sm777 Privacy Policy 🔒

1. Introduction and Scope

This Privacy Policy ("Policy") describes how sm777 ("we," "us," or "the Company") collects, uses, stores, shares, and protects personal data obtained from individuals ("you" or "the Player") who access or use the sm777 online gaming platform, including the website at sm777.bio and any related mobile applications or services (collectively, the "Platform").

This Policy applies to all personal data processing activities carried out by sm777 in connection with the operation of the Platform and the provision of online casino, sports betting, and related gaming services to players in the Philippines and other permitted jurisdictions.

By registering an account or using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must not use the Platform.

2. Data Controller Information

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, sm777 acts as the Personal Information Controller with respect to the personal data of registered players and website visitors.

All data protection inquiries, rights requests, and complaints may be directed to our Data Protection Officer (DPO) at: [email protected] (plain text only — not a clickable link). Requests submitted via live chat on the Platform will be acknowledged within 2 business hours.

3. Personal Data We Collect

sm777 collects the following categories of personal data, to the extent necessary for the purposes described in Section 6:

Category	Examples	Purpose
Identity Data	Full legal name, date of birth, government ID number, selfie/photo for KYC	Age verification, KYC compliance, fraud prevention
Contact Data	Philippine mobile number, email address, residential address	Account communication, OTP delivery, KYC verification
Financial Data	GCash account number, Maya account number, bank account details, transaction history	Deposit and withdrawal processing, AML compliance
Technical Data	IP address, device type and OS, browser type, login timestamps, session logs	Security monitoring, fraud detection, platform optimization
Gaming Data	Game history, wager amounts, bet types, win/loss records, bonus usage	Account management, responsible gaming monitoring, regulatory reporting
Communications Data	Live chat transcripts, support ticket content, email correspondence	Customer support, dispute resolution, quality assurance

sm777 does not collect sensitive personal information as defined under the Philippine Data Privacy Act (such as racial or ethnic origin, political opinions, religious beliefs, or medical data) except where strictly required for responsible gaming assessments, in which case explicit consent will be obtained.

4. How We Collect Your Data

sm777 collects personal data through the following means:

• Direct collection: Information you provide during account registration, identity verification (KYC), deposit/withdrawal requests, and support interactions;
• Automated collection: Technical data collected automatically when you access the Platform, including via cookies, server logs, and device fingerprinting technologies;
• Third-party sources: Identity verification data from KYC service providers; payment transaction data from GCash, Maya, and other payment processors; fraud intelligence from third-party anti-fraud services.

5. Legal Bases for Processing

sm777 processes your personal data under the following legal bases as recognized under the Philippine Data Privacy Act of 2012:

• Contractual necessity: Processing necessary to perform the contract between sm777 and you (i.e., providing gaming services, processing deposits and withdrawals, managing your account);
• Legal obligation: Processing necessary to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements and Anti-Money Laundering Act (AMLA) obligations;
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where our interests do not override your fundamental rights;
• Consent: Where required by law, we obtain your explicit consent before processing, particularly for direct marketing communications.

6. How We Use Your Personal Data

sm777 uses the personal data collected for the following purposes:

• To create, verify, and manage your sm777 player account;
• To process deposits and withdrawal requests via GCash, Maya, and other supported Philippine payment methods;
• To verify your identity and age (21+ requirement) in compliance with applicable Philippine gaming regulations and PAGCOR requirements;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities;
• To monitor gaming activity for responsible gaming purposes, including identifying patterns indicative of problem gambling;
• To communicate with you regarding your account, transactions, promotions (where consented), and platform updates;
• To comply with Anti-Money Laundering Act (AMLA) obligations, including transaction reporting where required;
• To improve and optimize the Platform through aggregated and anonymized analytics;
• To resolve disputes and enforce our Terms & Conditions.

7. Sharing of Personal Data

sm777 does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share personal data with the following categories of recipients only to the extent necessary:

• Payment processors: GCash (GXI), Maya (PayMaya Philippines), BPI, BDO, Metrobank, and other payment service providers, solely for the purpose of processing your transactions;
• KYC and identity verification providers: Third-party services that assist in verifying player identity documents and screening against sanctions or watchlists;
• IT and hosting providers: Cloud infrastructure and cybersecurity service providers who process data on our behalf under binding data processing agreements;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where required by law;
• Professional advisors: Legal counsel, auditors, and compliance consultants, under obligations of professional confidentiality.

