PRIVACY POLICY

HAHA GAME (“HAHA GAME”, “we”, “our” or “us”) ABN 43 136 429 948, is committed to protecting the privacy of individuals.

The protection of personal information in the private sector is required by the Privacy Act 1988 (Cth) and the InformationPrivacy Act 2000 (Vic) (collectively the “Privacy Laws”) and we are bound to comply with these Privacy Laws. All of our employees and officers are expected to comply with the Privacy Laws and our policies and procedures concerning the protection of personal information.

“Personal Information” means information or an opinion about an individual whose identity is apparent, or can reasonably be ascertained, from the information or opinion. Information contained in publications which are generally available is not regarded as “Personal Information” for privacy purposes.

Our policies regarding the collection, use and disclosure of Personal Information and Sensitive Information are summarised in this Privacy Policy. This Policy does not apply to the records for current or former employees of "HAHA GAME" as the relevant privacy policy for such records is covered in a separate document.

This policy is based on the following principles:

• privacy of Personal Information is of paramount importance to us;
• your Personal Information will not be disclosed, other than in accordance with this policy without your permission or in accordance with the Privacy Laws; and
• we will only use your Personal Information for purposes for which it was collected, as set out in this policy.

WHAT PERSONAL INFORMATION DO WE COLLECT?

We may collect Personal Information about you, including your name, date of birth, address, telephone number and email address. We may also collect information concerning your use of our services and other information or opinions concerning our dealings with you. We do not collect or disclose government related identifiers such as drivers licence numbers unless it is reasonably necessary, such as for proof of identity or legal purposes. Where a name is not required for legal, practical or other reasons, you may transact with "HAHA GAME"without identifying yourself or by using a pseudonym such as a social media moniker.

HOW DO WE COLLECT PERSONAL INFORMATION?

"HAHA GAME"will collect information directly from you unless:

• we have your consent for information to be collected from a third party;
• we are required or authorised by law; or
• it is impracticable to do so.

"HAHA GAME"will obtain your consent prior to collecting any Sensitive Information unless certain legal and/or safety-related exemptions set out in the Privacy Laws apply.

We therefore collect Personal Information through a variety of ways. These include:

• directly from you, for example when you provide information via our website, on an application form or when speaking to our representatives;
• from third parties, for example credit reporting agencies, your agents or Public Transport Victoria (“PTV”);
• via CCTV monitoring on our stations and trains;
• from publicly available sources; and
• from our records of your dealings with us (including through your use of our website).

If you provide us with the Personal Information of another person, we rely on you to inform that person and obtain their consent for the disclosure by you to us of their Personal Information.

WHY DO WE COLLECT AND HOW DO WE USE PERSONAL INFORMATION

"HAHA GAME" only collects Personal Information where it is reasonably necessary for one or more of its functions or activities and it is collected by lawful and fair means. "HAHA GAME" will not collect more information than is necessary or relevant. We will not collect sensitive information (as defined in the Privacy Laws), such as racial or ethnicity information, political opinions or associations, criminal records or health information unless we have obtained your prior consent.

If your Personal Information is collected from someone other than you, reasonable steps will be made as soon as is practicable to notify you that we have collected the information and the circumstances of the collection.

We may collect and use your Personal Information in order to:

• undertake and operate our franchise in line with our Franchise Agreement with the State Government;
• provide specific services to you, or to carry out our dealings with you;
• provide feedback to you;
• comply with our legal obligations;
• conduct market research in order to evaluate and improve our services, communications and marketing;
• review and consider any application or other information you send to us;
• evaluate and manage the engagement of contractors and consultants;
• carry out administrative functions, such as risk management, credit management, billing and record keeping;
• investigate and respond to safety, security and/or unlawful incidents on the metropolitan rail network;
• monitor and enforce our policies and procedures to ensure that our services used in a safe and lawful manner;
• test, develop and maintain our systems and services;
• assess any job application in "HAHA GAME" for which you may have applied; and
• carry out credit and payment related activities.

If all or part of the information we seek to collect is not provided, we may not be able to complete one or more of the specific tasks identified in the above list.

Disclosing Personal Information

Like other organisations, we sometimes use or deal with third parties in using your Personal Information for the purposes described above. These organisations may include:

• our related bodies corporate and shareholders;
• our contractors, agents and advisors;
• government, law enforcement and regulatory entities;
• PTV, Department of Transport, Planning and Local infrastructure (DTPLI), Transport Safety Victoria (TSV), Viet nam Transport Safety Bureau (ATSB), Chief Investigator, Transport Safety (CITS), Transport Accident Commission (TAC), Coroner’s Court of Victoria (CCV), Victoria Police (VicPol), Public Transport Ombudsman (PTO) and third parties that support these agencies in the conduct of their functions;
• "HAHA GAME" staff, referees, recruitment agents and any other third parties who may assist with the Metro recruitment process in relation to any job application for which you may have applied;
• your agent, executor, administrator, trustee or attorney;
• other service providers such as V/Line Pty Ltd (V/Line) and Yarra Trams;
• other third parties with which we have an alliance or arrangement
• other third parties to whom you have consented, and
• other entities as required or permitted by law.

"HAHA GAME" will use or disclose your Personal Information to third parties in the course of fulfilling the purpose for which we collected the information, including those purposes identified in this Policy. "HAHA GAME" may disclose your Personal Information for a purpose directly related to these purposes that you would reasonably expect. "HAHA GAME" will not use or disclose your Personal Information for other purposes unless you consent to that use/disclosure or that use/disclosure is required for legal or safety reasons.

