7GAIN PRIVACY POLICY

1. INTRODUCTION AND SCOPE

This Privacy Policy ("Policy") describes how 7gain ("we," "us," "our," or "Company") collects, uses, processes, stores, shares, and protects personal information obtained from users ("you," "your," or "User") of our online gaming platform accessible at https://7gain.cam (the "Platform" or "Website"). This Policy applies to all personal data processed by 7gain in connection with your use of our services, whether accessed via desktop, mobile browser, or mobile application.

7gain is committed to protecting your privacy and maintaining the confidentiality of your personal information in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, PAGCOR regulatory requirements, and international data protection standards including GDPR principles where applicable. By accessing or using the 7gain Platform, you acknowledge that you have read, understood, and consent to the data processing practices described in this Privacy Policy.

1.1 Data Controller

7gain acts as the data controller for all personal information collected through the Platform. We determine the purposes and means of processing your personal data and are responsible for ensuring compliance with applicable data protection laws. For data protection inquiries, please contact our Data Protection Officer at [email protected].

1.2 Children's Privacy

The 7gain Platform is not intended for use by individuals under the age of twenty-one (21) years. We do not knowingly collect personal information from minors. If we discover that we have inadvertently collected personal data from a person under 21 years of age, we will delete that information immediately. Parents or guardians who believe we have collected information from a minor should contact us immediately.

1.3 Changes to This Policy

We reserve the right to modify this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or business operations. Material changes will be communicated via email to your registered address and through prominent notice on the Website at least thirty (30) days before the changes take effect. Your continued use of the Platform after the effective date of the revised Policy constitutes acceptance of the updated terms.

2. PERSONAL DATA WE COLLECT

To provide our online gaming services, comply with regulatory requirements, and ensure platform security, 7gain collects various categories of personal information. The specific data collected depends on how you interact with our Platform:

2.1 Account Registration Information

When you create a 7gain account, we collect:

• Identity Information: Full legal name, date of birth, gender, nationality, government-issued identification number (e.g., Philippine passport number, driver's license number, or UMID number)
• Contact Information: Email address, mobile phone number, residential address (street address, city, province, postal code)
• Account Credentials: Username, password (stored in encrypted form), security questions and answers
• Demographic Information: Age range, preferred language, occupation (for regulatory compliance)

2.2 Verification and KYC Documentation

To comply with PAGCOR regulations and anti-money laundering requirements, we collect:

• Copies of government-issued identification documents (passport, driver's license, national ID)
• Proof of address documents (utility bills, bank statements, government correspondence)
• Proof of payment method ownership (bank statements, credit card photos with sensitive numbers masked, e-wallet screenshots)
• Selfie photographs holding identification documents for identity verification
• Source of funds documentation for high-value transactions

2.3 Financial and Transaction Data

When you conduct financial transactions on the Platform, we collect:

• Payment instrument details (bank account numbers, credit/debit card last four digits, e-wallet account names, cryptocurrency wallet addresses)
• Deposit and withdrawal history (amounts, dates, payment methods used, transaction IDs)
• Account balance information and transaction status
• Currency exchange rates and conversion records
• Bonus claims, wagering progress, and promotional participation records

2.4 Gaming and Behavioral Data

To provide personalized services and ensure responsible gaming, we collect:

• Gaming history (games played, bets placed, winnings and losses, session duration)
• Gameplay patterns and betting behavior for fraud detection and responsible gaming monitoring
• Chat messages and communications with customer support
• Preferences, favorites, and saved settings
• Tournament participation and leaderboard standings

2.5 Technical and Device Information

We automatically collect technical data when you access the Platform:

• IP address, geographic location (country, region, city based on IP)
• Device information (device type, operating system, browser type and version, screen resolution)
• Browsing data (pages visited, time spent on pages, referral sources, exit pages)
• Cookies and tracking identifiers (see Section 7 for details)
• Network connection type, ISP information, language settings
• Error logs, crash reports, and diagnostic data for troubleshooting

2.6 Marketing and Communication Preferences

• Email subscription status and communication preferences
• SMS and push notification opt-in/opt-out preferences
• Promotional campaign interactions (email opens, link clicks, offer redemptions)
• Survey responses and feedback submissions

3. HOW WE COLLECT YOUR DATA

3.1 Information You Provide Directly

Most personal data is provided directly by you when you register an account, complete verification processes, make deposits or withdrawals, communicate with customer support, participate in promotions, or update your account settings. You are responsible for ensuring the accuracy and completeness of information you provide.

