Privacy Policy

1. Introduction

sand77 ("we," "us," "our," or "the Platform") operates the online gaming website accessible at https://sand77.club. We understand that your personal information is important to you, and we take our responsibility to protect it seriously. This Privacy Policy ("Policy") describes how sand77 collects, processes, stores, shares, and protects personal data in connection with your use of the sand77 Platform.

This Policy applies to all registered players, visitors, and any other individuals whose personal data is processed by sand77 in connection with the Platform. It should be read together with the sand77 Terms and Conditions and Responsible Gaming Policy, both of which are available on this website.

By registering an account on sand77 or by continuing to use the 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. If you do not agree with any part of this Policy, you should discontinue use of the Platform immediately.

Your data stays with sand77. We do not sell, rent, or trade your personal information to third-party marketers. Data is shared only where strictly necessary for platform operations, payment processing, or legal compliance.

2. Data Controller

For the purposes of applicable data protection legislation, including the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, sand77 acts as the data controller in respect of personal data collected through the Platform.

As data controller, sand77 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable law. If you have any questions or concerns about how your personal data is handled, please refer to Section 14 of this Policy for contact details.

3. Personal Data We Collect

sand77 collects the following categories of personal data in connection with your use of the Platform:

Category	Examples	Purpose
Identity Data	Full name, date of birth, government-issued ID number, nationality	Account registration, KYC verification, age verification
Contact Data	Email address, mobile number, residential address	Account communications, support, notifications
Financial Data	GCash number, PayMaya account, bank account details (BPI, BDO, Metrobank), transaction history	Deposits, withdrawals, AML compliance
Technical Data	IP address, device type, browser type, operating system, session logs	Security, fraud prevention, platform optimization
Usage Data	Games played, wager amounts, session duration, bonus usage	Responsible gaming monitoring, personalization, analytics
Communications Data	Support chat logs, email correspondence, feedback submissions	Customer support, dispute resolution, quality assurance
Verification Documents	Copies of government-issued ID, proof of address, selfie verification	KYC compliance, fraud prevention, regulatory requirements

sand77 does not intentionally collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where such information is voluntarily provided by you in the context of a responsible gaming self-assessment or similar tool.

4. How We Collect Your Data

sand77 collects personal data through the following means:

Direct Interactions: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
Automated Technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies. Please refer to Section 11 for more information on our use of cookies.
Third-Party Sources: Identity and financial verification data received from payment processors (such as GCash and PayMaya), identity verification service providers, and fraud prevention agencies, where necessary to comply with our legal obligations.
Publicly Available Sources: In limited circumstances, sand77 may verify information against publicly available records for fraud prevention or AML compliance purposes.

5. How We Use Your Personal Data

sand77 uses your personal data for the following purposes:

Account Management: To create, maintain, and administer your sand77 player account, including processing your registration and verifying your identity.
Service Delivery: To provide you with access to the sand77 game library, process deposits and withdrawals, and deliver the services you have requested.
Legal and Regulatory Compliance: To comply with applicable Philippine laws and regulations, including anti-money laundering (AML) obligations, PAGCOR regulatory requirements, and the Data Privacy Act of 2012.
Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the Platform and its players.
Responsible Gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion requests, and provide responsible gaming tools and interventions where appropriate.
Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
Marketing and Promotions: To send you information about sand77 promotions, bonuses, and new games, where you have provided consent or where we have a legitimate interest in doing so. You may opt out of marketing communications at any time by contacting support.
Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and user experience of the sand77 Platform.

6. Legal Basis for Processing

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

Contractual Necessity: Processing is necessary for the performance of the contract between you and sand77, including account registration, game access, and payment processing.
Legal Obligation: Processing is required to comply with applicable laws and regulations, including AML obligations, PAGCOR requirements, and tax reporting obligations.
Legitimate Interests: Processing is necessary for sand77's legitimate interests, including fraud prevention, platform security, and responsible gaming monitoring, provided that such interests are not overridden by your rights and interests.
Consent: Where sand77 relies on your consent as the legal basis for processing — for example, for certain marketing communications — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

7. Data Sharing and Disclosure

sand77 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 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, for the purpose of processing deposits and withdrawals.
Identity Verification Providers: Third-party KYC and identity verification service providers engaged to assist with regulatory compliance.
Fraud Prevention Agencies: Organizations that assist sand77 in detecting and preventing fraudulent activity and money laundering.
Regulatory Authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other government authorities, where disclosure is required by law or regulatory directive.
Technology Service Providers: Cloud hosting providers, analytics platforms, and other technology vendors engaged to support the operation of the Platform, subject to contractual data processing agreements.
Legal and Professional Advisors: Lawyers, auditors, and other professional advisors engaged by sand77, subject to professional confidentiality obligations.

