kinph Privacy Policy

1 Introduction

kinph ("kinph," "we," "us," or "our") operates the online gaming platform accessible at kinph.cam. This Privacy Policy describes how kinph collects, uses, discloses, retains, and protects the personal information of individuals ("Players," "Users," or "you") who register for or otherwise interact with the kinph platform.

This Privacy Policy forms part of the kinph Terms and Conditions and is incorporated therein by reference. By creating a kinph account or using any part of the kinph platform, you acknowledge that you have read, understood, and agreed to the data practices described in this Privacy Policy.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, kinph is the personal information controller in respect of the personal data processed under this Privacy Policy. kinph determines the purposes for which, and the means by which, your personal data is processed.

If you have questions about how your personal data is handled by kinph, or wish to exercise your rights under applicable Philippine data protection law, you may contact our Data Protection Officer (DPO) using the details provided in Section 14 of this Privacy Policy.

3 Personal Data We Collect

kinph collects personal data that is necessary for the purposes set out in this Privacy Policy. The categories of personal data we collect include:

Category	Examples	When Collected
Identity Data	Full name, date of birth, nationality, government-issued ID number	Registration and KYC verification
Contact Data	Email address, mobile number, home address (province/city/barangay)	Registration and account updates
Financial Data	GCash number, bank account details (BPI, BDO, Metrobank), PayMaya account	Deposit and withdrawal requests
Transaction Data	Deposit and withdrawal history, bet history, bonus usage, balance records	Continuously during account use
Technical Data	IP address, device type, browser, operating system, session duration	Automatically on platform access
Verification Documents	Selfie with ID, proof of address, source-of-funds documentation	KYC and enhanced due diligence
Communications Data	Support chat logs, email correspondence, complaint records	When you contact kinph support

kinph does not intentionally collect sensitive personal information beyond what is required for age verification and identity confirmation as mandated by Philippine gaming and AML regulations. Where sensitive information is collected, it is handled with heightened security measures and is accessed only on a strict need-to-know basis.

4 How We Collect Your Personal Data

kinph collects personal data through the following means:

• Directly from you: When you register a kinph account, complete KYC verification, make deposits or withdrawals, contact customer support, or respond to surveys and promotions;
• Automatically: When you use the kinph platform, we automatically collect technical data such as your IP address, device information, and session activity through cookies, log files, and similar tracking technologies;
• From third parties: We may receive data from identity verification service providers, payment processors (including GCash, PayMaya, BPI, BDO, Metrobank), fraud detection agencies, and other lawfully operating data sources where required to verify your identity or assess risk.

5 Purpose and Legal Basis for Processing

5.1 Contractual Necessity

kinph processes personal data where it is necessary for the performance of our contract with you — i.e., to provide you with access to the kinph gaming platform, to process your deposits and withdrawals, to manage your account, and to deliver any bonuses or promotional benefits you are entitled to.

5.2 Legal Obligation

kinph is subject to legal obligations under Philippine gaming regulations, anti-money laundering (AML) law, counter-terrorism financing (CTF) law, and tax regulations. Processing of personal data is necessary to comply with these obligations, including age verification, Know Your Customer (KYC) procedures, and transaction reporting.

5.3 Legitimate Interests

kinph processes certain personal data on the basis of legitimate interests, including: fraud detection and prevention, platform security monitoring, responsible gaming enforcement (including the 21+ age requirement), and improving the quality of the kinph platform. We ensure that our legitimate interests do not override your fundamental privacy rights.

5.4 Consent

Where kinph relies on consent as the legal basis for processing — for example, for non-essential cookies, marketing communications, or optional profiling — you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. Consent withdrawal can be actioned via your account settings or by contacting kinph support.

6 Data Sharing and Disclosure

kinph does not sell, rent, or trade your personal data. kinph may share your personal data with the following categories of recipients, only to the extent necessary and in compliance with applicable law:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other authorized payment service providers, for the purpose of processing your deposits and withdrawals;
• Identity Verification Providers: Third-party KYC and AML service providers engaged by kinph to verify your identity and conduct due diligence as required under Philippine law;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where disclosure is required by law, court order, or regulatory instruction;
• Fraud and Security Providers: Third-party fraud prevention and cybersecurity service providers who assist kinph in protecting the platform and its players;
• Technology Service Providers: Cloud hosting providers, database operators, and software vendors engaged by kinph who process personal data on our behalf under strict data processing agreements and confidentiality obligations;
• Professional Advisers: Legal counsel, auditors, and accountants who require access to personal data in the course of providing professional services to kinph, subject to professional secrecy obligations.