3.2 Automated Collection Technologies

We use cookies, web beacons, pixel tags, and similar tracking technologies to automatically collect technical and behavioral data as you navigate the Platform. These technologies help us recognize your device, remember your preferences, analyze traffic patterns, and improve user experience. See Section 7 for detailed information about cookies and how to manage them.

3.3 Third-Party Sources

We may receive information about you from third-party service providers including:

• Payment processors and financial institutions (to verify payment methods and process transactions)
• Identity verification services (to confirm your identity and prevent fraud)
• Publicly available databases (for compliance screening and fraud prevention)
• Affiliate partners and marketing platforms (if you arrived at 7gain through an affiliate link)
• Social media platforms (only if you choose to connect your social account for easier login)

3.4 Customer Support Interactions

When you contact our customer support team via live chat, email, or phone, we collect the content of your communications, support ticket history, and any information you voluntarily provide to resolve your inquiry. Support conversations may be recorded for quality assurance and training purposes.

4. HOW WE USE YOUR DATA

7gain processes your personal information for specific, legitimate purposes in accordance with applicable data protection laws. We use your data to:

4.1 Provide and Manage Services

• Create, maintain, and secure your user account
• Process deposits, withdrawals, and other financial transactions
• Provide access to games and gambling services
• Track your gaming activity, betting history, and account balance
• Administer bonuses, promotions, tournaments, and loyalty programs
• Respond to customer support inquiries and resolve disputes
• Send transactional communications (account confirmations, transaction receipts, security alerts)

4.2 Comply with Legal and Regulatory Obligations

• Verify your identity, age, and address (KYC/AML compliance)
• Prevent fraud, money laundering, and terrorist financing
• Comply with PAGCOR reporting requirements and gaming regulations
• Respond to legal requests from law enforcement or regulatory authorities
• Maintain records required by Philippine tax authorities
• Enforce our Terms and Conditions and other legal agreements

4.3 Ensure Platform Security and Prevent Fraud

• Detect and prevent fraudulent, unauthorized, or illegal activity
• Identify suspicious betting patterns, collusion, or advantage play
• Protect against security threats, hacking attempts, and system attacks
• Monitor for duplicate accounts and multi-accounting violations
• Verify the legitimacy of payment methods and prevent chargebacks

4.4 Improve and Personalize User Experience

• Analyze usage patterns to optimize Platform performance and features
• Personalize game recommendations based on your preferences
• Customize promotional offers and bonus opportunities
• Conduct research, analytics, and statistical analysis
• Test new features and conduct A/B testing
• Troubleshoot technical issues and improve service quality

4.5 Marketing and Communication

• Send promotional emails, SMS, and push notifications (with your consent)
• Inform you about new games, bonuses, and special offers
• Conduct customer satisfaction surveys and request feedback
• Display targeted advertisements based on your interests

4.6 Responsible Gaming

• Monitor gambling behavior for signs of problem gambling
• Implement self-exclusion and deposit limit requests
• Provide responsible gaming tools and resources
• Intervene when concerning gambling patterns are detected

4.7 Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Contractual Necessity: Processing is necessary to fulfill our contractual obligations under the Terms and Conditions
• Legal Obligation: Processing is required to comply with Philippine laws and PAGCOR regulations
• Legitimate Interests: Processing is necessary for our legitimate business interests (fraud prevention, service improvement, security)
• Consent: You have provided explicit consent for marketing communications and optional data processing

5. DATA SHARING AND DISCLOSURE

7gain does not sell, rent, or trade your personal information to third parties for their marketing purposes. We only share your data in the following limited circumstances:

5.1 Service Providers and Business Partners

We share personal data with trusted third-party service providers who perform functions on our behalf, including:

• Payment Processors: GCash, Maya, banks, and cryptocurrency payment gateways to process your deposits and withdrawals
• Identity Verification Services: KYC/AML compliance providers to verify your identity and prevent fraud
• Gaming Software Providers: Third-party game suppliers who power our casino games, slots, and live dealer games
• Cloud Hosting Services: Infrastructure providers who host our servers and databases
• Customer Support Platforms: Live chat and ticketing systems for customer service operations
• Marketing and Analytics Tools: Email service providers, analytics platforms, and advertising networks

All service providers are contractually obligated to maintain confidentiality, use data only for specified purposes, and implement appropriate security measures.

