7bat Privacy Policy

1. Introduction and Scope

1.1 Who We Are. This Privacy Policy is issued by 7bat ("7bat," "we," "us," or "our"), the operator of the online gaming platform accessible at https://7bat.net (the "Platform"). 7bat is committed to protecting the privacy and personal data of all users who access or register on the Platform.

1.2 Purpose of This Policy. This Privacy Policy explains how 7bat collects, uses, stores, shares, and protects personal data in connection with the operation of the Platform. It also describes the rights available to you as a data subject under Philippine law and how you may exercise those rights.

1.3 Legal Framework. 7bat processes personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), and the issuances of the National Privacy Commission ("NPC"). Where applicable, 7bat also complies with the Anti-Money Laundering Act (RA 9160, as amended) and PAGCOR regulatory requirements, which impose additional data processing obligations.

1.4 Scope. This Policy applies to all personal data collected through the Platform, including data collected during account registration, KYC verification, gameplay, customer support interactions, and use of responsible gaming tools. It applies to all registered players, visitors to the Platform, and any individual whose personal data is processed by 7bat in connection with the Platform's operation.

1.5 Acceptance. By registering an account on the 7bat Platform or by 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.

2. Data We Collect

2.1 Data You Provide Directly. When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or use any feature of the Platform, you provide personal data directly to 7bat. This includes:

• Registration data: full legal name, date of birth, email address, mobile number, and residential address;
• KYC documents: government-issued photo identification (e.g., Philippine passport, UMID, SSS ID, PhilHealth ID, driver's license), proof of address, and payment method verification documents;
• Financial data: GCash account number, Maya account details, bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), and transaction records;
• Communications: messages sent to customer support, complaint submissions, and feedback provided through the Platform.

2.2 Data Collected Automatically. When you access or use the Platform, 7bat automatically collects certain technical and usage data, including:

• Device and connection data: IP address, device type, operating system, browser type and version, and screen resolution;
• Usage data: pages visited, features used, game sessions played, session start and end times, and clickstream data;
• Cookie and tracking data: session identifiers, preference cookies, and analytics data as described in Section 8 of this Policy.

2.3 Data from Third Parties. 7bat may receive personal data about you from third-party payment processors (such as GCash and Maya) in connection with deposit and withdrawal transactions, and from identity verification service providers engaged to assist with KYC compliance. Such data is processed in accordance with this Policy and the applicable agreements with those third parties.

2.4 Sensitive Personal Information. In certain circumstances, 7bat may process sensitive personal information as defined under the DPA, including government-issued ID numbers and financial account details. Such data is processed only to the extent strictly necessary for KYC compliance and regulatory obligations, and is subject to enhanced security measures.

3. How We Use Your Data

7bat processes your personal data for the following purposes, each supported by a lawful basis under the DPA:

Account Management and Service Delivery

We use your registration and contact data to create and manage your account, verify your identity, process your transactions, and deliver the gaming services you have requested. This processing is necessary for the performance of our contract with you.

KYC and Regulatory Compliance

We are required by PAGCOR regulations and the Anti-Money Laundering Act to verify the identity of all registered players before processing withdrawals and at other points during the account lifecycle. KYC data is processed to fulfill these legal obligations.

Fraud Prevention and Platform Security

We analyze usage data, transaction patterns, and device information to detect and prevent fraud, money laundering, bonus abuse, and other prohibited activities. This processing is based on our legitimate interest in maintaining the security and integrity of the Platform.

Customer Support and Dispute Resolution

Communications data is used to respond to your support requests, investigate complaints, and resolve disputes. Records of support interactions are retained for quality assurance and regulatory compliance purposes.

Responsible Gaming

We use your gameplay data and account activity to monitor for signs of problem gambling and to administer responsible gaming tools such as deposit limits, loss limits, and self-exclusion. This processing is based on our legal obligations under PAGCOR responsible gaming requirements and our legitimate interest in player welfare.

Platform Improvement and Analytics

Aggregated and anonymized usage data is analyzed to understand how players use the Platform, identify areas for improvement, and develop new features. This processing is based on our legitimate interest in improving our services.

Marketing Communications

With your consent, we may send you promotional communications about 7bat offers, new games, and platform updates. You may withdraw your consent to marketing communications at any time by updating your notification preferences in your account settings or by contacting customer support.

