KINPH Privacy Policy

01 Who We Are

This Privacy Policy is issued by KINPH, the operator of the online gaming platform accessible at kinph.net and through the KINPH mobile application (collectively, the "Platform"). References to "KINPH," "we," "us," or "our" in this document refer to the KINPH platform operator.

KINPH is the data controller responsible for the personal information of players and visitors who interact with the Platform. We are committed to handling your personal data with care, transparency, and in full compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

If you have any questions about this Privacy Policy or how KINPH handles your personal data, please contact our Data Protection Officer using the details provided in Section 14 of this document.

02 Personal Data We Collect

KINPH collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

03 How We Collect Your Data

KINPH collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting our support team, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, web beacons, pixel tags, and similar tracking technologies. See Section 7 for more details.
• Third-party sources: Identity verification data from accredited verification service providers; fraud prevention data from anti-fraud screening partners; payment transaction data from payment processors such as GCash and PayMaya.
• Publicly available sources: Information from public registries or databases where relevant to our legal compliance obligations, such as anti-money laundering screening.

04 How We Use Your Personal Data

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

• Account registration and management: To create and maintain your KINPH player account, verify your identity and age (21+ requirement), and manage your account preferences.
• Service delivery: To provide access to games, process deposits and withdrawals, credit bonuses, and deliver the full range of KINPH platform features.
• Legal and regulatory compliance: To fulfil our obligations under Philippine law, including anti-money laundering (AML) requirements, know-your-customer (KYC) procedures, and responsible gaming regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the Platform and its players.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance through our live chat and email support channels.
• Responsible gaming: To monitor gaming patterns, apply responsible gaming tools you have activated, and identify players who may be at risk of problem gambling.
• Marketing and promotions: To send you information about KINPH promotions, bonuses, and new games where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: To analyse usage patterns, conduct research, and improve the functionality, performance, and user experience of the KINPH platform.
• Legal claims: To establish, exercise, or defend legal claims involving KINPH or its players.

05 Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you as a registered KINPH player, including account management, game access, and financial transactions.
• Legal obligation: Processing necessary to comply with applicable Philippine laws and regulations, including AML, KYC, and gaming regulatory requirements.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and certain cookie-based tracking, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

06 Sharing Your Personal Data

KINPH 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:

• Identity verification providers: Accredited third-party services that assist KINPH in verifying player identity and age in compliance with KYC requirements.
• Payment processors: Financial service providers including GCash, PayMaya, BPI, BDO, and Metrobank, to facilitate deposits and withdrawals to and from your KINPH account.
• Fraud prevention and AML screening partners: Service providers that assist KINPH in detecting and preventing fraudulent transactions and money laundering activity.
• Technology and infrastructure providers: Cloud hosting, data storage, and platform technology providers who process data on KINPH's behalf under strict data processing agreements.
• Customer support platforms: Third-party live chat and ticketing system providers used to deliver player support services.
• Regulatory and law enforcement authorities: Philippine government agencies, regulatory bodies, or law enforcement authorities where disclosure is required by law, court order, or regulatory direction.
• Professional advisers: Lawyers, auditors, and other professional advisers engaged by KINPH in connection with legal, compliance, or financial matters, subject to professional confidentiality obligations.

All third-party service providers engaged by KINPH are required to implement appropriate technical and organisational security measures and are prohibited from using your personal data for any purpose other than the specific service they provide to KINPH.

07 Cookies & Tracking Technologies

KINPH uses cookies and similar tracking technologies to enhance your experience on the Platform, analyse usage patterns, and support our security and fraud prevention measures. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function correctly. These include session authentication cookies and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, game preferences, and responsible gaming tool configurations to personalise your experience.
• Analytics cookies: Collect anonymised data about how players use the Platform, including pages visited and features used, to help us improve performance and user experience.
• Security cookies: Used to detect and prevent fraudulent activity, bot access, and other security threats to the Platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the KINPH platform. KINPH does not use third-party advertising or behavioural targeting cookies.

08 Data Retention

KINPH retains your personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with AML and gaming regulatory requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• Gaming history: Retained for a minimum of three (3) years from the date of each gaming session.
• Customer support communications: Retained for three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing consent records: Retained for the duration of your consent and for one (1) year following withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised in accordance with KINPH's data disposal procedures.

09 Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the KINPH platform.
• Encryption of sensitive data at rest, including financial information and identity documents.
• Role-based access controls ensuring that KINPH staff can only access personal data necessary for their specific job functions.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with the requirements of the National Privacy Commission.

10 Your Data Protection Rights

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by KINPH:

• Right to be informed: The right to be notified of how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data KINPH holds about you, along with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data protection rights have been violated.

To exercise any of these rights, please contact KINPH's Data Protection Officer using the contact details in Section 14. We will respond to all verified requests within thirty (30) days, or within such other period as required by applicable law.

11 Children's Privacy

The KINPH platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. KINPH does not knowingly collect personal data from individuals under the age of 21.

If KINPH becomes aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and take appropriate steps in accordance with our regulatory obligations.

12 International Data Transfers

KINPH primarily processes and stores personal data within the Philippines. Where it is necessary to transfer personal data to service providers or infrastructure partners located outside the Philippines, KINPH ensures that such transfers are conducted in accordance with the requirements of the Philippine Data Privacy Act of 2012.

International transfers are only made to countries or organisations that provide an adequate level of data protection, or where appropriate safeguards are in place, such as contractual data processing agreements that impose obligations equivalent to those required under Philippine law.

13 Updates to This Privacy Policy

KINPH reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. The most current version of this Privacy Policy will always be published on this page, with the effective date noted at the top of the document.

Where changes are material, KINPH will notify registered players via email or through a prominent notice on the Platform prior to the changes taking effect. Your continued use of the KINPH platform following notification of any update constitutes your acceptance of the revised Privacy Policy.

We encourage you to review this Privacy Policy periodically to stay informed about how KINPH protects your personal data.

14 Contact Us & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or KINPH's handling of your personal data, please contact our Data Protection Officer:

• Live Chat: Available 24/7 through the KINPH platform and mobile application — the fastest way to reach us.
• Email: [email protected]
• Response Time: KINPH aims to acknowledge all privacy-related enquiries within 72 hours and to provide a substantive response within 30 days.

If you are not satisfied with KINPH's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. Information about how to file a complaint is available through the National Privacy Commission's official channels.

For questions about responsible gaming tools, self-exclusion, or account restrictions, please visit our Responsible Gaming page or contact our support team directly.