5.2 Legal and Regulatory Authorities

We may disclose your personal information to government agencies, law enforcement, or regulatory bodies when:

• Required by Philippine law or PAGCOR regulations
• Responding to subpoenas, court orders, or legal processes
• Reporting suspicious transactions for AML compliance
• Cooperating with law enforcement investigations
• Complying with tax reporting obligations

5.3 Corporate Transactions

In the event of a merger, acquisition, sale of assets, bankruptcy, or other corporate restructuring, your personal information may be transferred to the acquiring entity. We will notify you via email and website notice before your data is transferred and becomes subject to a different privacy policy.

5.4 Protection of Rights

We may disclose personal information when we believe in good faith that disclosure is necessary to:

• Protect our rights, property, or safety, or those of our users or the public
• Enforce our Terms and Conditions or other policies
• Investigate and prevent fraud, security breaches, or illegal activity
• Defend against legal claims or investigations

5.5 With Your Consent

We may share your information with third parties when you have provided explicit consent for such sharing, such as when participating in co-branded promotions or connecting third-party services to your account.

5.6 Aggregated and Anonymized Data

We may share aggregated, anonymized, or de-identified data that cannot be used to identify you personally. This includes statistical information about user demographics, platform usage trends, and gaming patterns used for research, marketing, or business intelligence purposes.

6. DATA SECURITY MEASURES

7gain implements comprehensive technical, administrative, and physical security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

6.1 Technical Security Controls

• Encryption: All data transmitted between your device and our servers is protected by industry-standard 256-bit SSL/TLS encryption
• Password Protection: Passwords are hashed using secure cryptographic algorithms and never stored in plain text
• Firewall Protection: Multi-layer firewalls protect our infrastructure from external threats
• Intrusion Detection: Real-time monitoring systems detect and respond to suspicious activity
• Secure Data Centers: Personal data is stored in ISO 27001 certified data centers with redundant security controls
• Regular Security Audits: Third-party penetration testing and security assessments conducted quarterly

6.2 Access Controls

• Strict role-based access controls limit employee access to personal data on a need-to-know basis
• Multi-factor authentication required for administrative access to sensitive systems
• All access to personal data is logged and regularly audited
• Employee background checks and confidentiality agreements for staff handling personal data

6.3 Organizational Measures

• Comprehensive data protection policies and procedures documented and enforced
• Regular employee training on data protection and security best practices
• Incident response plan for data breach notification and remediation
• Regular backup and disaster recovery procedures to prevent data loss

6.4 Your Role in Security

While we implement robust security measures, you also play a crucial role in protecting your account:

• Choose a strong, unique password and do not share it with anyone
• Enable two-factor authentication if available
• Log out of your account when using shared or public devices
• Keep your contact information current so we can reach you about security issues
• Report any suspicious activity or unauthorized access immediately
• Avoid accessing your account over unsecured public Wi-Fi networks

6.5 Data Breach Notification

In the unlikely event of a data breach that compromises your personal information, we will notify you via email within seventy-two (72) hours of discovering the breach, as required by Philippine data protection law. The notification will include details about what information was affected, steps we are taking to address the breach, and recommendations for protecting yourself.

7. YOUR PRIVACY RIGHTS

Under the Data Privacy Act of 2012 and applicable international data protection standards, you have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request confirmation of whether we process your personal data and to obtain a copy of your personal information. You can access most of your data directly through your account dashboard. For comprehensive data access requests, contact [email protected].

7.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal data. You can update most information through your account settings. For changes to verified information (name, date of birth), contact customer support with supporting documentation.

7.3 Right to Erasure ("Right to be Forgotten")

You may request deletion of your personal data when it is no longer necessary for the purposes for which it was collected, you withdraw consent, or there are no overriding legitimate grounds for processing. However, we may retain certain data to comply with legal obligations, resolve disputes, or enforce our agreements. Deletion requests are processed within thirty (30) days.

7.4 Right to Restrict Processing

You may request restriction of processing your personal data in certain circumstances, such as when you contest the accuracy of the data or object to processing based on legitimate interests. During the restriction period, we will store your data but not actively process it except with your consent or for legal claims.

7.5 Right to Data Portability

You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit that data to another service provider. Data portability requests can be submitted to [email protected] and will be fulfilled within thirty (30) days.

7.6 Right to Object

You may object to processing of your personal data based on legitimate interests or for direct marketing purposes. You can opt out of marketing communications at any time by clicking "unsubscribe" in emails, adjusting your account communication preferences, or contacting customer support.

7.7 Right to Withdraw Consent

Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing conducted before withdrawal. Note that withdrawal of consent for essential processing may prevent us from providing services to you.

