Privacy Policy

77haha ("the Company," "we," "us," or "our") operates the online gaming platform accessible at 77haha.vip. We are committed to protecting the privacy and personal data of every individual who interacts with our platform, whether as a registered player, a visitor browsing our website, or a person contacting our customer support team.

This Privacy Policy ("Policy") describes our practices regarding the collection, use, storage, disclosure, and protection of personal information in connection with your use of the 77haha platform. It applies to all players across the Philippines — from Metro Manila and Cebu to Davao and Iloilo — and to all services offered through 77haha.vip.

This Policy is to be read together with the 77haha Terms & Conditions. By registering for or using the 77haha platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein. If you do not agree to this Policy, please do not access or use the platform.

For the purposes of the Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, 77haha is the Personal Information Controller ("PIC") in respect of the personal data you provide when using the platform.

As the PIC, 77haha determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is conducted lawfully, fairly, and transparently. Our designated Data Protection Officer ("DPO") can be contacted via the details provided in Section 15 of this Policy.

Where 77haha engages third-party service providers to process personal data on its behalf (for example, payment processors, KYC verification providers, or game software suppliers), such providers act as Personal Information Processors ("PIP") and are contractually bound to process data only in accordance with 77haha's instructions and this Policy.

77haha collects personal data from you directly (when you register, deposit, or contact support), automatically (through your use of the platform), and from third parties (such as KYC verification services and payment processors). The categories of personal data we collect include:

77haha does not intentionally collect sensitive personal information (as defined under the Data Privacy Act of 2012) beyond what is strictly necessary for identity verification, responsible gaming compliance, and regulatory reporting. We do not collect biometric data except where a player voluntarily submits a selfie photograph as part of the KYC process.

77haha processes your personal data on the following legal bases as prescribed under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing is necessary to perform the contract between you and 77haha — principally, to create and maintain your account, process deposits and withdrawals, and deliver the gaming services you have subscribed to.
• Legal obligation: Processing is required for compliance with applicable laws, including anti-money laundering (AML) regulations, PAGCOR reporting requirements, the Data Privacy Act of 2012, and any lawful order or request from a competent government authority.
• Legitimate interests: Processing is necessary to protect the security of the platform, detect and prevent fraud, abuse, and prohibited conduct, and to improve platform performance and user experience, where these interests are not overridden by your fundamental rights.
• Consent: Where we rely on your consent (for example, to send you marketing communications), you may withdraw that consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

77haha uses personal data collected from you for the following specific purposes:

5.1 Account Management & Service Delivery

We use your identity and contact data to create and maintain your 77haha account, authenticate your identity at login, and provide access to gaming services, deposit and withdrawal facilities, and customer support. This processing is necessary to perform our contractual obligations to you.

5.2 Payment Processing

Financial data is used to facilitate deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels. All payment processing is handled in partnership with certified payment processors and is subject to their respective privacy policies.

5.3 Identity Verification & KYC

Identity documents and verification data are processed to confirm that you meet the eligibility requirements for the platform (including the 21+ age requirement), to comply with anti-money laundering obligations, and to satisfy PAGCOR KYC requirements.

5.4 Fraud Prevention & Platform Security

Technical data, gaming activity data, and financial data are used to detect and prevent fraudulent activity, multi-accounting, collusion, money laundering, and other prohibited conduct. We also use this data to maintain the integrity and security of the 77haha platform.

5.5 Responsible Gaming

Gaming activity data and account settings are used to administer responsible gaming tools, including deposit limits, loss limits, session time alerts, and self-exclusion. This processing is conducted in fulfilment of our regulatory obligations and in the genuine interest of player welfare.

5.6 Legal & Regulatory Compliance

We may process and retain your personal data as required to comply with applicable laws, respond to lawful requests from government authorities, and meet our reporting obligations to PAGCOR and other relevant regulators.

5.7 Customer Support

Communications data is processed to respond to your support enquiries, resolve account issues, and maintain records of interactions for quality assurance and training purposes.

77haha does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may disclose your personal data to the following categories of recipients strictly where necessary:

All third-party service providers who receive personal data from 77haha are bound by data processing agreements that require them to maintain appropriate security measures, process data only for the specified purpose, and comply with applicable data protection laws.

77haha uses cookies and similar tracking technologies (including web beacons and local storage objects) on its platform. Cookies are small text files stored on your device when you visit a website. They help us provide you with a better experience by remembering your preferences, keeping you signed in, and measuring how the platform is used.

7.1 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication tokens and security cookies. They cannot be disabled without breaking core platform functionality.
• Functional Cookies: Remember your preferences, such as language settings, preferred game categories, and responsible gaming settings.
• Performance & Analytics Cookies: Collect anonymised data about how visitors use the platform — which pages are visited most, where errors occur — to help us improve the user experience.
• Security Cookies: Used to detect and prevent fraud, identify suspicious login patterns, and support our security monitoring systems.

7.2 Managing Cookies

You can control cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, or be notified when a cookie is set. Please note that disabling strictly necessary cookies will prevent you from logging in or using core platform features. For detailed instructions on managing cookies in your specific browser, refer to your browser's help documentation.