7 Data Retention

kinph retains personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, and in accordance with applicable legal, regulatory, and business retention requirements. The following retention periods apply as a general guide:

• Account and identity data: Retained for the duration of your active kinph account plus a minimum of five (5) years following account closure, in accordance with AML record-keeping requirements under Philippine law;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required for AML and tax compliance;
• Support communications: Retained for three (3) years from the date of the communication unless a longer period is required for unresolved disputes;
• Technical and session data: Retained for up to twelve (12) months for security and fraud prevention purposes, after which it is anonymized or deleted;
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year thereafter for record-keeping purposes.

After the applicable retention period has expired, personal data is securely deleted or anonymized in a manner that prevents re-identification.

8 Security Measures

kinph implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• TLS (Transport Layer Security) encryption for all data in transit between your device and kinph servers;
• AES-256 encryption for sensitive data stored at rest, including identity documents and financial information;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Multi-factor authentication (MFA) requirements for kinph staff accessing production systems;
• Regular penetration testing, vulnerability assessments, and security audits conducted by independent security professionals;
• Incident response procedures including breach notification protocols aligned with NPC reporting requirements.

While kinph takes all reasonable measures to protect your personal data, no method of electronic storage or transmission is 100% secure. kinph cannot guarantee absolute security but is committed to immediately investigating and responding to any suspected data breach.

9 Cookies and Tracking Technologies

9.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. kinph uses cookies and similar technologies (including web beacons and local storage) to operate the platform, remember your preferences, maintain your session, and analyze usage patterns.

9.2 Types of Cookies Used by kinph

• Strictly Necessary Cookies: Essential for the kinph platform to function. These cannot be disabled and do not require your consent;
• Performance & Analytics Cookies: Used to understand how players use kinph, which pages are visited most, and where errors occur. These are used only with your consent;
• Functionality Cookies: Used to remember your preferences (e.g., language, region, display settings) to improve your experience on kinph;
• Marketing Cookies: Used to deliver promotional content relevant to your interests. These are only activated where you have given explicit consent.

9.3 Managing Cookies

You can manage or disable non-essential cookies at any time through your browser settings or through the cookie preference interface on kinph. Note that disabling certain cookies may affect the functionality of the kinph platform.

10 Your Data Privacy Rights

Under the Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, you have the following rights in relation to your personal data processed by kinph:

• Right to be Informed: You have the right to know how your personal data is being collected, processed, and used by kinph;
• Right to Access: You may request a copy of the personal data kinph holds about you;
• Right to Correction: You may request that inaccurate or incomplete personal data be corrected;
• Right to Erasure or Blocking: You may request that your personal data be deleted or blocked where processing is no longer necessary, where consent has been withdrawn, or where processing is unlawful. This right is subject to kinph's legal retention obligations;
• Right to Object: You may object to processing carried out on the basis of legitimate interests or for direct marketing purposes;
• Right to Data Portability: You may request a structured, machine-readable copy of personal data you have provided to kinph, where technically feasible;
• Right to File a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe kinph has violated your data privacy rights.

To exercise any of the above rights, please contact kinph's Data Protection Officer using the details in Section 14. kinph will respond to verified requests within thirty (30) days in accordance with NPC guidelines.

11 Minors and Age Restriction

kinph is strictly intended for individuals aged 21 years and above, in compliance with Philippine gaming regulations and PAGCOR guidelines. kinph does not knowingly collect personal data from persons below the age of 21. If kinph becomes aware that personal data has been collected from a person under 21, kinph will take immediate steps to delete that data and close the associated account.

If you are a parent or guardian and believe that a minor has provided personal data to kinph, please contact our Data Protection Officer immediately using the contact details in Section 14.

12 Cross-Border Data Transfers

kinph may transfer personal data to service providers or technology infrastructure located outside the Philippines where necessary for platform operations. Where such transfers occur, kinph ensures that adequate safeguards are in place — including contractual clauses based on standard data protection requirements recognized under Philippine law — to ensure that your personal data receives a level of protection equivalent to that provided under the Data Privacy Act of 2012.

By using the kinph platform, you acknowledge and consent to the transfer of your personal data as described in this section, subject to the protections outlined above.

13 Changes to This Privacy Policy

kinph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, or operational requirements. Where changes are material, kinph will notify registered players via the email address associated with their account or through an in-platform notification prior to the changes taking effect.

The "Last Updated" date at the top of this Privacy Policy reflects the most recent revision. Continued use of the kinph platform following the effective date of any revised Privacy Policy constitutes acceptance of the updated terms.

14 Contact and Complaints

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way kinph processes your personal data, please contact our Data Protection Officer:

Email: [email protected]

Please include your full name, registered kinph username, and a detailed description of your inquiry or request. kinph will acknowledge your request within five (5) business days and provide a substantive response within thirty (30) days.

If you are not satisfied with kinph's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. The NPC is the supervisory authority responsible for enforcing the Data Privacy Act of 2012. Information on filing a complaint with the NPC is available through their official government channels.