Privacy Policy — kimgph

1. Introduction

kimgph ("kimgph," "we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who access or use the kimgph platform, including our website, mobile applications, and all associated services (collectively, the "Services"). This Privacy Policy applies to all registered players, visitors, and any person whose personal data is processed by kimgph in connection with the Services.

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC) of the Philippines. It is also informed by the requirements of the Philippine Amusement and Gaming Corporation (PAGCOR) with respect to player data management and anti-money laundering obligations.

By registering an account with kimgph, accessing the platform, or otherwise providing your personal data to us, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and processing of your personal data as described herein.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, kimgph acts as the Personal Information Controller (PIC) with respect to the personal data of its registered players and website visitors.

kimgph has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with the DPA and this Privacy Policy. Contact details for the DPO are provided in Section 14 of this Policy.

Where kimgph engages third-party service providers to process personal data on its behalf (for example, payment processors, KYC verification providers, and analytics platforms), such third parties act as Personal Information Processors (PIPs) and are bound by data processing agreements that require them to process personal data only in accordance with kimgph's instructions and applicable Philippine law.

3. Information We Collect

kimgph collects personal data from you in the following categories, depending on how you interact with the platform:

3.1 Registration & Identity Data

• Full legal name, date of birth, and gender
• Government-issued identification number (e.g., PhilSys ID, UMID, driver's license, passport number)
• Nationality and country of residence
• Username and encrypted password

3.2 Contact Data

• Email address
• Mobile phone number
• Residential address (including barangay, city/municipality, province, and postal code)

3.3 Financial & Transaction Data

• GCash or PayMaya account number (where used for deposits or withdrawals)
• Bank account details (BPI, BDO, Metrobank, or other Philippine banks)
• Credit or debit card details (Visa, Mastercard — stored in tokenized form only)
• Deposit and withdrawal history, transaction amounts in Philippine Peso (PHP)
• Source of funds documentation (where required for KYC compliance)

3.4 Technical & Usage Data

• IP address, device type, operating system, and browser type
• Session duration, pages visited, and features used on the kimgph platform
• Game history, betting patterns, and wagering activity
• Login timestamps and geolocation data (city/region level)

3.5 Communications Data

• Records of your communications with kimgph customer support
• Feedback, survey responses, and promotional opt-in preferences

4. How We Use Your Data

kimgph uses the personal data we collect for the following purposes:

5. Legal Basis for Processing

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

• Consent: Where you have given your explicit consent to the processing of your personal data for a specific purpose, such as receiving promotional communications or participating in optional surveys.
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and kimgph — specifically, to provide you with access to the Services, process your transactions, and manage your account.
• Legal Obligation: Where processing is required to comply with a legal obligation applicable to kimgph, including PAGCOR regulatory requirements, Anti-Money Laundering Act (AMLA) obligations, and NPC data breach notification requirements.
• Legitimate Interests: Where processing is necessary for the legitimate interests of kimgph, such as fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your rights and freedoms.

6. Cookies & Tracking Technologies

kimgph uses cookies and similar tracking technologies on its platform to enhance your user experience, maintain your session, and collect analytics data. The types of cookies we use include:

• Strictly Necessary Cookies: Required for the platform to function correctly, including session management and security features. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as language settings and display options, to personalize your experience on kimgph.
• Analytics Cookies: Collect anonymized data about how users interact with the kimgph platform, helping us identify areas for improvement. This data does not identify you personally.
• Marketing Cookies: Used to deliver relevant promotional content to you based on your activity on the platform. These are only activated where you have provided consent.

You may manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the kimgph platform. Strictly necessary cookies cannot be disabled as they are essential to the operation of the Services.

7. Data Sharing & Disclosure

kimgph 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, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard processing partners, for the purpose of processing your deposits and withdrawals in Philippine Peso.
• KYC & Identity Verification Providers: Third-party providers engaged to verify your identity and government-issued identification documents in compliance with PAGCOR and AMLA requirements.
• 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 or regulatory mandate.
• IT & Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on kimgph's behalf under binding data processing agreements.
• Customer Support Platforms: Third-party helpdesk and live chat providers used to manage player support communications.
• Legal & Professional Advisors: Lawyers, auditors, and compliance consultants engaged by kimgph, subject to professional confidentiality obligations.

All third-party processors engaged by kimgph are required to implement appropriate technical and organizational security measures and to process personal data only in accordance with kimgph's documented instructions.

8. Data Retention

kimgph retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, in compliance with PAGCOR regulations and AMLA record-keeping requirements.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• Customer support communications: Retained for two (2) years from the date of the communication, unless retention for a longer period is required for dispute resolution purposes.
• Marketing preferences and consent records: Retained for the duration of your account and for two (2) years following account closure or withdrawal of consent.
• Technical and usage data: Retained for thirteen (13) months on a rolling basis for analytics and security purposes.

Upon expiry of the applicable retention period, kimgph will securely delete or anonymize your personal data in accordance with NPC-approved disposal methods.

9. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the kimgph platform.
• Encryption at rest for sensitive personal information, including government ID numbers and financial account details.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Multi-factor authentication (MFA) for administrative access to systems containing personal data.
• Incident response procedures aligned with NPC breach notification requirements under the DPA.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, kimgph will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay, in accordance with NPC Circular 16-03.

10. Your Rights Under the Data Privacy Act

As a data subject under Republic Act No. 10173, you have the following rights with respect to your personal data held by kimgph:

• Right to be Informed: You have the right to be informed of how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right to Access: You may request a copy of the personal data kimgph holds about you, along with information about how it is being processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to Erasure or Blocking: You may request the deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, or where processing is unlawful, subject to kimgph's legal retention obligations.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to Data Portability: You may request that kimgph provide your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact kimgph's Data Protection Officer using the contact details in Section 14. kimgph will respond to all verified data subject requests within fifteen (15) business days of receipt, in accordance with NPC guidelines.

11. Children's Privacy

The kimgph platform is strictly intended for individuals who are at least twenty-one (21) years of age, as required under Philippine gambling laws enforced by PAGCOR. kimgph does not knowingly collect personal data from individuals under the age of 21.

If kimgph becomes aware that personal data has been collected from a person under the age of 21, we will immediately suspend the associated account, delete the personal data in question, and report the matter to PAGCOR as required. If you believe that a minor has registered on the kimgph platform, please contact us immediately at the details provided in Section 14.

12. Third-Party Links

The kimgph platform may contain links to third-party websites or services for informational purposes. kimgph is not responsible for the privacy practices or content of any third-party websites. This Privacy Policy applies solely to personal data collected and processed by kimgph in connection with the Services. We encourage you to review the privacy policies of any third-party websites you visit.

13. Changes to This Privacy Policy

kimgph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. When material changes are made, we will notify registered players via email or a prominent notice on the kimgph platform at least seven (7) days before the changes take effect.

The "Last updated" date at the top of this Policy will be revised whenever changes are made. Your continued use of the kimgph platform following the effective date of any amendment constitutes your acknowledgment of the revised Privacy Policy.

14. Contact & Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by kimgph, please contact our Data Protection Officer:

Data Protection Officer — kimgph

Email: [email protected]

kimgph's DPO is registered with the National Privacy Commission of the Philippines in accordance with NPC Circular 17-01. All data subject requests and privacy-related complaints will be handled in strict confidence and in accordance with the Data Privacy Act of 2012 and its IRR.