ha88 Privacy Policy

01. Introduction

1.1 ha88 is committed to protecting the privacy and personal data of all players who use the Platform. This Policy has been prepared in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

1.2 This Policy applies to all personal data collected through the Platform, including data collected during registration, gameplay, financial transactions, customer support interactions, and your general use of ha88.one.

1.3 This Policy should be read together with the ha88 Terms & Conditions, which govern your use of the Platform. Capitalized terms not defined in this Policy have the meanings given to them in the Terms & Conditions.

1.4 This Policy is effective as of January 1, 2026. We may update this Policy from time to time. The most current version will always be available at ha88.one/privacy-policy.

02. Personal Data We Collect

2.1 ha88 collects the following categories of personal data from players:

Category	Examples	Purpose
Identity Data	Full name, date of birth, government-issued ID number, nationality	Account registration, KYC verification, age verification (21+)
Contact Data	Email address, mobile number, residential address	Account communications, support, notifications
Financial Data	GCash number, bank account details, transaction history	Processing deposits and withdrawals, AML compliance
Gaming Data	Game history, wager amounts, win/loss records, session duration	Game operation, responsible gaming monitoring, dispute resolution
Technical Data	IP address, device type, browser type, operating system, login timestamps	Security, fraud prevention, platform optimization
Usage Data	Pages visited, features used, click patterns, session duration	Platform improvement, personalization, analytics
Communications Data	Support chat logs, email correspondence, feedback submissions	Customer support, quality assurance, dispute resolution

2.2 Sensitive Personal Information. In certain circumstances, ha88 may collect sensitive personal information as defined under the Data Privacy Act, including government-issued identification numbers (e.g., PhilSys ID, passport, driver's license) for KYC purposes. Such data is handled with the highest level of care and is processed only to the extent necessary for legal compliance.

2.3 Voluntary Provision. You are not legally required to provide your personal data to ha88. However, failure to provide certain mandatory information (such as identity and contact data) will prevent us from creating your account or providing our services to you.

03. How We Collect Your Data

3.1 ha88 collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated technologies : Data collected automatically when you use the Platform, including cookies, log files, pixel tags, and similar tracking technologies that record your IP address, device identifiers, browser type, and usage patterns;
• Third-party sources: Data received from payment processors (such as GCash and Maya), identity verification providers, fraud prevention services, and regulatory bodies where permitted by law.

04. How We Use Your Personal Data

4.1 ha88 uses your personal data for the following purposes:

• To create, verify, and manage your player account;
• To process deposits, withdrawals, and other financial transactions;
• To verify your identity and age (21+) in compliance with KYC and PAGCOR requirements;
• To detect, investigate, and prevent fraud, money laundering, and other illegal activities;
• To operate, maintain, and improve the Platform and its games;
• To personalize your gaming experience and deliver relevant promotions;
• To send you account-related notifications, security alerts, and support communications;
• To monitor gameplay for responsible gaming purposes and enforce self-exclusion requests;
• To comply with applicable Philippine laws, PAGCOR regulations, and NPC guidelines;
• To resolve disputes and enforce our Terms & Conditions.

4.2 Marketing Communications. With your consent, ha88 may send you promotional emails or in-platform notifications about new games, bonuses, and special offers. You may withdraw your consent to receive marketing communications at any time by updating your account preferences or contacting our support team.

05. Legal Basis for Processing

5.1 ha88 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you, including account management and transaction processing;
• Legal obligation: Processing required to comply with applicable Philippine laws, including AML regulations, PAGCOR requirements, and NPC guidelines;
• Legitimate interests: Processing necessary for ha88's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent, particularly for marketing communications and non-essential cookies.

06. Data Sharing & Disclosure

6.1 ha88 does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary:

• Payment processors: GCash, Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your financial transactions;
• Identity verification providers: Third-party KYC and AML compliance service providers engaged to verify your identity and prevent fraud;
• Technology providers: Cloud hosting, data analytics, and platform infrastructure providers who process data on our behalf under strict data processing agreements;
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies where disclosure is required by law;
• Law enforcement: Philippine law enforcement agencies where disclosure is required by a valid court order, subpoena, or legal process;
• Professional advisers: Lawyers, auditors, and accountants bound by professional confidentiality obligations.

6.2 All third-party service providers who process personal data on behalf of ha88 are required to implement appropriate technical and organizational security measures and to process data only in accordance with ha88's instructions and applicable Philippine law.

07. Cookies & Tracking Technologies

7.1 ha88 uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function, including session management and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and display options to personalize your experience.
• Analytics cookies: Collect aggregated, anonymized data about how players use the Platform to help us identify areas for improvement.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access, and bot traffic.

7.2 You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. ha88 does not use cookies to track your activity across unrelated third-party websites.

08. Data Retention

8.1 ha88 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the duration of your account and for a period thereafter as required by applicable law.

8.2 Specifically, financial transaction records and KYC documentation are retained for a minimum of five (5) years following the closure of your account, in accordance with Philippine AML regulations and PAGCOR requirements.

8.3 Gaming history and account activity logs are retained for a minimum of three (3) years for dispute resolution and regulatory compliance purposes.

8.4 Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.

09. Data Security

9.1 ha88 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit;
• Encryption of sensitive data at rest using industry-standard algorithms;
• Role-based access controls limiting data access to authorized personnel only;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication for administrative access to systems containing personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

9.2 In the event of a personal data breach that is likely to result in harm to affected players, ha88 will notify the National Privacy Commission (NPC) and affected individuals in accordance with the requirements of the Data Privacy Act and NPC Circular No. 16-03.

10. Your Data Subject Rights

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ha88:

• Right to be informed: The right to be notified of how your personal data is being collected and processed;
• Right of access: The right to request a copy of the personal data ha88 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 your personal data, subject to ha88's legal retention obligations;
• Right to object: The right to object to the processing of your personal data on grounds relating to your particular situation, including processing for direct marketing purposes;
• Right to data portability: The right to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

10.2 To exercise any of the above rights, please contact our Data Protection Officer (DPO) using the contact details provided in Section 14 of this Policy. ha88 will respond to your request within thirty (30) days, as required by the Data Privacy Act.

10.3 Please note that certain rights are subject to limitations. For example, ha88 may be unable to delete data that it is legally required to retain, or data that is necessary to resolve an ongoing dispute.

11. Children's Privacy

11.1 ha88 implements age verification procedures during registration to prevent minors from accessing the Platform. If you are a parent or guardian and believe that your child has registered on the Platform, please contact our support team immediately at support@ha88.one so that we can take appropriate action.

12. International Data Transfers

12.1 ha88 primarily stores and processes personal data within the Philippines. In certain circumstances, personal data may be transferred to and processed in countries outside the Philippines — for example, where ha88 uses cloud infrastructure or technology service providers with servers located abroad.

12.2 Where personal data is transferred outside the Philippines, ha88 ensures that appropriate safeguards are in place to protect your data, including contractual clauses that require the recipient to provide a level of data protection equivalent to that required under Philippine law.

13. Updates to This Policy

13.1 ha88 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory requirements. When we make material changes, we will notify registered players via email or an in-platform notification prior to the changes taking effect.

13.2 The effective date at the top of this Policy indicates when it was last updated. Your continued use of the Platform after the effective date of any revised Policy constitutes your acceptance of the updated terms.

14. Contact & Data Protection Officer

14.1 ha88 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this Policy. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact our DPO:

Data Protection Officer — ha88
Email: support@ha88.one

14.2 If you are not satisfied with ha88's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.