sm777 Privacy Policy

This Privacy Policy applies to all personal data processed by sm777 in connection with the sm777 Platform accessible at sm777.bid (including its mobile application and any related digital interfaces). It governs data collected from registered players, prospective registrants, visitors, and any individual who interacts with the Platform.

sm777 is the personal information controller as defined under Republic Act No. 10173 (the "Data Privacy Act" or "DPA") and its Implementing Rules and Regulations (IRR). sm777 is registered with the National Privacy Commission (NPC) of the Philippines in accordance with its obligations as a personal information controller processing personal data of Philippine residents.

By registering an Account on the sm777 Platform or continuing to use the Platform after this Policy has been made available to you, 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.

sm777 collects the minimum personal data necessary to provide a safe, compliant, and functional gaming service. The categories of data we collect, and the circumstances in which we collect them, are set out below.

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, time zone setting.
• Usage Data: Pages visited, games played, session duration, bet history, bonus activity, login timestamps, and click patterns.
• Location Data: Approximate geolocation derived from IP address, used for fraud detection and regulatory compliance. Precise GPS location is not collected.
• Cookie Data: Identifiers set by cookies and similar technologies as described in Section 6 of this Policy.

sm777 may receive limited personal data about you from third parties in specific circumstances: from payment processors (GCash, PayMaya, banks) to confirm the status of financial transactions; from identity verification service providers used to cross-check KYC document authenticity; and from fraud prevention partners who flag potentially fraudulent activity associated with an IP address or device fingerprint.

sm777 uses personal data only for the specific, declared purposes described in this Policy. We do not use your data for purposes that are incompatible with those for which it was collected without seeking fresh consent or establishing another lawful basis.

• Account Management: Creating and maintaining your sm777 Account, authenticating your identity at login, and managing your account preferences and responsible gaming settings.
• Service Delivery: Processing deposits, executing gameplay transactions, crediting winnings to your Wallet, and processing withdrawal requests to your verified GCash, PayMaya, or bank account.
• Regulatory Compliance: Fulfilling sm777's obligations under PAGCOR regulations, the Anti-Money Laundering Act (AMLA, RA 9160 as amended), the Data Privacy Act, and all other applicable Philippine law. This includes mandatory reporting to PAGCOR and the Anti-Money Laundering Council (AMLC).
• KYC and Age Verification: Confirming that players are at least 21 years of age and are who they claim to be before processing withdrawals or granting elevated account privileges.
• Fraud Prevention and Security: Detecting and preventing fraudulent transactions, unauthorized account access, bonus abuse, money laundering, and other prohibited conduct described in the sm777 Terms & Conditions.
• Customer Support: Responding to your queries, resolving disputes, and improving support quality through the analysis of anonymized support interaction data.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behaviors and providing relevant responsible gaming interventions in accordance with PAGCOR requirements and sm777's own Responsible Gaming program.
• Marketing Communications: Sending you promotional materials, bonus notifications, and new game announcements, subject to your marketing preferences and as further described in Section 12.
• Platform Improvement: Analyzing aggregated usage data to improve game performance, page load times, user interface design, and overall platform reliability.

Under the Philippine Data Privacy Act of 2012, sm777 processes your personal data on the following lawful bases, each of which applies to specific processing activities:

• Consent (Section 12(a) DPA): Processing for marketing communications and for certain optional features of the Platform. You may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.
• Performance of a Contract (Section 12(b) DPA): Processing necessary to provide the services you requested when registering an sm777 Account and agreeing to the Terms & Conditions — including account operation, payment processing, and game delivery.
• Compliance with Legal Obligations (Section 12(c) DPA): Processing required by PAGCOR regulations, the AMLA, the DPA itself, and other Philippine statutes applicable to sm777's operations. This includes KYC, AML reporting, age verification, and mandatory record retention.
• Legitimate Interests (Section 12(f) DPA): Processing for fraud prevention, security monitoring, Platform improvement, and dispute resolution, where these interests are not overridden by your fundamental rights and freedoms as a data subject.

sm777 does not sell your personal data. We share your personal data only in the specific circumstances described below, and only to the extent strictly necessary for the stated purpose:

sm777 is obligated to share player data with PAGCOR, the AMLC, the National Privacy Commission, the Bureau of Internal Revenue (BIR), and other Philippine government agencies when required by law, regulation, court order, or official government request. sm777 will, where legally permissible, notify you of such disclosures.

Financial transaction data is shared with payment processors (GCash / G-Xchange Inc., PayMaya / Maya Bank, and partner banks including BPI, BDO, and Metrobank) to the extent required to execute deposits and withdrawals. These processors are contractually bound to handle your data in compliance with applicable Philippine financial regulations and data protection law.

Game providers (including JILI, Pragmatic Play, Evolution Gaming, PG Soft, and others) receive anonymized session and wagering data for game performance analytics, RTP calculation, and fraud detection purposes. Game providers do not receive your name, contact details, or financial data unless required for a specific certified verification process.

KYC document data is processed by certified identity verification service providers. These providers operate under data processing agreements with sm777 and are prohibited from using your KYC data for any purpose other than verifying your identity for sm777.

sm777's legal advisers, auditors, and accountants may access personal data on a confidential, need-to-know basis in connection with the services they provide to sm777. All professional advisers are bound by legal professional privilege or contractual confidentiality obligations.

sm777 uses cookies and similar technologies (web beacons, pixel tags, local storage) to operate the Platform, maintain your session, prevent fraud, and analyze usage patterns. Cookies are small text files stored on your device by your browser at the instruction of the Platform.

