kuyaph Privacy Policy

1. Introduction and Scope

1.1 kuyaph is committed to protecting the privacy and security of the personal information entrusted to us by our players. This Privacy Policy applies to all personal data collected through the kuyaph website, mobile-optimized platform, customer support channels, and any other services operated by kuyaph.

1.2 This Policy should be read together with the kuyaph Terms and Conditions, which govern your use of the Platform. In the event of any conflict between this Policy and the Terms and Conditions on matters of data privacy, this Policy shall prevail.

1.3 kuyaph acts as the Personal Information Controller (PIC) in respect of the personal data it collects from Players, as defined under the Data Privacy Act of 2012. kuyaph has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data privacy laws.

2. Personal Data We Collect

kuyaph collects the following categories of personal data from Players:

Category	Examples	Purpose
Identity Data	Full name, date of birth, government-issued ID number	KYC verification, age verification, fraud prevention
Contact Data	Email address, Philippine mobile number, home address	Account management, support communications, notifications
Financial Data	GCash number, bank account details, transaction history	Processing deposits and withdrawals, AML compliance
Gaming Data	Game history, wager amounts, win/loss records, session duration	Platform operation, responsible gaming monitoring, dispute resolution
Technical Data	IP address, device type, browser type, operating system	Security, fraud detection, platform optimization
Usage Data	Pages visited, features used, click patterns, session logs	Platform improvement, personalization, analytics
Communications Data	Support chat transcripts, email correspondence	Support quality, dispute resolution, compliance records

kuyaph does not intentionally collect sensitive personal information (as defined under the Data Privacy Act) beyond what is strictly necessary for KYC and regulatory compliance purposes.

3. How We Collect Your Data

kuyaph collects personal data through the following means:

• Direct Collection: Information you provide when registering an Account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated Collection: Technical and usage data collected automatically when you access the kuyaph Platform, including through cookies, web beacons, and server logs.
• Third-Party Sources: Identity verification data from KYC service providers; fraud screening data from anti-fraud partners; payment data from payment processors such as GCash and Maya.
• Regulatory Sources: Information received from PAGCOR or other regulatory authorities in connection with compliance obligations.

4. How We Use Your Personal Data

kuyaph uses the personal data it collects for the following purposes:

• Account Management: Creating, maintaining, and managing your kuyaph Account, including processing your registration and verifying your identity.
• Platform Operation: Enabling you to access and use all features of the kuyaph Platform, including games, deposits, withdrawals, and promotions.
• KYC and Regulatory Compliance: Verifying your age (21+), identity, and source of funds as required by PAGCOR regulations and Philippine anti-money laundering laws.
• Payment Processing: Processing deposits and withdrawals through your chosen payment method (GCash, Maya, bank transfer, or debit card).
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, money laundering, and other illegal conduct on the Platform.
• Responsible Gaming: Monitoring gaming patterns to identify potential problem gambling behavior and to administer responsible gaming tools such as deposit limits and self-exclusion.
• Customer Support: Responding to your inquiries, resolving disputes, and providing technical assistance.
• Marketing Communications: Sending you promotional offers, bonuses, and platform updates, where you have consented to receive such communications. You may opt out at any time.
• Platform Improvement: Analyzing usage data to improve the kuyaph Platform's features, performance, and user experience.
• Legal Obligations: Complying with applicable Philippine laws, PAGCOR requirements, court orders, and regulatory requests.

5. Legal Basis for Processing

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

• Contractual Necessity: Processing necessary to perform the contract between you and kuyaph (i.e., the Terms and Conditions), including Account management, game operation, and payment processing.
• Legal Obligation: Processing required to comply with Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act itself.
• Legitimate Interests: Processing for kuyaph's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

6.1 kuyaph does not sell, rent, or trade your personal data to third parties for their own commercial purposes.

6.2 kuyaph 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:

• KYC and Identity Verification Providers: Third-party services that assist kuyaph in verifying player identities and ages as required by PAGCOR.
• Payment Processors: GCash, Maya, and banking partners necessary to process your deposits and withdrawals.
• Fraud Prevention and Security Partners: Services that help kuyaph detect and prevent fraudulent activity and money laundering.
• Game Providers: Third-party game developers and live dealer studios whose games are available on the kuyaph Platform, to the extent necessary for game operation.
• IT and Cloud Service Providers: Infrastructure and hosting providers that support the operation of the kuyaph Platform, subject to strict data processing agreements.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where required by law.
• Legal and Professional Advisors: Lawyers, auditors, and other professional advisors engaged by kuyaph, subject to professional confidentiality obligations.

