🔒 77haha Privacy Policy

1. Introduction

77haha ("77haha," "we," "us," or "our") operates the online gaming platform accessible at https://77haha.app and provides online casino, sports betting, bingo, and related gaming services to eligible players in the Philippines. As a personal information controller under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations, 77haha is responsible for the lawful, fair, and transparent processing of your personal data.

This Privacy Policy describes what personal information 77haha collects from you, how we use and share it, the legal bases for that processing, how long we retain it, and the rights you have over your personal data. It applies to all users of the 77haha platform, including registered players in Manila, Cebu, Davao, Quezon City, and across the entire Philippines.

By registering an account on 77haha, accessing the website, or using any part of the Service, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy. This Privacy Policy forms part of and should be read together with the 77haha Terms & Conditions.

2. Personal Data We Collect

77haha collects only the personal data necessary to provide the Service, maintain regulatory compliance, and protect the integrity of the platform. The categories of personal data we collect include:

2.1 Identity and Contact Data

• Full legal name as it appears on your government-issued Philippine identification document
• Date of birth (to verify you are at least 21 years of age as required by PAGCOR)
• Philippine residential address (barangay, city, province)
• Email address
• Philippine mobile phone number (Globe, Smart, or DITO)
• Government-issued ID type and number (e.g., Philippine passport, Driver's License, PhilSys National ID, SSS/UMID card)

2.2 Financial Data

• GCash account number and registered mobile number
• PayMaya / Maya wallet credentials (account number only)
• BPI, BDO, Metrobank, or other Philippine bank account details provided for withdrawals
• Deposit and withdrawal transaction history
• Source of funds declarations (where required for regulatory compliance)

2.3 Gaming and Usage Data

• Game history, bet amounts, outcomes, and session durations
• Account balance and bonus credit records
• Login timestamps, device type, and IP addresses
• Customer support interaction records (chat logs, email correspondence)

2.4 Technical Data

• Browser type and version
• Operating system and device identifiers
• Internet service provider and approximate geolocation (province/city level)
• Cookies and similar tracking technology data (see Section 7)

3. How We Collect Your Personal Data

77haha collects personal data through the following channels:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey or promotion.
• Automatically: Through cookies, web beacons, and server logs when you browse the 77haha website or use the platform, which capture technical and usage data.
• From third parties: From payment processors (e.g., GCash, PayMaya) to confirm transaction status; from identity verification service providers used for KYC compliance; and from fraud prevention and anti-money laundering screening services.

4. How We Use Your Personal Data

77haha uses your personal data for the following purposes:

Purpose	Data Used
Account registration and authentication	Identity, contact, technical data
Age and identity verification (KYC)	Identity data, government ID
Processing deposits and withdrawals	Financial data, identity data
Providing gaming services and maintaining game records	Gaming and usage data
Customer support and dispute resolution	All relevant data categories
Anti-money laundering (AML) compliance	Financial data, identity data
Fraud detection and prevention	Technical data, gaming and usage data
Responsible gaming monitoring and intervention	Gaming and usage data
Sending service-related communications (e.g., transaction confirmations, security alerts)	Contact data
Marketing and promotional communications (where you have opted in)	Contact data, preferences
Platform improvement and analytics	Technical data, usage data (aggregated/anonymised)
Regulatory reporting to PAGCOR	Identity, financial, gaming data

5. Legal Basis for Processing

77haha processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual necessity: Processing required to enter into and perform the player account agreement, including KYC verification, payment processing, and delivery of gaming services.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and other applicable Philippine laws.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications, where you have given explicit opt-in consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

77haha does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share personal data only in the following limited circumstances:

• Payment processors: GCash, PayMaya, and Philippine banking partners receive the minimum data necessary to process your financial transactions.
• KYC and AML service providers: Identity verification and anti-money laundering screening partners process your identity documents under strict data processing agreements.
• Game software providers: Our game studio partners receive anonymised session data necessary to deliver game content and verify outcomes. They do not receive your name, contact details, or financial data.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine regulatory bodies may receive data as required by law or court order.
• Professional advisors: Legal counsel, auditors, and accountants under confidentiality obligations.

All third-party data processors engaged by 77haha are bound by data processing agreements that require them to process personal data only as instructed by 77haha and to maintain appropriate security standards.

