ha77 Privacy Policy

1. Definitions

For the purposes of this Privacy Policy, the following terms have the meanings set out below:

• "Personal Data" means any information that relates to an identified or identifiable individual — for example, your name, email address, mobile number, date of birth, or device identifier.
• "Processing" means any operation performed on personal data, including collection, storage, use, transmission, and deletion.
• "Data Controller" means the entity that determines the purposes and means of processing personal data. In relation to ha77.io, ha77 is the Data Controller.
• "Data Processor" means a third party that processes personal data on behalf of the Data Controller under a contractual obligation.
• "KYC" means Know Your Customer — the identity verification process ha77 uses to confirm the identity of registered Players.
• "Cookies" means small text files placed on your device by ha77.io to facilitate session management, analytics, and platform functionality.
• "Platform" means the ha77.io website, all associated web pages, mobile-optimised interfaces, and any services accessible through them.

2. Personal Data We Collect

ha77 collects personal data in two broad categories: data you provide directly, and data collected automatically through your use of the platform.

2.1 Data You Provide Directly

When you register an account, verify your identity, make a deposit or withdrawal, or contact our support team, you may provide the following information:

• Identity Data: Full legal name, date of birth, gender, nationality.
• Contact Data: Email address, mobile phone number, residential address (city, district, Bangladesh).
• Account Credentials: Username and encrypted password (ha77 does not store plaintext passwords).
• KYC Documents: Scanned copies or photographs of your National ID card, passport, or driving licence; proof of address documents; selfie or liveness verification image.
• Payment Data: Mobile financial service account numbers (bKash, Nagad, Rocket, Upay) — ha77 does not store full card numbers or mobile wallet PINs.
• Communications Data: The content of messages, emails, and live chat conversations you initiate with the ha77 support team.
• Responsible Gaming Data: Deposit limits, session limits, cooling-off preferences, and self-exclusion requests you submit through your account settings.

2.2 Data Collected Automatically

When you browse or interact with ha77.io, certain technical data is collected automatically by our systems:

• Device Data: Device type, operating system version, browser type and version, screen resolution, and device language settings.
• Usage Data: Pages visited, games played, bets placed, session duration, click-stream data, and navigation paths through the platform.
• Location Data: General geographic location inferred from your IP address (city/region level — ha77 does not collect GPS-level location data).
• Log Data: Server logs including IP address, timestamps of access, HTTP request types, and error reports.
• Cookie Data: Session identifiers, preference cookies, and analytics identifiers as described in Section 7 of this policy.

3. How We Collect Your Data

ha77 collects personal data through the following channels:

• Account Registration Form: Identity and contact data entered when you create your ha77 account.
• KYC Verification Submission: Identity documents uploaded through the secure KYC portal within your account dashboard.
• Payment Transactions: Payment account identifiers provided when you initiate a deposit or withdrawal via bKash, Nagad, Rocket, or Upay.
• Customer Support Interactions: Data shared in emails, live chat sessions, or support tickets submitted to the ha77 team.
• Platform Activity: Automatically collected through cookies, server logs, and session tracking as you use ha77.io.
• Account Settings Changes: Information you provide when updating your profile, setting responsible gaming limits, or submitting a self-exclusion request.

4. Why We Use Your Personal Data

ha77 uses the personal data it collects for the following specific purposes:

Purpose	Data Used	Basis
Account creation and management	Identity, contact, credentials	Contract performance
Identity verification (KYC)	Identity documents, selfie	Legal obligation
Processing deposits and withdrawals	Payment data, identity data	Contract performance
Fraud prevention and security monitoring	Log data, device data, IP address	Legitimate interests
Responsible gaming compliance	Usage data, responsible gaming preferences	Legal obligation / consent
Customer support delivery	Communications data, account data	Contract performance
Platform analytics and improvement	Usage data, cookie data, device data	Legitimate interests
Promotional communications (opt-in)	Contact data, usage preferences	Consent
Legal and regulatory compliance	All relevant data categories	Legal obligation

ha77 does not use your personal data for purposes beyond those listed above without first seeking your explicit consent or establishing a new legitimate legal basis for the processing.