Any third party receiving personal data from sm777 is required to implement appropriate data protection safeguards consistent with the Philippine Data Privacy Act.

8. Data Retention

sm777 retains personal data only for as long as necessary to fulfil the purposes described in this Policy or as required by applicable Philippine law. The following general retention periods apply:

• Account data: Retained for the duration of the account relationship and for a minimum of 5 years following account closure, in compliance with AMLA record-keeping requirements;
• Transaction records: Retained for a minimum of 5 years from the date of the transaction, in compliance with AMLA and PAGCOR requirements;
• KYC documents: Retained for the duration of the account relationship and for a minimum of 5 years following account closure;
• Technical logs: Retained for a maximum of 12 months from generation, unless retained longer for ongoing fraud investigations or legal proceedings;
• Marketing consents: Retained until withdrawn by you or for a maximum of 3 years from last interaction, whichever is earlier.

9. Cookies and Tracking Technologies

sm777 uses the following categories of cookies and similar technologies on the Platform:

• Strictly necessary cookies: Required for the Platform to function — session management, login authentication, load balancing, and security tokens. These cannot be disabled without impairing Platform functionality;
• Analytics cookies: Used to understand aggregate player behaviour, page performance, and error rates on the Platform. Data collected is anonymised and aggregated before analysis;
• Fraud prevention cookies: Device fingerprinting and behavioural analytics used to detect suspicious login patterns and prevent unauthorized account access.

sm777 does not use advertising cookies or tracking pixels for third-party retargeting purposes. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies will impair your ability to log in and use the Platform.

10. Your Rights Under Philippine Law

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by sm777:

• Right to be informed: To be told what personal data we hold about you and how it is processed;
• Right of access: To request a copy of the personal data sm777 holds about you;
• Right to rectification: To request correction of inaccurate or incomplete personal data;
• Right to erasure: To request deletion of personal data where there is no longer a legal basis for retention (subject to our regulatory retention obligations);
• Right to object: To object to processing based on legitimate interests;
• Right to data portability: To receive your personal data in a structured, commonly used format;
• Right to lodge a complaint: To file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated.

To exercise any of these rights, contact sm777 via live chat or at [email protected]. Requests will be acknowledged within 72 hours and resolved within 30 calendar days.

11. Security of Your Personal Data

sm777 implements appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers;
• Encryption at rest for sensitive personal data stored in our databases;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Two-factor authentication requirements for all administrative access to systems holding personal data;
• Regular third-party penetration testing and security audits;
• Incident response procedures with mandatory notification to affected players and the National Privacy Commission within 72 hours of discovering a material personal data breach.

12. Children and Minors

The sm777 Platform is strictly intended for individuals who are 21 years of age or older in accordance with Philippine gaming regulations. sm777 does not knowingly collect personal data from individuals under 21 years of age. If sm777 discovers that personal data has been collected from a person under 21, that account will be immediately suspended, all data will be deleted, and any funds will be returned after identity verification.

If you are a parent or guardian and believe that a minor in your care has registered an account on sm777, please contact us immediately via live chat so we can take prompt action.

13. Changes to This Policy

sm777 reserves the right to update or modify this Privacy Policy at any time. When material changes are made, we will notify registered players via the contact details held on their accounts (mobile number or email) at least 7 days before the changes take effect. The "Last Updated" date at the top of this page will reflect the date of the most recent revision. Continued use of the Platform after the effective date of revised Terms constitutes your acceptance of the updated Policy.

14. Contact and Data Protection Officer

For any privacy-related questions, data rights requests, or concerns about sm777's handling of your personal data, please contact our Data Protection Officer:

• Live Chat: Available 24/7 via the sm777 Platform — fastest response, typically under 2 hours
• Email: [email protected] (plain text — not a clickable link)

sm777 takes all privacy inquiries seriously and is committed to resolving them promptly and transparently in accordance with Philippine law.