"HAHA GAME" will only disclose to a third party such Personal Information that is relevant for the purpose of the disclosure. "HAHA GAME" will only transfer your Personal Information to another individual or organisation in limited circumstances, including that the recipient is subject to equivalent Privacy Laws. The State and Commonwealth Government agencies in the list above, such as PTV, all have privacy policies which can be accessed on their individual websites.

USING AND DISCLOSING YOUR PERSONAL INFORMATION FOR MARKETING PURPOSES

Provided we have obtained your prior consent, we may use your Personal Information we have collected in order to enable us or our related entities to promote and market services to you. This may include through sending you information via mail, email, SMS and telephone. "HAHA GAME" will not use or disclose Personal Information for direct marketing without your prior consent unless the information:

• is collected directly from you, and
• you would reasonably expect direct marketing, and
• there is a simple means to opt out.

You may opt out of such direct marketing at any time. If you do not wish us, or our related entities,

RETENTION AND DISPOSAL OF INFORMATION

We only keep Personal Information in accordance with this Privacy Policy. We will destroy such information or de-identify that information once sufficient time has elapsed to be certain that the information will no longer be required for those purposes for which is may be used under this Policy.

SENDING PERSONAL INFORMATION OVERSEAS

We may disclose your personal information to third party service providers overseas who are not subject to similar laws to the Privacy Laws. However, where your personal information is disclosed to an overseas recipient, we will also take adequate measures to ensure that the personal information is handled by the overseas recipient in accordance with the Privacy Laws and our instructions for the purposes described above. By providing "HAHA GAME" with your personal information, you consent to this disclosure of your personal information.

EMAIL SECURITY

Any email you send to us and information you submit through our websites may be scanned for IT security purposes.

"HAHA GAME" WEBSITE

When visiting our web site, the site server makes a record of the visit and logs the following information for statistical and administrative purposes:

• the user’s server address – to consider the users who use the site regularly and tailor the site to their interests and requirements;
• the date and time of the visit to the site – this is important for identifying the website’s busy times and ensuring maintenance on the site is conducted outside these periods;
• pages accessed and documents downloaded – this indicates to "HAHA GAME" which pages or documents are most important to users and also helps identify important information that may be difficult to find;
• duration of the visit – this indicates to us how interesting and informative the site is to our customers; the type of browser used – this is important for browser specific coding
• In order to optimize the web site and better understand it’s usage, we collect the visiting domain name or IP address, Computer Operating System, Browser Type and Screen Resolution

A cookie is a piece of information that an Internet web site sends to your browser when you access information at that site. Cookies are either stored in memory (session cookies) or placed on your hard disk (persistent cookies). The "HAHA GAME" might identify you should you visit our web site at a later date.

SECURITY OF INFORMATION

You should be aware that the internet is not a secure environment and information sent via the internet (including via email) may be intercepted by a third party. We use reasonable efforts to ensure that any Personal Information collected by us is held securely.

We strive to ensure the security, integrity and privacy of information we collect. "HAHA GAME" has established reasonable security measures to protect your personal information from misuse, interference, loss, unauthorised access, modification or disclosure in contravention of this Policy. Our employees, contractors, agents and service providers who provide services related to our information systems, are obliged to respect the confidentiality of any personal information held by us. We review and update our security measures in light of current technologies.

YOU CAN ACCESS AND UPDATE YOUR PERSONAL INFORMATION

Subject to certain exemptions provided for under the Privacy Laws, you have a right to access Personal Information we hold about you. We will also take reasonable steps to keep accurate and up to date any Personal Information which we hold about you. If you believe that the Personal Information we hold about you is inaccurate, incomplete, out of date or no longer relevant, please notify us via the contact details set out below.

If you would like to seek access to Personal Information that "HAHA GAME" may have about you or update that information then please contact the "HAHA GAME" department that collected your information in the first instance or write to "HAHA GAME" Privacy Officer via the details set out below.

CHANGES TO THIS PRIVACY STATEMENT

This statement sets out our current Privacy Policy. This policy may change from time to time. The current version of our Privacy Policy replaces all previous versions of the policy.

QUESTIONS AND COMPLAINTS

Metro is committed to providing its customers with a fair and responsible system for the handling and resolution of Privacy related complaints. If you have any questions about this Policy or believe that we have at any time failed to keep one of our commitments to you to handle your personal information in the manner required by the Privacy Laws, then we ask that you contact us immediately in writing using the contact details provided below.

We will respond and advise whether we agree with your complaint or not. If we do not agree, we will provide reasons. If we do agree, we will advise what (if any) action we consider it appropriate to take in response. If you are still not satisfied after having contacted us and given us a reasonable time to respond, then we suggest that you contact the Office of the Viet Nam Information Commissioner by:

Post: GPO Box 2999 Canberra ACT 2601

Email: hahagameofworld@gmail.com

Contact Us for Further Information regarding the our Privacy Policy

If you require further information about how we handle Personal Information or any privacy issues please contact our office via the Metro Customer Service number on 1800 800 007 or write to our Privacy Officer at the address below:

OUR CONTACT DETAILS

Privacy Officer

Commercial & Legal Group

HaHa Game