7.8 Right to Lodge a Complaint

If you believe we have violated your privacy rights or applicable data protection laws, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Contact details: National Privacy Commission, 5th Floor, Philippine International Convention Center (PICC), Vicente Sotto St., Pasay City, Philippines | Email: [email protected] | Hotline: (+632) 8234-2228

7.9 Exercising Your Rights

To exercise any of these rights, please submit a written request to [email protected] or contact customer support. We will verify your identity before processing your request and respond within thirty (30) days. There is no fee for exercising your rights unless your request is manifestly unfounded or excessive.

8. COOKIES AND TRACKING TECHNOLOGIES

8.1 What Are Cookies

Cookies are small text files stored on your device when you visit websites. They help websites remember your preferences, recognize your device on return visits, and provide analytics about website usage. 7gain uses cookies and similar technologies to enhance user experience, improve platform functionality, and deliver personalized content.

8.2 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Required for basic platform functionality, account login, and security. Cannot be disabled.	Session / Persistent
Performance Cookies	Collect anonymous data about how users interact with the platform to improve performance.	Up to 2 years
Functionality Cookies	Remember your preferences (language, currency) and provide enhanced features.	Up to 1 year
Marketing Cookies	Track your activity across websites to deliver targeted advertising and measure campaign effectiveness.	Up to 1 year

8.3 Third-Party Cookies

We use third-party cookies from service providers such as Google Analytics (website analytics), Facebook Pixel (advertising), and game providers (game functionality). These third parties may collect information about your online activities across different websites. We do not control third-party cookies and recommend reviewing their privacy policies.

8.4 Managing Cookie Preferences

You can manage cookie preferences through your browser settings. Most browsers allow you to block or delete cookies, although this may affect platform functionality. To manage cookies:

• Chrome: Settings > Privacy and Security > Cookies and other site data
• Firefox: Preferences > Privacy & Security > Cookies and Site Data
• Safari: Preferences > Privacy > Manage Website Data
• Edge: Settings > Privacy, search, and services > Cookies and site permissions

You can also opt out of targeted advertising by visiting the Digital Advertising Alliance opt-out page or using browser extensions like Privacy Badger.

8.5 Do Not Track Signals

Some browsers transmit "Do Not Track" signals to websites. Currently, there is no universal standard for how websites should respond to these signals. 7gain does not currently respond to Do Not Track browser signals but provides cookie management options as described above.

9. DATA RETENTION

9.1 Retention Periods

We retain your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods vary by data type:

• Account Information: Retained for the duration of your account plus seven (7) years after closure for regulatory compliance
• Transaction Records: Retained for ten (10) years to comply with Philippine anti-money laundering and tax laws
• KYC Documentation: Retained for seven (7) years after account closure per PAGCOR requirements
• Gaming History: Retained for five (5) years for audit and dispute resolution purposes
• Marketing Data: Retained until you opt out or withdraw consent, then deleted within ninety (90) days
• Technical Logs: Retained for up to two (2) years for security monitoring and troubleshooting

9.2 Deletion Upon Request

When you exercise your right to erasure, we will delete or anonymize your personal data within thirty (30) days, except where retention is required by law or for legitimate business purposes (fraud prevention, dispute resolution, compliance). After the applicable retention period expires, personal data is securely deleted or irreversibly anonymized.

9.3 Inactive Accounts

Accounts inactive for three (3) consecutive years may be closed, and personal data will be archived according to our standard retention schedule. We will notify you via email before archiving an inactive account and provide an opportunity to reactivate.

10. INTERNATIONAL DATA TRANSFERS

Your personal information may be transferred to and processed in countries outside the Philippines where our service providers, cloud infrastructure, or business operations are located. These countries may have different data protection standards than the Philippines. When we transfer personal data internationally, we ensure appropriate safeguards are in place, including:

• Standard contractual clauses approved by data protection authorities
• Service providers certified under recognized privacy frameworks
• Adequate data protection certifications and compliance programs
• Binding corporate rules for intra-group data transfers

By using the 7gain Platform, you consent to the transfer of your personal information outside the Philippines subject to these safeguards.

11. CONTACT INFORMATION

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us:

Data Protection Officer
7gain Privacy Team
Email: [email protected]
Customer Support: [email protected]
Live Chat: Available 24/7 on our website

We will respond to your inquiry within fifteen (15) business days. For urgent security concerns, please contact customer support immediately via live chat.