ha77 Privacy Policy

ha77 ("ha77", "we", "us", "our") operates the online gaming platform accessible at https://ha77.one, designed primarily for players based in the Philippines. We understand that when you create an account, deposit funds, and play on ha77, you are trusting us with personal information that matters to you. We take that responsibility seriously.

This Privacy Policy describes how ha77 collects, uses, discloses, retains, and protects your personal data in the course of providing our gaming services. It also describes your rights in relation to that data and how you can exercise them.

This Policy applies to all users of the ha77 Platform, including registered players, users who browse the Platform without registering, and individuals who contact ha77 customer support. By creating an account or continuing to use the ha77 Platform, you confirm that you have read and understood this Privacy Policy.

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, ha77 is the data controller responsible for your personal data collected through the ha77 Platform.

If you have any questions or concerns about how ha77 processes your personal data, you may contact our Data Protection Officer (DPO) at: [email protected]

Please include "Data Privacy" in the subject line of your message so your enquiry is directed to the appropriate team promptly.

Ha77 collects personal data in the following categories:

Ha77 collects personal data through the following means:

• Direct provision by you: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the ha77 Platform, including IP addresses, device identifiers, session data, and cookies as described in Section 12.
• Third-party sources: Data received from identity verification service providers during KYC processing, payment processors (GCash, PayMaya, BPI, BDO, Metrobank) in the course of transaction processing, and fraud detection service providers.
• Regulatory sources: Information received from PAGCOR or other regulatory bodies in connection with compliance obligations, including self-exclusion registers.

Ha77 processes your personal data on the following legal bases under the Philippine Data Privacy Act and applicable data protection principles:

• Contractual necessity: Processing required to perform the gaming services contract with you — including account management, gameplay provision, payment processing, and customer support.
• Legal obligation: Processing necessary to comply with applicable laws, including KYC obligations, anti-money laundering reporting, PAGCOR regulatory requirements, and age verification mandates.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and improvement of ha77 services, where these interests do not override your privacy rights.
• Consent: Where ha77 relies on your consent for specific processing activities (such as certain marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

Ha77 uses collected personal data for the following specific purposes:

1. Account creation and management: Creating, maintaining, and securing your ha77 account, including authentication, password resets, and two-factor authentication processes.
2. Identity verification (KYC): Verifying your identity and age as required by applicable gaming regulatory obligations before processing withdrawal requests above applicable thresholds.
3. Payment processing: Processing your deposits and withdrawal requests through GCash, PayMaya, BPI, BDO, Metrobank, and any other supported payment methods, and maintaining transaction records.
4. Gameplay provision: Delivering gaming services, maintaining game session records, processing bet outcomes, and providing your gaming history.
5. Regulatory compliance: Meeting ha77's obligations under PAGCOR regulations, Philippine anti-money laundering laws (Republic Act 9160 as amended), the Data Privacy Act, and any other applicable laws.
6. Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, account takeover attempts, and other prohibited activities on the ha77 Platform.
7. Responsible gaming: Monitoring gaming patterns for potential problem gambling indicators, enforcing deposit limits, session limits, and self-exclusion restrictions set by you or required by regulation.
8. Customer support: Responding to your enquiries, resolving disputes, and maintaining records of support interactions for quality assurance.
9. Platform improvement: Analysing aggregated, anonymised usage data to improve ha77's services, user experience, and game library offerings.
10. Marketing communications: Sending promotional offers and updates where you have provided consent to receive such communications, and where this is consistent with applicable law. You may opt out at any time.

Ha77 does not sell, rent, or trade your personal data to third parties for commercial marketing purposes. Data is shared only in the following limited circumstances:

• Authorised service providers: Third-party vendors contracted to provide services to ha77, including payment processing (GCash, PayMaya, BPI, BDO, Metrobank), KYC and identity verification services, IT infrastructure providers, and customer support platform operators. These service providers are contractually bound to process data only on ha77's instructions and to maintain appropriate security standards.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission of the Philippines, law enforcement agencies, and other governmental authorities where disclosure is required or permitted by applicable Philippine law.
• Fraud prevention and security: Fraud prevention bureaus and financial crime detection services where sharing is necessary to protect the integrity of the Platform and the interests of ha77 and its players.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of ha77's business operations, personal data may be transferred to the acquiring entity, subject to appropriate confidentiality obligations and notification to affected players.
• With your consent: To any third party where you have provided explicit consent to such disclosure.

Where ha77 transfers personal data to service providers or infrastructure located outside the Philippines, we ensure that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Philippine Data Privacy Act. These safeguards may include contractual data protection clauses, adequacy determinations, or other mechanisms approved by the National Privacy Commission of the Philippines.

Ha77 takes a data minimisation approach to international transfers — only the minimum data necessary for the specific service purpose is transmitted across borders, and only to recipients bound by equivalent data protection obligations.