7. Cookies and Tracking Technologies

77haha uses cookies and similar technologies on the platform to maintain session state, personalise your experience, and gather aggregated analytics data. The main categories of cookies used are:

• Essential cookies: Required for the platform to function (e.g., login session cookies). These cannot be disabled.
• Functional cookies: Remember your preferences (e.g., language, display settings).
• Analytics cookies: Collect anonymised usage data to help us understand how players use the platform and improve it. No personally identifiable information is included in analytics reports.

You may configure your browser to refuse or delete non-essential cookies. Please note that disabling cookies may impair the functionality of certain platform features.

8. Data Retention

77haha retains personal data only for as long as necessary for the purposes for which it was collected, or as required by applicable law. In practice, this means:

• Account and KYC records are retained for a minimum of five (5) years following account closure, as required by PAGCOR licensing conditions and the AMLA.
• Financial transaction records are retained for a minimum of five (5) years in compliance with AMLA record-keeping obligations.
• Customer support interaction records are retained for three (3) years from the date of the last interaction.
• Marketing consent records are retained for three (3) years from the date of consent or until consent is withdrawn, whichever is earlier.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 77haha's data destruction protocols.

9. Data Security

77haha implements technical and organisational security measures proportionate to the risk and nature of the personal data processed. These measures include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmissions between your device and 77haha servers;
• Encryption of sensitive data at rest, including financial account details and identity document images;
• Role-based access controls ensuring that 77haha staff access personal data only on a need-to-know basis;
• Multi-factor authentication for administrative platform access;
• Regular penetration testing and security audits by independent third-party specialists;
• Automated anomaly detection and intrusion prevention systems monitoring for unauthorised access.

In the event of a personal data breach that is likely to adversely affect your rights, 77haha will notify the National Privacy Commission (NPC) within 72 hours of becoming aware of the breach and notify affected data subjects as required by the DPA Implementing Rules.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, as a data subject you have the following rights with respect to your personal data held by 77haha:

• Right to be Informed: The right to be informed of how your personal data is being processed — which this Privacy Policy fulfils.
• Right of Access: The right to request a copy of the personal data 77haha holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of personal data that is no longer necessary, subject to overriding legal retention obligations.
• Right to Object: The right to object to the processing of your personal data where processing is based on legitimate interests or for direct marketing purposes.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been infringed.

To exercise any of these rights, submit a written request to 77haha's Data Protection Officer at the contact details provided in Section 15. We will respond within thirty (30) days of receiving your request. We may require identity verification before processing a data subject request.

11. Children's Privacy

The 77haha platform is strictly intended for users who are 21 years of age or older. 77haha does not knowingly collect personal data from individuals under 21 years of age. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and permanently close the associated account.

If you have reason to believe that a person under 21 has registered on 77haha, please contact us immediately at [email protected] so that we may investigate and take appropriate action.

12. Cross-Border Data Transfers

77haha primarily stores and processes personal data on servers located within Southeast Asia. Where personal data is transferred to a jurisdiction outside the Philippines, 77haha ensures that appropriate safeguards are in place in accordance with NPC guidelines, including contractual clauses that impose data protection standards equivalent to those required under the Philippine DPA.

Game software providers whose servers may be located in other jurisdictions are required by contract to process Filipino player data in a manner consistent with Philippine data privacy law.

13. Third-Party Links and Services

The 77haha platform may reference payment services such as GCash and PayMaya, which are operated by third parties. When you interact with these third-party services, their own privacy policies govern the collection and use of your personal data. 77haha is not responsible for the privacy practices of third-party services and encourages you to review their privacy policies independently.

14. Updates to This Privacy Policy

77haha may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory guidance. Material changes will be communicated to registered players via email and/or in-platform notification prior to the effective date. The "Last Updated" date at the top of this policy indicates when the most recent version was published.

Continued use of the 77haha platform following the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not agree with the revised policy, you must cease using the platform and contact us to close your account.

15. Contact Us and Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact 77haha's Data Protection Officer:

• Email: [email protected]
• Subject Line: "Data Privacy Request" or "DPO Enquiry"
• Response Time: We aim to acknowledge all data privacy requests within five (5) business days and provide a full response within thirty (30) days.

You also have the right to file a complaint with the Philippine National Privacy Commission (NPC) at any time if you believe that 77haha has not handled your personal data in accordance with the Data Privacy Act of 2012.