologies

sunny77 uses cookies and similar tracking technologies to operate the platform effectively and enhance your gaming experience. The types of cookies we use are:

• Essential Cookies: Required for the platform to function. These include session cookies that maintain your login state, security cookies that prevent cross-site request forgery (CSRF), and load-balancing cookies. These cannot be disabled without impairing platform functionality.
• Functional Cookies: Remember your preferences such as language settings, preferred display options, and game lobby filters. Disabling these may reduce convenience but will not prevent access to the platform.
• Analytics Cookies: Collect anonymized data about how users navigate the platform, which games are most popular, and how long sessions last. This data helps us improve the sunny77 experience for all Filipino players.
• Marketing Cookies: Used only where you have consented, to track which promotional content you have engaged with and to avoid showing you the same offer repeatedly.

You can manage your cookie preferences through your web browser settings. Most modern browsers allow you to block or delete cookies, though doing so may affect essential platform functionality. Please note that our platform does not currently respond to "Do Not Track" browser signals.

7 Data Retention

sunny77 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and PAGCOR regulations. The general retention periods that apply to your data are as follows:

• Account and Identity Data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements under RA 9160 as amended.
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations and AMLC reporting obligations.
• Gaming History: Retained for a minimum of two (2) years to enable dispute resolution and regulatory auditing.
• Customer Support Communications: Retained for two (2) years from the date of the most recent interaction in a support case.
• Marketing Consent Records: Retained for the duration of your account plus three (3) years following account closure, to demonstrate compliance with consent obligations.
• KYC Verification Documents: Retained for the duration of the account plus five (5) years, as required by PAGCOR and AML legislation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with sunny77's data destruction procedures. Anonymized data (which can no longer be used to identify you) may be retained indefinitely for statistical and analytical purposes.

8 Data Security

sunny77 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• SSL/TLS Encryption: All data in transit between your browser or mobile device and the sunny77 platform is encrypted using TLS 1.2 or higher.
• Data Encryption at Rest: Sensitive data fields — including financial account references and government ID numbers — are encrypted at the database level using AES-256 encryption.
• Two-Factor Authentication (2FA): sunny77 offers SMS-based 2FA to add an additional layer of protection to your account login. We strongly recommend enabling this feature via your account security settings.
• Access Controls: Access to personal data within sunny77's systems is restricted to authorized personnel on a strict need-to-know basis. All internal access is logged and audited.
• Penetration Testing: sunny77 conducts regular security assessments and penetration tests of its platform to identify and remediate vulnerabilities before they can be exploited.
• Incident Response: sunny77 maintains a documented data breach response plan. In the event of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify the National Privacy Commission (NPC) and affected users within the timeframe required by law.

While sunny77 takes all reasonable steps to protect your data, no online system is completely immune to security risks. You also play a role in keeping your account secure — please use a strong, unique password for your sunny77 account and never share your login credentials with anyone.

9 Your Privacy Rights

As a data subject under the Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by sunny77:

• Right to Be Informed: You have the right to be informed about how your personal data is being processed. This Privacy Policy fulfils that obligation.
• Right to Access: You have the right to obtain a copy of the personal data sunny77 holds about you, along with information about how it is processed. Requests will be fulfilled within 30 days.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data. You may update most account details directly via your account profile; for KYC data, please contact support.
• Right to Erasure: You have the right to request deletion of your personal data. Please note that this right is subject to legal retention obligations — we cannot delete data we are legally required to retain.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, though we may be able to demonstrate compelling grounds to continue processing in certain cases.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: If you believe your data privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission of the Philippines at https://privacy.gov.ph.

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 13. We may need to verify your identity before processing any request to protect against unauthorized access to your data.

10 Children's Privacy

sunny77 does not knowingly collect, process, or retain personal data from individuals under the age of 21. Our registration process includes age verification steps designed to prevent underage registration. Where sunny77 discovers or has reasonable grounds to suspect that a registered user is under 21 years of age, we will immediately:

• Suspend the account pending age verification;
• Withhold any balance pending investigation;
• Delete or anonymize all personal data associated with the account upon confirmation of underage status;
• Refuse any withdrawal request and report the matter to relevant authorities where required by law.

Parents or guardians who have reason to believe that a minor has accessed or registered on the sunny77 platform are strongly encouraged to contact our support team immediately via live chat or email.

11 International Data Transfers

sunny77 primarily stores and processes personal data within servers located in Asia-Pacific jurisdictions. In some circumstances, your personal data may be transferred to or accessible by our third-party service providers operating outside the Philippines — for example, game providers or technology partners whose infrastructure is located in other countries.

Where such international transfers occur, sunny77 ensures that appropriate safeguards are in place to protect your data to a standard that is at least equivalent to the protections afforded under the Data Privacy Act of 2012. These safeguards may include:

• Data processing agreements incorporating standard contractual clauses;
• Transfers to jurisdictions recognized by the National Privacy Commission as providing adequate levels of data protection;
• Binding corporate rules where applicable within our corporate group.

By using the sunny77 platform, you acknowledge and consent to the potential transfer of your personal data to jurisdictions outside the Philippines where necessary to deliver the services you have requested, subject to the safeguards described above.

12 Updates to This Privacy Policy

sunny77 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. The following process applies when updates are made:

• The "Last Updated" date displayed at the top of this page will be revised to reflect the date of the most recent changes.
• For material changes that significantly affect how we use your personal data, we will notify registered users via email to the address on file and/or via a prominent notice on the sunny77 platform, at least seven (7) days before the changes take effect where practicable.
• Minor administrative updates — such as corrections of typographical errors or clarifications that do not alter the substantive meaning of any provision — may be made without prior notice.
• Your continued use of the sunny77 platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not accept the changes, you must cease using the platform and may close your account.

We encourage you to review this Privacy Policy periodically to stay informed about how sunny77 protects your personal information.

13 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or sunny77's handling of your personal data, please contact us through any of the following channels:

• Live Chat: Available 24/7 via the support widget on the sunny77 platform — the fastest way to reach our team for account-related privacy queries.
• Email (Data Privacy Requests): [email protected] — please include "Privacy Request" in the subject line along with your registered username to help us process your request promptly. Allow up to 3 business days for a response to general queries and up to 30 days for formal data subject access requests.

When contacting us about a privacy matter, please provide your full registered name, email address, and a clear description of your request or concern. We may need to verify your identity before acting on any request to ensure that we do not disclose or modify your data in response to an unauthorized request.