You can manage non-essential cookies through your browser settings. Note that disabling certain cookies may impair Platform functionality. Most modern browsers provide controls to view, manage, and delete cookies under Settings > Privacy or equivalent menu.

sm777 retains personal data only for as long as necessary to fulfill the purpose for which it was collected, or as required by applicable law. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your Account and for a minimum of five (5) years following Account closure, in compliance with AMLA record-keeping obligations and PAGCOR requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by the AMLA and BIR record-keeping regulations.
• KYC Documents: Retained for a minimum of five (5) years following Account closure or the last transaction, whichever is later.
• Gaming History (Bet Records): Retained for a minimum of three (3) years for dispute resolution purposes and regulatory compliance, after which they may be anonymized.
• Support Communications: Retained for two (2) years from the date of the most recent interaction in a support thread.
• Marketing Consent Records: Retained for the period during which you are subscribed to marketing communications, plus three (3) years thereafter as evidence of consent.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in a manner that prevents reconstruction of the original personal data.

sm777 implements a multi-layered security program to protect your personal data against unauthorized access, accidental loss, destruction, and unlawful processing. Our technical and organizational security measures include, but are not limited to:

• TLS 256-bit SSL encryption for all data transmitted between your device and sm777 servers;
• AES-256 encryption for personal data stored in sm777's databases at rest;
• Role-based access controls limiting staff access to personal data on a strictly need-to-know basis;
• Multi-factor authentication required for all sm777 administrative system access;
• Comprehensive intrusion detection and prevention systems monitoring for anomalous access patterns in real time;
• Regular independent penetration testing of the Platform and its infrastructure by certified third-party security professionals;
• Audit logging of all access to personal data stores, retained for security review purposes;
• Regular staff training on data privacy obligations and information security best practices;
• A formal incident response plan tested annually, covering detection, containment, notification to the NPC, and player communication.

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by sm777. These rights may be exercised by submitting a written request to [email protected]. sm777 will respond to all data subject rights requests within thirty (30) calendar days of receipt.

To exercise any of these rights, contact our Data Protection Officer at [email protected]. We may require you to verify your identity before processing the request to protect against unauthorized access to your data. sm777 will not charge a fee for routine data subject rights requests unless a request is manifestly unfounded or excessive.

sm777 is a gaming platform exclusively for adults. In the Philippines, casino-style gambling is restricted to persons aged 21 years or older under PAGCOR regulations. sm777 does not knowingly collect or process personal data from persons under the age of 21.

Age verification is conducted at the point of registration and, more thoroughly, during the KYC process prior to the first withdrawal. Any Account found to have been registered by a person under 21 years of age will be immediately suspended, all associated data preserved only for the purposes of any resulting regulatory investigation, and the matter reported to PAGCOR.

Parents and guardians who believe their child may have accessed the sm777 Platform and provided personal data are encouraged to contact our Data Protection Officer immediately at [email protected]. sm777 will delete any personal data relating to a minor promptly upon verification, unless retention is required for regulatory purposes.

sm777's primary data processing infrastructure is located in the Philippines. However, certain service providers and game platforms — including Evolution Gaming's live casino studios and some cloud infrastructure partners — may process data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, sm777 ensures that appropriate safeguards are in place in accordance with the DPA and NPC guidelines. These safeguards include contractual data processing agreements incorporating the NPC's standard contractual clauses, binding corporate rules where applicable, and transfers only to jurisdictions that the NPC has determined provide an adequate level of data protection.

You may request information about the specific safeguards applicable to any cross-border transfer of your personal data by contacting our Data Protection Officer at [email protected].

With your consent, sm777 may send you promotional communications about new games, bonus offers, tournaments, and platform updates via SMS to your registered Philippine mobile number and/or email to your registered email address. Your consent to receive marketing communications is sought during registration and can be updated at any time from your Account Settings or by replying STOP to any SMS communication.

sm777 does not use automated profiling for the purpose of highly personalized advertising. Any personalization of offers (for example, showing you bonus offers relevant to your preferred game category) is based on your own gameplay history and is conducted solely within the sm777 Platform. This data is not shared with advertising networks or third-party data brokers.

The sm777 Platform may, from time to time, contain references to information about game providers or payment methods. sm777 does not embed third-party widgets, social media plugins, or external tracking scripts from advertising networks that would allow third parties to collect your data through the sm777 Platform without your knowledge.

This Privacy Policy applies exclusively to data collected by sm777 through the sm777 Platform. sm777 is not responsible for the privacy practices of any third parties, including payment processors and game providers, whose own privacy policies govern their handling of any data you provide to them directly.

sm777 reserves the right to update or amend this Privacy Policy at any time. Material changes — meaning changes that substantively affect how we use your personal data or your rights as a data subject — will be communicated to you via your registered email address at least fourteen (14) days before taking effect. The updated Policy will also be published on this page with a revised effective date.

Non-material changes, such as clarifications of existing language or updates required by NPC guidance, may take effect immediately upon publication. We encourage you to review this page periodically to stay informed of how sm777 is protecting your personal data. The most current version of this Policy is always accessible at sm777.bid/privacy-policy.

Your continued use of the sm777 Platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy. If you do not accept the amended Policy, you should cease using the Platform and submit an Account closure request as described in the sm777 Terms & Conditions.

sm777 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data, or if you believe your data rights have been violated, you may contact the DPO directly:

For general customer support — including account, payment, and gameplay inquiries that do not concern data privacy specifically — please contact: [email protected]. The support team operates 24/7 and responds in both English and Filipino.