4. Sharing Your Data

4.1 No Sale of Personal Data. 7bat does not sell, rent, or trade your personal data to any third party for their own commercial or marketing purposes. Your data is shared only as described in this Section.

4.2 Payment Processors. To process deposits and withdrawals, 7bat shares necessary financial data with payment service providers including GCash, Maya, and participating Philippine banks. These providers process your data only as necessary to complete the transaction and are bound by their own privacy policies and applicable Philippine financial regulations.

4.3 KYC and Identity Verification Providers. 7bat may engage third-party identity verification service providers to assist with KYC compliance. These providers receive only the data necessary to perform identity verification and are contractually bound to process such data solely for that purpose.

4.4 Game Providers. Certain games on the Platform are provided by third-party game developers. These providers may receive anonymized session data necessary to deliver the game experience. 7bat does not share personally identifiable information with game providers beyond what is technically necessary for game delivery.

4.5 Regulatory and Law Enforcement Authorities. 7bat is required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities when required by law, court order, or regulatory directive. Such disclosures are made only to the extent required and in accordance with applicable legal procedures.

4.6 Professional Advisors. 7bat may share personal data with its legal counsel, auditors, and other professional advisors where necessary for the provision of professional services, subject to appropriate confidentiality obligations.

4.7 Business Transfers. In the event of a merger, acquisition, or sale of all or substantially all of 7bat's assets, personal data held by 7bat may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in advance.

5. Data Retention

5.1 General Retention Principle. 7bat retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. When personal data is no longer needed, it is securely deleted or anonymized.

5.2 Account Data. Personal data associated with your account is retained for the duration of your account's active status and for a period of five (5) years following account closure, in accordance with PAGCOR record-keeping requirements and the Anti-Money Laundering Act.

5.3 KYC Documents. Identity documents and KYC verification records are retained for a minimum of five (5) years from the date of the last transaction on your account, as required by RA 9160 (Anti-Money Laundering Act) and its implementing regulations.

5.4 Transaction Records. Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, in compliance with AMLC and PAGCOR requirements.

5.5 Support Communications. Customer support records are retained for three (3) years from the date of the interaction, or longer where the communication relates to an unresolved dispute or regulatory matter.

5.6 Marketing Data. Where you have consented to marketing communications, your contact data used for marketing purposes is retained until you withdraw your consent or request deletion, whichever occurs first.

6. Data Security

6.1 Technical Measures. 7bat implements appropriate technical security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption of personal data at rest and in transit using industry-standard protocols (TLS/SSL);
• Access controls limiting data access to authorized personnel on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform;
• Secure storage of KYC documents with restricted access logging;
• Multi-factor authentication requirements for administrative access to data systems.

6.2 Organizational Measures. In addition to technical controls, 7bat maintains organizational security measures including staff training on data privacy obligations, confidentiality agreements with all personnel who handle personal data, and documented data handling procedures.

6.3 Your Responsibilities. You are responsible for maintaining the security of your account credentials. 7bat will never ask you for your password via email, chat, or phone. If you suspect that your account has been compromised, you must notify 7bat immediately through the customer support channels.

6.4 Limitations. While 7bat takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. 7bat cannot guarantee absolute security but commits to promptly addressing any security incidents in accordance with its breach response procedures described in Section 11.

7. Your Rights Under RA 10173

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by 7bat:

• Right to be Informed: You have the right to be informed of how your personal data is being collected and processed, including the purposes of processing, the identity of the data controller, and the recipients of your data. This Privacy Policy fulfills this obligation.
• Right to Access: You have the right to request a copy of the personal data that 7bat holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data that 7bat holds about you. You may update certain account information directly through your account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where processing is unlawful. This right is subject to 7bat's legal obligations to retain certain data under PAGCOR and AMLA regulations.
• Right to Object: You have the right to object to the processing of your personal data where such processing is based on legitimate interest, including processing for direct marketing purposes.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that such data be transmitted to another data controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that your data privacy rights have been violated. The NPC can be reached through its official website at privacy.gov.ph.

8. Cookies and Tracking Technologies

8.1 What Are Cookies. Cookies are small text files placed on your device when you visit the Platform. They allow the Platform to recognize your device, maintain your session, and remember your preferences across visits.