77haha retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting requirements. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in accordance with PAGCOR's record-keeping requirements and AML obligations under Republic Act No. 9160.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, consistent with anti-money laundering regulations.
• KYC documents: Retained for the minimum period required by PAGCOR and applicable AML regulations, which is generally five (5) years from the date of account closure.
• Customer support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Gaming activity logs: Retained for a minimum of one (1) year for operational purposes and up to five (5) years where required for regulatory compliance.
• Marketing preferences: Retained until you withdraw consent or close your account, after which they are deleted within ninety (90) days.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an individual. Where data cannot be immediately deleted due to backup cycles or archival systems, it is isolated from further active processing until deletion is completed.

77haha implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Transport Layer Security (TLS 1.3): All data transmitted between your browser and the 77haha platform is encrypted in transit. This prevents interception of your credentials and personal information during transmission.
• Password hashing: Account passwords are stored using industry-standard hashing algorithms. Passwords are never stored in plain text and are not accessible even to 77haha staff.
• Access controls: Access to personal data is restricted to staff and systems with a legitimate operational need. Access is governed by role-based permissions, multi-factor authentication, and regular access reviews.
• Intrusion detection and monitoring: Our platform infrastructure is monitored continuously for suspicious activity, attempted intrusions, and anomalous access patterns.
• Data encryption at rest: Sensitive personal data, including KYC documents and financial records, is stored in encrypted form.
• Security assessments: We conduct regular vulnerability assessments and penetration testing of our platform infrastructure.

Despite these measures, no method of electronic data storage or transmission over the internet can be guaranteed to be completely secure. In the unlikely event of a personal data breach that is likely to result in a risk to your rights and freedoms, 77haha will notify the National Privacy Commission (NPC) and affected individuals in accordance with the requirements of the Data Privacy Act of 2012 and its Implementing Rules and Regulations.

Under the Data Privacy Act of 2012 (Republic Act No. 10173), you are entitled to the following rights with respect to your personal data held by 77haha:

To exercise any of these rights, submit a written request to the 77haha Data Protection Officer via the contact details in Section 15. We will respond within fifteen (15) working days of receiving a valid, verifiable request. We may require you to confirm your identity before processing your request to prevent unauthorised access to personal data.

If you believe that 77haha has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on filing a complaint is available at the NPC's official website.

The 77haha platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect personal data from persons under the age of 21. Registration by persons under this age is prohibited under our Terms & Conditions and applicable PAGCOR regulations.

If we become aware that we have inadvertently collected personal data from an individual under 21 years of age, we will take immediate steps to delete such data and close the associated account. Parents and guardians who believe that a minor under their care has registered for or used the 77haha platform should contact our Data Protection Officer immediately using the details provided in Section 15.

Some of the third-party service providers used by 77haha — including game software providers, analytics services, and security infrastructure partners — may be located or operate servers in jurisdictions outside the Philippines. Where personal data is transferred outside the Philippines, 77haha ensures that such transfers are made in compliance with the Data Privacy Act of 2012, including by:

• Transferring data only to countries or organisations that provide an adequate level of data protection as recognised under Philippine law;
• Where an adequacy finding does not exist, implementing contractual safeguards (such as standard data protection clauses) with the recipient to ensure your data receives equivalent protection; and
• Ensuring that all cross-border transfers are limited to the minimum data necessary for the stated purpose.

You may request information about the specific safeguards in place for any particular cross-border data transfer by contacting the 77haha Data Protection Officer.

Where you have provided your consent during registration or through your account settings, 77haha may send you promotional communications about new games, bonuses, and offers available on the platform. These communications may be delivered via SMS to your registered Philippine mobile number or by other in-platform notification channels.

You may withdraw your consent to receive marketing communications at any time by updating your notification preferences in your account settings. Withdrawing consent will not affect the lawfulness of any marketing communications sent before the withdrawal, and will not affect any other aspect of your account or the services available to you.

77haha does not share your personal data with third parties for the purpose of those third parties sending you their own marketing communications.

77haha reserves the right to update or amend this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or regulatory requirements. Material changes to this Policy will be communicated to registered players via the mobile number or other contact details associated with their 77haha account, and an updated version of the Policy will be published on this page with a revised effective date.

Your continued use of the 77haha platform following the effective date of any revised Policy constitutes your acceptance of the updated terms. We recommend that you review this Privacy Policy periodically to remain informed of how we handle your personal data. If you have any concerns about changes to this Policy, please contact our Data Protection Officer before continuing to use the platform.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 77haha, you may contact our Data Protection Officer through the following channels:

• DPO Email: [email protected] (plain text — not a clickable link)
• Subject line: Please include "Privacy / DPO Request" in the subject line of your email to ensure prompt routing to our Data Protection Officer.
• Live Chat: Available 24/7 through the support widget inside your logged-in 77haha account. For DPO-related matters, request escalation to the privacy team.
• Response time: We aim to acknowledge all privacy-related requests within five (5) working days and to provide a substantive response within fifteen (15) working days.

For complaints that cannot be resolved directly with 77haha, you have the right to escalate your concern to the National Privacy Commission of the Philippines, the competent supervisory authority for data protection matters under the Data Privacy Act of 2012.