haha88 Privacy Policy

1 Who We Are & Scope of This Policy

haha88 ("Company," "we," "us," "our") operates the online casino and sports betting platform accessible at haha88.one (the "Platform"). haha88 acts as the Personal Information Controller (PIC) under the Philippine Data Privacy Act of 2012 (RA 10173) in respect of the personal data of Philippine-resident users of the Platform.

This Privacy Policy applies to all personal data collected through your use of the Platform, including data collected during account registration, identity verification (KYC), deposits, withdrawals, gameplay, customer support interactions, and any marketing communications you have opted to receive.

This Policy should be read alongside haha88's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. By creating a haha88 account, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

2 Personal Data We Collect

haha88 collects the following categories of personal data, depending on the nature of your interaction with the Platform:

• Full legal name;
• Date of birth (for age verification — players must be 21+);
• Philippine mobile number or email address;
• Account username and encrypted password; and
• Residential address (province, city, barangay).

• Copy of valid government-issued photo ID (e.g., passport, driver's license, UMID, PhilHealth ID, SSS ID, PRC ID);
• Selfie photograph or proof-of-liveness image;
• Proof of address documentation, where requested by the compliance team; and
• Tax Identification Number (TIN), where required for reporting obligations.

• GCash account number or PayMaya account details registered to your name;
• Bank account name, number, and institution (BPI, BDO, Metrobank, or other Philippine banks);
• Cryptocurrency wallet addresses where applicable;
• Deposit and withdrawal transaction histories; and
• Wagering and gaming activity records.

• IP address and geolocation data at time of login;
• Device identifiers, operating system, and browser type;
• Session duration, pages visited, and features accessed;
• Login timestamps and access logs; and
• Cookie and tracking technology data (see Section 6).

• Records of live chat conversations, emails, and support tickets;
• Content of communications submitted to haha88 in connection with a complaint, dispute, or inquiry; and
• Call recordings, where applicable and where you have been notified of recording.

3 How We Use Your Personal Data

haha88 processes your personal data for the following specific purposes:

4 Legal Basis for Processing

haha88 processes personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform the contract you have with haha88 — including account management, gaming services, and payment processing;
• Legal Obligation: Processing required to comply with PAGCOR regulations, AMLA obligations, NPC requirements, and other applicable Philippine law;
• Legitimate Interests: Processing necessary for fraud detection, security monitoring, platform improvement, and responsible gaming administration, where our legitimate interests are not overridden by your data protection rights; and
• Consent: Processing for marketing and promotional communications, where we rely on your explicit opt-in consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

5 Data Sharing & Disclosure

haha88 does not sell, rent, or trade your personal data. We share personal data with third parties only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment Processors: GCash (G-Xchange, Inc.), PayMaya (Voyager Innovations), BPI, BDO, Metrobank, and cryptocurrency payment gateway providers — for the sole purpose of processing deposits and withdrawals;
• KYC & Identity Verification Services: Accredited identity verification partners to assist with document authentication and age verification;
• Game Providers: JILI, PG Soft, Pragmatic Play, and other licensed game studios receive the minimum player session data required to operate their games within the haha88 platform environment;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities where disclosure is required by law, court order, or regulatory mandate;
• Legal Advisors & Auditors: Professional advisors and independent auditors engaged by haha88 under confidentiality obligations; and
• Business Succession: In the event of a merger, acquisition, or sale of haha88's business or assets, personal data may be transferred to the successor entity subject to at least equivalent privacy protections.

All third-party data processors engaged by haha88 are subject to written data processing agreements requiring them to process personal data only on haha88's documented instructions and to implement appropriate technical and organizational security measures.

6 Cookies & Tracking Technologies

haha88 uses cookies and similar tracking technologies on its Platform for the following purposes:

• Strictly Necessary Cookies: Required for Platform functionality, including maintaining your logged-in session state and preserving security settings. These cannot be disabled without rendering core platform functions inoperable.
• Performance & Analytics Cookies: Used to collect aggregated, anonymized data about how users navigate the Platform, which pages load most slowly, and which features are most used. This data helps haha88 improve platform performance and stability.
• Functional Cookies: Store your preferences, such as language settings and game lobby view preferences, to provide a personalized experience on return visits.
• Responsible Gaming Cookies: Maintain session start timestamps to support session time limit tools activated by players under account settings.

You may manage cookie preferences through your browser settings. Disabling non-essential cookies may affect the functionality and personalization features of the Platform. haha88 does not use third-party advertising cookies or cross-site tracking technologies for behavioral advertising purposes.