6.3 All third-party service providers engaged by kuyaph are required to process personal data only in accordance with kuyaph's instructions and applicable data privacy laws.

7. Cookies and Tracking Technologies

7.1 The kuyaph Platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and analyze Platform usage.

7.2 The following types of cookies are used on the kuyaph Platform:

• Essential Cookies: Strictly necessary for the Platform to function, including session management and security cookies. These cannot be disabled.
• Analytics Cookies: Used to collect aggregated, anonymized data about how Players use the Platform, helping kuyaph improve its services.
• Preference Cookies: Used to remember your settings and preferences, such as language and display options.
• Marketing Cookies: Used to deliver relevant promotional content, subject to your consent.

7.3 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the kuyaph Platform.

8. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the kuyaph Platform.
• Encryption of sensitive data at rest, including financial information and government ID data.
• Role-based access controls ensuring that kuyaph staff can only access personal data necessary for their specific job functions.
• Regular security audits and penetration testing conducted by independent third-party security firms.
• Two-factor authentication options for Player Accounts to prevent unauthorized access.
• Secure, access-controlled data centers with physical security measures.

8.2 While kuyaph takes all reasonable precautions to protect your data, no security system is completely impenetrable. In the event of a data breach that poses a risk to your rights, kuyaph will notify you and the National Privacy Commission as required by law.

9. Data Retention

9.1 kuyaph retains personal data for the following periods, unless a longer retention period is required by Philippine law or PAGCOR regulations:

• Account Data: For the duration of your Account plus five (5) years following Account closure, as required by PAGCOR and anti-money laundering regulations.
• Financial Transaction Records: Ten (10) years from the date of the transaction, in compliance with the Anti-Money Laundering Act.
• KYC Documents: Five (5) years following Account closure or the completion of the relevant transaction.
• Support Communications: Three (3) years from the date of the communication, for dispute resolution and quality assurance purposes.
• Marketing Preferences: Until you withdraw your consent or close your Account, whichever is earlier.

9.2 Upon expiry of the applicable retention period, personal data will be securely deleted or irreversibly anonymized so that it can no longer be associated with you.

10. Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by kuyaph:

To exercise any of these rights, please contact the kuyaph Data Protection Officer using the contact details in Section 14. kuyaph will respond to all valid requests within thirty (30) days, as required by the Data Privacy Act.

11. Children's Privacy and Age Restrictions

11.1 The kuyaph Platform is strictly restricted to individuals who are twenty-one (21) years of age or older, in compliance with Philippine gambling laws and PAGCOR regulations. kuyaph does not knowingly collect personal data from individuals under 21 years of age.

11.2 If kuyaph discovers that personal data has been collected from a person under 21 years of age, the associated Account will be immediately suspended, all data will be deleted to the extent permitted by law, and the matter may be referred to the appropriate authorities.

11.3 Parents or guardians who believe that a minor has registered on the kuyaph Platform should contact kuyaph support immediately at [email protected].

12. Cross-Border Data Transfers

12.1 kuyaph's primary data processing operations are conducted within the Republic of the Philippines. However, some of kuyaph's third-party service providers, including game providers and cloud infrastructure partners, may process data in other jurisdictions.

12.2 Where personal data is transferred outside the Philippines, kuyaph ensures that appropriate safeguards are in place, including contractual data protection clauses that meet the standards required by the National Privacy Commission.

12.3 kuyaph will not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate safeguards and, where required, obtaining your consent.

13. Changes to This Privacy Policy

13.1 kuyaph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or Platform features. Material changes will be communicated to Players via email or a prominent notice on the kuyaph Platform at least seven (7) days before taking effect.

13.2 The "Last Updated" date at the top of this Policy indicates when it was most recently revised. We encourage you to review this Policy periodically to stay informed about how kuyaph protects your personal data.

13.3 Your continued use of the kuyaph Platform following notification of any amendment constitutes your acceptance of the revised Privacy Policy.

14. Contact and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or kuyaph's data practices, please contact our Data Protection Officer:

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 on the kuyaph Platform
• Response Time: DPO requests acknowledged within 72 hours; full response within 30 days

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that kuyaph has not handled your personal data in accordance with the Data Privacy Act of 2012.