5. Legal Basis for Processing

ha77 processes personal data only where a valid legal basis exists. The legal bases we rely on are:

• Contract Performance: Processing that is necessary to deliver the services you have requested when creating a ha77 account, including account management, payment processing, and game access.
• Legal Obligation: Processing required to comply with applicable laws and regulatory requirements, including anti-money laundering (AML) obligations, KYC verification requirements, and responsible gaming mandates.
• Legitimate Interests: Processing carried out in the legitimate interests of ha77 or a third party, provided those interests are not overridden by your rights. This includes fraud detection, security monitoring, platform analytics, and service improvement. ha77 has conducted legitimate interests assessments for all processing activities under this basis.
• Consent: Processing based on your freely given, specific, and informed consent. This applies to optional marketing communications and non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

ha77 does not sell or rent your personal data to any third party. We may share personal data with third parties only in the following circumstances:

6.1 Payment Service Providers

When you make a deposit or withdrawal, the relevant mobile financial service provider (bKash, Nagad, Rocket, or Upay) will receive transaction data necessary to process the payment. These providers operate their own privacy policies and are independent data controllers in respect of their own processing. ha77 shares only the minimum data required to complete the transaction.

6.2 Identity Verification Services

ha77 may use third-party KYC and identity verification services to assist in confirming the identity of Players as required by our anti-fraud and responsible gaming obligations. These providers act as Data Processors under binding data processing agreements with ha77 and are prohibited from using Player data for any purpose other than KYC verification on ha77's behalf.

6.3 Technology and Infrastructure Providers

ha77 engages third-party cloud hosting providers, content delivery networks, and platform infrastructure services to operate ha77.io. These providers may process personal data as part of their service delivery and do so under contractual data processing agreements that restrict how data may be used.

6.4 Game Content Providers

ha77 integrates games developed by third-party game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi. Certain anonymised or aggregated usage data may be shared with these providers for the purpose of game performance monitoring and player experience improvement. ha77 does not share individually identifiable personal data with game studios.

6.5 Legal and Regulatory Disclosure

ha77 may disclose personal data to law enforcement agencies, regulatory bodies, or other governmental authorities where required or permitted by law — for example, in response to a valid court order, subpoena, or where disclosure is necessary to prevent fraud or criminal activity.

7. Cookies and Tracking Technologies

ha77.io uses cookies and similar tracking technologies to ensure the platform functions correctly, to measure performance, and to provide a personalised experience. The categories of cookies we use are as follows:

Cookie Type	Purpose	Required?
Essential / Session	Maintain your login session, remember your account state, and enable core platform functionality. Without these cookies, ha77.io cannot function correctly.	Yes — cannot be disabled
Functional / Preference	Remember your platform preferences such as display settings, responsible gaming limits interface, and language preferences.	Optional
Analytics / Performance	Collect anonymised data about how users navigate ha77.io — pages visited, session duration, and error rates — to help us improve the platform.	Optional
Security	Assist in detecting and preventing fraudulent or abusive activity on the platform, including bot detection and IP reputation scoring.	Yes — cannot be disabled

ha77 does not use third-party advertising or retargeting cookies. You may manage optional cookie preferences through your browser settings. Disabling optional cookies will not prevent you from accessing the core ha77 platform but may affect certain non-essential features.

8. Data Retention

ha77 retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to any longer retention period required by applicable law or regulation. The general retention periods we apply are:

• Account and Identity Data: Retained for the duration of your active account plus a minimum of 5 years following account closure, in accordance with standard anti-money laundering record-keeping obligations.
• KYC Documents: Retained for a minimum of 5 years from the date of the last transaction on the account, or as required by applicable financial regulations.
• Transaction Records: Retained for a minimum of 5 years from the transaction date.
• Customer Support Communications: Retained for 2 years from the date of the last interaction, unless the communication relates to a dispute or investigation, in which case retention continues until resolution plus 2 years.
• Analytics and Log Data: Anonymised within 12 months of collection. Identifiable log data (e.g., IP address logs) retained for up to 12 months.
• Marketing Preferences: Retained until you withdraw consent or request deletion.

Upon expiry of the applicable retention period, personal data is securely deleted using industry-standard data destruction methods, or anonymised in a manner that prevents re-identification.

9. Your Data Rights

As a ha77 user, you hold the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request".