Ha77 implements a layered security framework to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security measures include:

• Encryption in transit: All data transmitted between your device and ha77's servers is encrypted using industry-standard Transport Layer Security (TLS) protocols, equivalent to the encryption used by licensed Philippine banking institutions.
• Encryption at rest: Sensitive personal data and financial records stored on ha77's infrastructure are encrypted using strong cryptographic standards.
• Access controls: Strict role-based access controls limit access to personal data to ha77 personnel who require it for legitimate operational purposes. All staff with data access are subject to confidentiality obligations and appropriate training.
• Two-factor authentication: ha77 offers SMS-based two-factor authentication for player accounts and requires it for internal administrative access to sensitive systems.
• Regular security assessments: Ha77's technical infrastructure undergoes periodic security reviews and vulnerability assessments to identify and remediate potential weaknesses.
• Incident response: Ha77 maintains a documented data breach response procedure. In the event of a breach affecting your personal data, ha77 will notify the National Privacy Commission and affected players in accordance with the timelines prescribed by the Data Privacy Act and its Implementing Rules.

Ha77 retains personal data only for as long as necessary to fulfil the purposes for which it was collected and to comply with applicable legal, regulatory, and operational requirements. The following retention periods apply as general guidelines:

Upon expiry of the applicable retention period, ha77 will securely delete or anonymise personal data in accordance with industry-standard data destruction procedures.

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by ha77:

Cookies are small text files placed on your device when you access the ha77 Platform. They allow ha77 to recognise your device across sessions and provide a consistent, secure user experience.

• Strictly Necessary Cookies: Essential for the operation of the ha77 Platform — including session management, login authentication, and security functions. These cannot be disabled without disrupting core platform functionality.
• Functional Cookies: Remember your preferences and settings (e.g., language selection, game view preferences) to improve your experience across sessions.
• Analytical Cookies: Collect anonymised data on how players interact with the ha77 Platform to help us understand usage patterns and improve performance. Ha77 uses aggregated, non-identifiable data for this purpose.
• Security Cookies: Support fraud detection and prevention systems, including device fingerprinting used to identify suspicious login attempts from unfamiliar devices.

You may configure your browser to refuse some or all cookies, or to alert you when cookies are being placed. Note that disabling strictly necessary cookies will affect your ability to use key features of the ha77 Platform, including logging into your account. Analytical cookies may be declined without affecting your gaming experience.

Some ha77 service providers (such as analytics and payment processing partners) may set their own cookies when you interact with their components on the ha77 Platform. These third-party cookies are subject to the privacy policies of the respective providers.

The ha77 Platform is strictly intended for adults aged 18 years and above. Ha77 does not knowingly collect personal data from individuals under the age of 18. Age verification is a required component of the ha77 KYC process, and any account found to have been registered by a person under 18 will be closed immediately.

Where ha77 discovers that personal data has been collected from a minor — whether through a registration misrepresentation or any other means — such data will be deleted as promptly as possible, and the incident will be reported to appropriate regulatory authorities as required by applicable law.

Ha77 processes gaming activity data and account usage patterns for responsible gaming monitoring purposes. This includes automated monitoring for behavioural indicators associated with problem gambling, enforcement of self-imposed limits, and compliance with any regulatory requirements regarding player protection measures.

Responsible gaming data — including self-exclusion records, limit settings, and any responsible gaming assessments — is treated with a heightened level of confidentiality. This data is accessed only by authorised responsible gaming personnel and is never used for marketing or profiling purposes unrelated to player protection.

Where a player is added to a regulatory self-exclusion register administered by PAGCOR or any other relevant authority, ha77 is required to process that registration data in order to enforce the exclusion across the ha77 Platform. This processing is required by law and cannot be refused.

For more information about ha77's responsible gaming tools, please visit the ha77 Responsible Gaming page at https://ha77.one/responsible-gaming.

Ha77 reserves the right to update or modify this Privacy Policy at any time. The most current version will always be available at https://ha77.one/privacy-policy, with the effective date clearly indicated at the top of the document.

Where amendments are material — meaning they significantly change how ha77 processes your personal data or your rights in relation to that data — ha77 will notify registered players via the email address associated with their account, or through a prominent notice on the Platform, at least seven (7) days prior to the changes taking effect.

Continued use of the ha77 Platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with any updated terms, you should cease using the Platform and request account closure.

For any questions, concerns, or requests relating to this Privacy Policy or ha77's data processing practices, please contact:

Data Protection Officer, ha77
Email: [email protected]
Please include "Data Privacy" in the subject line. We aim to respond within 15 business days.

If you are not satisfied with ha77's response to your privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC). The NPC is the independent supervisory authority responsible for overseeing compliance with the Philippine Data Privacy Act.

Information about how to lodge a complaint with the NPC is available on the NPC's official government website. Ha77 cooperates fully with NPC investigations and complies with all NPC orders and recommendations.