7 Data Retention

haha88 retains personal data for the periods necessary to fulfil the purposes for which it was collected, subject to the following minimum retention requirements imposed by Philippine law and PAGCOR regulations:

• Account Data: Retained for the duration of your account's active status and for a minimum of 5 years following account closure, in compliance with AMLC record-keeping requirements;
• KYC Documents: Retained for a minimum of 5 years from the date of account closure, as required by the Anti-Money Laundering Act;
• Transaction Records: Retained for a minimum of 5 years from the date of the transaction, in accordance with AMLC and PAGCOR requirements;
• Support Communication Records: Retained for 3 years from the date of the final communication, or longer where the communication relates to an unresolved dispute; and
• Technical Logs: Retained for 1 year for security and fraud detection purposes.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymized in a manner that prevents identification of the individual data subject.

8 Data Security Measures

haha88 implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include:

• TLS/SSL encryption for all data in transit between the Platform and your device;
• AES-256 encryption for sensitive data at rest on haha88 servers;
• Multi-factor authentication options for player accounts;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing by accredited third-party security firms;
• Intrusion detection systems and 24/7 security monitoring; and
• Employee data protection training and confidentiality obligations.

In the event of a personal data breach that is likely to adversely affect your rights and freedoms, haha88 will notify you and the National Privacy Commission within the timeframes required by the Philippine Data Privacy Act and its Implementing Rules and Regulations.

9 Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, as a data subject you have the following rights in respect of personal data processed by haha88:

To exercise any of the above rights, submit a written request to haha88's Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." Include your registered username, a description of the right you wish to exercise, and any relevant details. haha88 will respond within 15 business days of receipt, or within the period required by applicable law if shorter.

10 Cross-Border Data Transfers

Some of haha88's third-party service providers — including game studios and certain cloud infrastructure partners — are located outside the Philippines. Where personal data is transferred outside the Philippines, haha88 ensures that such transfers comply with the requirements of the Philippine Data Privacy Act, including:

• Transferring data only to recipients in jurisdictions that provide an adequate level of protection for personal data; or
• Implementing standard contractual clauses or other appropriate safeguards approved by the NPC where transfers are made to recipients in jurisdictions not deemed adequate.

In all cases, data transferred internationally is subject to the same level of protection as described in this Privacy Policy, and haha88 remains responsible for ensuring appropriate safeguards are in place.

11 Children's Privacy & Underage Access

haha88 is strictly an adults-only platform. The minimum age to register and use haha88 is 21 years, consistent with the legal gambling age in the Philippines under applicable PAGCOR regulations. haha88 does not knowingly collect personal data from individuals under the age of 21.

If haha88 becomes aware that personal data has been collected from a person under 21, we will immediately close the associated account, return any real money balance (subject to AML obligations), delete the collected personal data, and report the incident as required by applicable regulations.

If you believe a person under the age of 21 has registered a haha88 account, please contact us immediately at [email protected] so we can take appropriate action.

12 Marketing Communications

haha88 may send you marketing communications about promotions, bonuses, new games, and platform updates — but only where you have explicitly opted in to receive such communications during account registration or through your account communication settings.

You may opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email;
• Updating your notification preferences under Account Settings → Communication Preferences; or
• Submitting a written opt-out request to [email protected].

Opting out of marketing communications does not affect the delivery of transactional communications that are necessary for account operation, such as deposit confirmations, withdrawal notifications, security alerts, and responsible gaming notifications.

13 Third-Party Links

The haha88 Platform may contain links to third-party websites or services — for example, payment gateway portals or game provider interfaces — that are not operated by haha88. This Privacy Policy does not apply to third-party websites or services. haha88 has no control over the content, privacy policies, or data practices of third-party sites and accepts no responsibility for them.

We encourage you to review the privacy policies of any third-party services you access through the haha88 Platform, particularly your GCash, PayMaya, or bank's privacy policy, before providing personal data to those services.

14 Changes to This Privacy Policy

haha88 may update this Privacy Policy from time to time to reflect changes in our data processing practices, Philippine legal requirements, NPC guidance, or PAGCOR regulatory updates. Material changes — meaning changes that alter your rights or our data collection and processing activities in a significant way — will be communicated to registered players via email or on-Platform notice at least 7 days before taking effect.

The "Last Updated" date at the top of this Policy reflects the date of the most recent revision. Continued use of haha88 following the effective date of a revised Privacy Policy constitutes your acknowledgment of the changes. We recommend reviewing this Policy periodically.

Previous versions of this Privacy Policy are available upon request from haha88's Data Protection Officer.

15 Contact & Data Protection Officer

haha88 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. For any privacy-related inquiries, requests to exercise your data subject rights, or to report a potential data protection concern, contact the haha88 DPO through the following channels:

• Email: [email protected] — use the subject line "Privacy / DPO" for faster routing;
• Live Chat: Available 24/7 from your haha88 account dashboard — ask to be connected with the data protection team.

If you are not satisfied with haha88's response to a privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines at privacy.gov.ph.