• Right of Access: You may request a copy of all personal data ha77 holds about you. We will provide this within 30 days of receiving a valid request, free of charge.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you may request that we correct or complete it. Minor corrections (such as updating your phone number) can be made directly through your account settings.
• Right to Erasure: You may request deletion of your personal data where: (a) the data is no longer necessary for the purpose for which it was collected; (b) you have withdrawn consent and no other legal basis applies; or (c) the data has been processed unlawfully. Note that we may be required to retain certain data by law even following a deletion request — in such cases, we will explain the basis for retention.
• Right to Restriction: You may request that we restrict processing of your personal data in certain circumstances — for example, while a rectification request is under review.
• Right to Data Portability: You may request a structured, machine-readable copy of personal data you have provided to ha77 directly, to be transferred to another service provider of your choice.
• Right to Object: You may object to processing based on legitimate interests, including profiling. ha77 will cease the relevant processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing communications, optional cookies), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out prior to withdrawal.

10. Data Security

ha77 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• Encryption in Transit: All data transmitted between your browser or app and ha77.io is encrypted using TLS (Transport Layer Security). HTTP connections are automatically redirected to HTTPS.
• Encryption at Rest: Sensitive personal data, including KYC documents and payment identifiers, is encrypted in storage using AES-256 or equivalent standards.
• Access Controls: Access to personal data is restricted to authorised ha77 personnel who require it for legitimate operational purposes. Access is granted on a need-to-know basis and reviewed regularly.
• Audit Logging: All access to personal data systems is logged. Logs are monitored for anomalous activity and reviewed regularly by the ha77 security team.
• Vulnerability Management: ha77's platform undergoes periodic security assessments to identify and remediate potential vulnerabilities before they can be exploited.
• Incident Response: ha77 maintains an incident response plan that governs how the team responds to security incidents, including notification procedures for affected users.

While ha77 takes all reasonable steps to secure your personal data, no online platform can guarantee absolute security against all threats. Players are also responsible for maintaining the security of their own account credentials. If you believe your ha77 account has been compromised, contact [email protected] immediately.

11. Children and Minors

ha77 employs age verification checks at the point of account registration and during KYC verification to prevent individuals under the age of 21 from accessing the platform. If ha77 becomes aware that personal data has been collected from an individual under 21 — whether through a misrepresentation made at registration or through any other means — we will immediately close the associated account, delete the data collected, and void any transactions made on the account.

If you are a parent or guardian and you believe your child may have registered an account on ha77, please contact us immediately at [email protected] so we can investigate and take appropriate action.

12. Third-Party Links and Services

ha77.io may contain references to or integrations with third-party services, including payment gateways (bKash, Nagad, Rocket, Upay) and game content providers (Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi). These third parties operate under their own privacy policies and data practices, which are independent of this Privacy Policy.

ha77 is not responsible for the privacy practices of third-party services and does not control how those parties collect, store, or use data. We recommend that you review the privacy policies of any third-party services you interact with through or alongside the ha77 platform.

ha77.io does not include links to external third-party websites for marketing or advertising purposes. Any links present on the platform serve solely to facilitate your use of ha77 services.

13. Amendments to This Privacy Policy

ha77 reserves the right to update or amend this Privacy Policy at any time. When material changes are made — for example, changes to the categories of data we collect, the purposes for which we use it, or the third parties with whom we share it — ha77 will notify registered users by email to the address on file at least 14 days before the updated policy takes effect.

The revised policy will be published at ha77.io/privacy-policy with an updated "Last Updated" date at the top. For non-material changes (such as clarifications of language or corrections of typographical errors), ha77 may update the policy without prior notice, though the "Last Updated" date will always reflect the most recent revision.

Your continued use of ha77.io after the effective date of any amendment constitutes your acceptance of the updated Privacy Policy. If you do not agree with a proposed change, you may close your account before the effective date by contacting [email protected].

14. Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way ha77 handles your personal data, please contact our team using the following details:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: Use "Privacy Enquiry" for general questions or "Data Rights Request" for formal data rights requests
• Response Target: Within 2 business hours for urgent data security matters; within 2 business days for general privacy enquiries
• Support Hours: 24 hours a day, 7 days a week, including Bangladesh public holidays
• Language: English