8.2 Types of Cookies Used. 7bat uses the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function. They maintain your login session, remember your language preference, and ensure security features operate correctly. These cookies cannot be disabled without affecting Platform functionality.
• Functional Cookies: These cookies remember your preferences and settings, such as your responsible gaming limits and notification preferences, to provide a more personalized experience.
• Analytics Cookies: These cookies collect anonymized information about how players use the Platform, including which pages are visited most frequently and how players navigate between sections. This data is used solely to improve the Platform.

8.3 Third-Party Cookies. 7bat does not permit third-party advertising networks to place cookies on the Platform. Any third-party cookies present on the Platform are limited to those placed by payment processors and game providers strictly necessary for their respective services.

8.4 Managing Cookies. You can manage or disable cookies through your browser settings. Please note that disabling strictly necessary cookies will affect your ability to use the Platform, including your ability to log in and maintain a session. Instructions for managing cookies are available in your browser's help documentation.

9. Minors and Age Restriction

9.1 Strict 21+ Policy. The 7bat Platform is strictly for individuals who are twenty-one (21) years of age or older, in accordance with PAGCOR regulations governing online casino-style gaming in the Philippines. 7bat does not knowingly collect personal data from individuals under the age of 21.

9.2 Age Verification. As part of the KYC process, 7bat verifies the age of all registered players. Any account found to be held by a person under 21 years of age will be immediately suspended, and any personal data collected in connection with such an account will be deleted, except where retention is required by law.

9.3 Parental Notification. If you believe that a minor under the age of 21 has registered an account on the 7bat Platform or has provided personal data to 7bat, please contact our Data Protection Officer immediately using the contact details in Section 13. 7bat will take prompt action to investigate and, where confirmed, delete the relevant data and close the account.

10. Cross-Border Data Transfers

10.1 Primary Processing in the Philippines. 7bat's primary data processing operations are conducted within the Philippines. Personal data collected from Filipino players is stored on servers located in the Philippines or in jurisdictions that provide an adequate level of data protection as recognized by the NPC.

10.2 International Transfers. In certain circumstances, personal data may be transferred to or accessed from outside the Philippines — for example, where 7bat engages international service providers for platform infrastructure, security monitoring, or game delivery. Any such transfers are conducted in accordance with the DPA's requirements for cross-border data transfers, including the use of appropriate contractual safeguards.

10.3 Safeguards. Where personal data is transferred outside the Philippines, 7bat ensures that the recipient provides a level of data protection equivalent to that required under the DPA, either through contractual clauses approved by the NPC or by transferring data only to jurisdictions with adequate data protection laws.

11. Data Breach Procedures

11.1 Breach Response. In the event of a personal data breach that is likely to result in a real risk of serious harm to affected data subjects, 7bat will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, in accordance with NPC Circular No. 16-03 on Personal Data Breach Management.

11.2 Notification to Affected Players. Where a data breach is likely to result in a high risk to the rights and freedoms of affected players, 7bat will notify those players without undue delay. Notification will be provided via the email address registered to the affected account and will include a description of the nature of the breach, the categories of data affected, the likely consequences, and the measures taken or proposed to address the breach.

11.3 Breach Register. 7bat maintains an internal register of all personal data breaches, including those that do not require notification to the NPC or affected players. This register is available for inspection by the NPC upon request.

12. Amendments to This Policy

12.1 Right to Amend. 7bat 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. The updated Policy will be posted on this page with a revised effective date.

12.2 Material Changes. Where amendments are material — meaning they significantly affect how your personal data is processed or your rights as a data subject — 7bat will provide advance notice via email to your registered address at least fourteen (14) days before the changes take effect.

12.3 Continued Use. Your continued use of the 7bat Platform after the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with the amended Policy, you may close your account in accordance with the Terms and Conditions.

12.4 Version Archive. Previous versions of this Privacy Policy are available upon request by contacting the Data Protection Officer at the details provided in Section 13.

13. Contact and DPO Details

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 7bat, please contact our Data Protection Officer:

• Data Protection Officer: 7bat Data Privacy Office
• Email: [email protected]
• General Support Email: [email protected]
• Response Time: Within 15 business days for data subject requests; within 72 hours for urgent security matters
• Language: English

For complaints that cannot be resolved directly with 7bat, you may contact the National Privacy Commission of the Philippines:

• National Privacy Commission (NPC)
• Website: privacy.gov.ph (not a clickable link)
• Jurisdiction: Republic of the Philippines