All third-party service providers engaged by sand77 are required to process your personal data only in accordance with our instructions and applicable data protection law. They are not permitted to use your data for their own purposes.

8. Data Retention

sand77 retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements. The following general retention periods apply:

Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR regulatory requirements and applicable AML legislation.
Transaction Records: Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of 2001 (Republic Act No. 9160) and its amendments.
KYC Documents: Identity verification documents are retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
Communications Data: Customer support records and correspondence are retained for a period of three (3) years from the date of the last interaction.
Technical and Usage Data: Log files and usage data are retained for up to twelve (12) months, unless a longer retention period is required for security investigations or legal proceedings.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with sand77's data disposal procedures.

9. Data Security

sand77 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

Encryption of data in transit using industry-standard Transport Layer Security (TLS) protocols.
Encryption of sensitive data at rest, including financial information and identity documents.
Access controls limiting data access to authorized personnel on a strict need-to-know basis.
Regular security assessments, vulnerability testing, and penetration testing of Platform infrastructure.
Multi-factor authentication requirements for administrative access to systems containing personal data.
Staff training on data protection obligations and information security best practices.

While sand77 takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, sand77 will notify the National Privacy Commission (NPC) and affected individuals in accordance with the requirements of the Data Privacy Act of 2012.

You are responsible for keeping your sand77 account credentials confidential. If you suspect that your account has been compromised, please contact our support team immediately.

10. Your Data Privacy Rights

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

Right to Be Informed: The right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy.
Right of Access: The right to request a copy of the personal data that sand77 holds about you, together with information about how it is being processed.
Right to Rectification: The right to request correction of any inaccurate or incomplete personal data held by sand77.
Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to sand77's legal retention obligations.
Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that sand77 has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact sand77 using the details provided in Section 14. sand77 will respond to all verified data subject requests within thirty (30) days of receipt. In complex cases, this period may be extended by a further thirty (30) days, in which case you will be notified of the extension and the reasons for it.

11. Cookies and Tracking Technologies

11.1 What Are Cookies

Cookies are small text files placed on your device when you visit the sand77 Platform. They allow the Platform to recognize your device, remember your preferences, and collect information about how you use the site. sand77 uses both session cookies (which expire when you close your browser) and persistent cookies (which remain on your device for a set period).

11.2 Types of Cookies We Use

Strictly Necessary Cookies: Essential for the Platform to function correctly, including maintaining your login session and enabling secure transactions. These cookies cannot be disabled.
Performance and Analytics Cookies: Used to collect anonymized information about how visitors use the Platform, helping sand77 identify areas for improvement and optimize the user experience.
Functionality Cookies: Used to remember your preferences and settings, such as language preferences and display options, to provide a more personalized experience.
Security Cookies: Used to detect and prevent fraudulent activity, unauthorized access, and other security threats to the Platform.

11.3 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse or delete cookies. However, disabling strictly necessary cookies may affect the functionality of the sand77 Platform and prevent you from accessing certain features. Please refer to your browser's help documentation for instructions on managing cookie settings.

12. Minors and Age Restriction

The sand77 Platform is strictly intended for adults aged twenty-one (21) years and above, in accordance with Philippine gambling regulations. sand77 does not knowingly collect personal data from individuals under the age of 21. If you are under 21 years of age, you must not register an account or use the Platform in any way.

If sand77 becomes aware that personal data has been collected from a person under the age of 21 without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the Platform, please notify us immediately using the contact details in Section 14.

13. Changes to This Privacy Policy

sand77 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, sand77 will post a notice on the Platform and update the effective date displayed at the top of this page. Where required by law, sand77 will seek your consent before implementing material changes to the way your personal data is processed.

Your continued use of the sand77 Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised Policy. We encourage you to review this page periodically to stay informed about how sand77 protects your personal data.

14. Contact and Data Privacy Inquiries

If you have any questions, concerns, or requests relating to this Privacy Policy or the way sand77 processes your personal data, please contact our Data Privacy team. We are committed to addressing all privacy-related inquiries promptly and transparently.

Data Privacy Inquiries: [email protected]

You also have the right to lodge a complaint with the National Privacy Commission of the Philippines if you are not satisfied with sand77's response to your privacy concern. For responsible gaming concerns, please visit our Responsible Gaming page for additional support resources available to Filipino players.

Contents