sand77 Privacy Policy

1. Introduction

sand77 ("sand77," "we," "us," or "our") is committed to protecting the privacy and personal data of all players and visitors who use the sand77 online gaming platform at sand77.xyz and any associated mobile applications (collectively, the "Platform"). This Privacy Policy describes how sand77 collects, uses, discloses, stores, and protects your personal information in connection with your use of the Platform.

This Privacy Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines. By registering an account or using the sand77 Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

This Privacy Policy should be read together with the sand77 Terms & Conditions and Responsible Gaming Policy, each of which is incorporated by reference.

2. Data We Collect

2.1 Information You Provide Directly

When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in promotions on sand77, we collect personal information that you provide directly, including:

• Identity data: Full legal name, date of birth, gender, nationality;
• Contact data: Email address, mobile number, residential address (including city, province, and postal code);
• Identity verification data: Government-issued ID number and type (e.g., Philippine National ID, passport, driver's license, SSS/GSIS ID, voter's ID), selfie or photo for liveness verification;
• Financial data: GCash or Maya account details, bank account details (for bank transfer transactions), transaction history on the sand77 Platform;
• Account data: Username, encrypted password, account preferences, responsible gaming settings;
• Communications data: Records of your correspondence with sand77 support, including live chat transcripts and email exchanges.

2.2 Information Collected Automatically

When you access the sand77 Platform, we automatically collect certain technical and usage data, including:

• Device data: IP address, device type, operating system, browser type and version;
• Usage data: Pages visited, games played, session duration, betting history, login timestamps;
• Location data: General geographic location derived from your IP address (country and city level);
• Cookie data: Data collected via cookies and similar tracking technologies as described in Section 6.

2.3 Information from Third Parties

sand77 may receive personal data about you from third parties in limited circumstances, including identity verification service providers, payment processors (e.g., GCash, Maya, partner banks), and fraud prevention services. Such data is used solely for the purposes described in this Privacy Policy.

3. How We Use Your Data

sand77 uses your personal data for the following purposes:

• Account management: To register and maintain your sand77 player account, verify your identity, and manage your account settings;
• Service delivery: To provide access to games, process deposits and withdrawals, and deliver the features of the sand77 Platform;
• KYC and AML compliance: To verify your identity and comply with anti-money laundering (AML) obligations under Philippine law and PAGCOR regulations;
• Responsible gaming: To monitor gaming activity, enforce responsible gaming limits and self-exclusion requests, and identify players who may be at risk of problem gambling;
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance;
• Promotions and marketing: To send you information about sand77 promotions, bonuses, and offers where you have consented to receive such communications;
• Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, cheating, and other prohibited conduct on the Platform;
• Legal compliance: To comply with applicable laws, regulations, and regulatory directives, including those issued by PAGCOR and the NPC;
• Platform improvement: To analyze usage patterns and improve the functionality, performance, and user experience of the sand77 Platform.

4. Legal Basis for Processing

sand77 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing is necessary to perform the contract between you and sand77 (i.e., the Terms & Conditions), including account registration, game access, and payment processing;
• Legal obligation: Processing is necessary to comply with legal obligations applicable to sand77, including KYC/AML requirements under Philippine law and PAGCOR regulations;
• Legitimate interests: Processing is necessary for sand77's legitimate interests, including fraud prevention, security, and Platform improvement, where such interests are not overridden by your rights and interests;
• Consent: Where sand77 relies on your consent as the legal basis for processing (e.g., for marketing communications), you have the right to withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

5. Sharing Your Data

5.1 Service Providers

sand77 shares personal data with trusted third-party service providers who assist in operating the Platform, including identity verification providers, payment processors, cloud hosting providers, customer support platforms, and analytics providers. All service providers are contractually required to process personal data only on sand77's instructions and to maintain appropriate security measures.

5.2 Regulatory and Law Enforcement Authorities

sand77 may disclose personal data to PAGCOR, the NPC, the Anti-Money Laundering Council (AMLC), law enforcement agencies, or other government authorities where required by law, court order, or regulatory directive. sand77 will notify affected players of such disclosures where permitted by law.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of sand77's assets, personal data held by sand77 may be transferred to the acquiring entity. Players will be notified of any such transfer and any material changes to this Privacy Policy that result from it.

5.4 No Sale of Personal Data

sand77 does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. Any sharing of personal data is limited to the purposes described in this Privacy Policy.

6. Cookies & Tracking Technologies

6.1 What Are Cookies

Cookies are small text files placed on your device when you visit the sand77 Platform. sand77 uses cookies and similar tracking technologies (such as web beacons and local storage) to operate the Platform, remember your preferences, analyze usage, and support security features.

6.2 Types of Cookies Used

• Strictly necessary cookies: Required for the Platform to function, including session management and security. These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language, responsible gaming settings) to personalize your experience.
• Analytics cookies: Collect anonymized data about how players use the Platform to help sand77 improve its services.
• Marketing cookies: Used to deliver relevant promotions and measure the effectiveness of sand77's marketing campaigns, where you have consented.

6.3 Managing Cookies

You can manage or disable cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the sand77 Platform. For more information on managing cookies, refer to your browser's help documentation.

7. Data Retention

sand77 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements. Specifically:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements;
• Transaction data: Retained for a minimum of five (5) years from the date of the transaction;
• KYC documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction;
• Support communications: Retained for a minimum of two (2) years from the date of the communication;
• Marketing data: Retained until you withdraw your consent to receive marketing communications.

Upon expiry of the applicable retention period, sand77 will securely delete or anonymize your personal data in accordance with its data disposal procedures.

8. Your Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by sand77:

• Right to be informed: The right to be informed of how your personal data is collected and processed;
• Right of access: The right to request a copy of the personal data sand77 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 sand77's legal retention obligations;
• Right to object: The right to object to the processing of your personal data on grounds relating to your particular situation, including processing 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 lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact sand77's Data Protection Officer at [email protected]. sand77 will respond to your request within the timeframes prescribed by the Data Privacy Act and NPC regulations.

9. Data Security

sand77 implements appropriate technical and organizational 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 sand77 Platform;
• Encryption of sensitive data at rest, including financial data and identity documents;
• Access controls limiting personal data access to authorized sand77 personnel on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform;
• Employee training on data privacy and security obligations.

10. Children's Privacy

The sand77 Platform is strictly intended for persons aged 21 years and above, in accordance with PAGCOR regulations governing online gaming in the Philippines. sand77 does not knowingly collect personal data from persons under the age of 21. If sand77 becomes aware that it has inadvertently collected personal data from a person under the age of 21, it will take immediate steps to delete such data from its records.

If you are a parent or guardian and believe that your child has provided personal data to sand77, please contact us immediately at [email protected] so that we can take appropriate action.

11. Third-Party Links

The sand77 Platform may contain links to third-party websites or services for informational purposes. sand77 is not responsible for the privacy practices or content of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit. This Privacy Policy applies solely to personal data collected by sand77 through the sand77 Platform.

12. Changes to This Policy

sand77 reserves the right to update or amend this Privacy Policy at any time. Where changes are material, sand77 will provide reasonable notice to registered players via email or a prominent notice on the Platform prior to the changes taking effect. The date of the most recent revision is indicated at the top of this page.

Your continued use of the sand77 Platform following the effective date of any amendment constitutes your acceptance of the revised Privacy Policy. If you do not agree to the amended Policy, you must cease using the Platform and may close your account in accordance with the Terms & Conditions.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or sand77's handling of your personal data, please contact our Data Protection Officer: