kinph Privacy Policy

1. Introduction

kinph ("kinph," "we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who access or use the kinph Casino platform at https://kinph.vip and its associated subdomains, mobile-optimised pages, and related services (collectively, the "Platform").

This Privacy Policy ("Policy") describes the types of personal information kinph collects, the purposes for which it is processed, the parties with whom it may be shared, and the rights available to you as a data subject under the Republic Act No. 10173 — the Data Privacy Act of 2012 of the Philippines ("DPA") — and its implementing rules and regulations.

By registering a kinph account, accessing the kinph Login page, or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, you must not access or use the Platform.

This Policy should be read in conjunction with the kinph Terms & Conditions, which govern the contractual relationship between you and kinph. In the event of any conflict between this Policy and the Terms & Conditions regarding data privacy matters, this Policy shall prevail.

2. Data Controller

The data controller responsible for your personal information collected via the kinph Platform is kinph, the operator of https://kinph.vip. kinph processes personal data in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), the implementing rules issued by the National Privacy Commission (NPC) of the Philippines, and applicable PAGCOR requirements relating to player identity verification and record-keeping.

For all data privacy enquiries, requests to exercise your rights under the DPA, or to reach the kinph Data Protection Officer, please use the contact details set out in Section 13 of this Policy.

3. Personal Data We Collect

kinph collects the following categories of personal data in connection with the operation of the Platform:

3.1 Account Registration Data

• Full legal name
• Date of birth
• Email address
• Philippine mobile phone number
• Username and hashed password
• Preferred currency (Philippine Peso / PHP)

3.2 Identity Verification (KYC) Data

• Government-issued photo identification (PhilSys ID, UMID, passport, driver's license)
• Proof of address documentation where required
• Selfie or liveness verification image where required by kinph's KYC provider
• Source of funds documentation in cases where enhanced due diligence applies

3.3 Financial Transaction Data

• GCash account reference number (anonymised token — kinph does not store full GCash account credentials)
• PayMaya, BPI, BDO, and Metrobank transaction reference data
• Deposit amounts, withdrawal amounts, and transaction timestamps
• Account wallet balance history

3.4 Gaming Activity Data

• Game session history, wager amounts, game outcomes, and bonus usage records
• Sports betting selections and settlement records
• Responsible gaming tool settings and self-exclusion status

3.5 Technical & Device Data

• IP address and geolocation data (city/region level)
• Device type, operating system, and browser version
• Session duration, page visit logs, and click-path data
• Cookie identifiers (see Section 8)

3.6 Communications Data

• Support chat transcripts and email correspondence with kinph
• Complaint and dispute records
• Marketing communication preferences and opt-in/opt-out records

4. Purpose & Legal Basis for Processing

kinph processes your personal data only for specified, legitimate purposes. The following table summarises the primary processing activities and their corresponding legal bases under the Data Privacy Act of 2012:

Purpose	Legal Basis
Account creation, authentication, and management of your kinph account	Contractual necessity
Processing deposits and withdrawals via GCash, PayMaya, and Philippine bank channels	Contractual necessity
Identity and age verification (KYC) as required by PAGCOR regulations	Legal obligation
Anti-money laundering (AML) screening and suspicious activity monitoring	Legal obligation
Providing gaming services, calculating game outcomes, and settling wagers	Contractual necessity
Customer support, dispute resolution, and complaint handling	Contractual necessity / Legitimate interest
Responsible gaming monitoring, self-exclusion enforcement, and player protection	Legal obligation / Legitimate interest
Sending transactional notifications (deposits, withdrawals, account alerts)	Contractual necessity
Sending marketing communications about kinph promotions and offers	Consent (opt-in)
Platform security, fraud detection, and abuse prevention	Legitimate interest
Analytics, platform performance improvement, and game portfolio curation	Legitimate interest

Where kinph relies on your consent as the legal basis for processing — particularly for marketing communications — you have the right to withdraw that consent at any time via the communication preferences section of your kinph account dashboard, without affecting the lawfulness of processing that occurred prior to withdrawal.

5. Data Sharing & Third-Party Disclosure

kinph does not sell your personal data to third parties. kinph may share your personal data with the following categories of recipients strictly to the extent necessary for the purposes described in this Policy:

• PAGCOR and Philippine Regulatory Authorities: kinph is required to share player data with PAGCOR and other relevant Philippine government bodies as mandated by applicable gaming and AML regulations. Such disclosures are non-negotiable legal obligations.
• KYC and Identity Verification Providers: Third-party identity verification services process your KYC documents on kinph's behalf. These providers operate under data processing agreements and are bound by equivalent data security obligations.
• Payment Service Providers: GCash, PayMaya, and Philippine banking partners receive the minimum data necessary to process deposit and withdrawal transactions. kinph does not transmit full identity documents to payment providers.
• Game Content Providers: Third-party game studios (such as JILI, Pragmatic Play, PG Soft, Evolution) receive anonymised session identifiers to deliver game content. These providers do not receive your personal identity information.
• Cloud Infrastructure and IT Service Providers: kinph's Platform is hosted on secure cloud infrastructure. Service providers operating in this capacity are bound by data processing agreements and security standards consistent with the DPA.
• Law Enforcement and Courts: kinph may disclose personal data where required by valid legal process, court order, or binding government direction under Philippine law.

All third parties who process personal data on kinph's behalf are required to implement technical and organisational security measures consistent with kinph's obligations under the Data Privacy Act of 2012.

6. Data Retention

kinph retains personal data only for as long as necessary to fulfil the purpose for which it was collected, subject to applicable legal and regulatory minimum retention requirements. The following retention periods apply:

• Account and KYC Records: Retained for a minimum of five (5) years from account closure, consistent with PAGCOR record-keeping requirements and AML obligations under the Anti-Money Laundering Act of the Philippines.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming Activity Logs: Retained for a minimum of two (2) years from the date of each game session, or five (5) years where the session is subject to a dispute or investigation.
• Support Communications: Retained for two (2) years from the date of last correspondence, or until resolution of any related dispute.
• Marketing Consent Records: Retained until consent is withdrawn and for one (1) year thereafter for audit purposes.

Upon expiry of the applicable retention period, kinph will securely delete or anonymise your personal data in accordance with its internal data disposal procedures.

7. Data Security

kinph implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit Transport Layer Security (TLS) encryption for all data transmitted between your device and the kinph Platform.
• Encryption at rest for sensitive personal data fields, including identity document copies and financial data, stored in kinph's database infrastructure.
• One-way cryptographic hashing for all stored account passwords. kinph cannot retrieve your password in plain text.
• Role-based access controls limiting employee access to personal data to those with a legitimate operational need.
• Automated intrusion detection and anomalous access monitoring systems.
• Regular third-party penetration testing and security audits of the kinph Platform.
• Two-factor authentication (2FA) enforced for all internal kinph staff accounts with access to player data systems.

Notwithstanding these measures, no data transmission over the internet or data storage system is entirely secure. kinph will notify the National Privacy Commission (NPC) and affected players of any personal data breach that is likely to result in a risk to player rights and freedoms, within the timeframe required by the Data Privacy Act of 2012 and NPC Circular 16-03.

8. Cookies & Tracking Technologies

kinph uses cookies and similar tracking technologies to operate and improve the Platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the kinph Login session management, security token validation, and core Platform functionality. These cannot be disabled without impairing your ability to use the Platform.
• Functional Cookies: Store your language preferences, game lobby layout settings, and other personalisation options to improve your kinph experience.
• Analytics Cookies: Aggregate, anonymised data on page visits, session duration, and feature usage patterns used to improve the Platform. No personally identifiable data is transmitted to analytics systems.
• Marketing Cookies: Used only with your prior consent to measure the effectiveness of kinph promotional campaigns. You may withdraw consent via your account settings.

You may configure your browser to decline or delete cookies; however, disabling strictly necessary cookies will prevent you from accessing your kinph account and using the Platform's gaming features.

9. Your Data Subject Rights

Under the Data Privacy Act of 2012 (Republic Act No. 10173), 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 and processed — fulfilled by this Privacy Policy.
• Right of Access: The right to request a copy of the personal data kinph holds about you and information about how it is processed.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data held by kinph.
• 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 kinph's legal retention obligations under PAGCOR regulations and the Anti-Money Laundering Act.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to Object: The right to object to processing of your personal data for direct marketing purposes. You may opt out of marketing communications via your kinph account settings at any time.
• Right to Complain: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe kinph has not complied with its obligations under the Data Privacy Act.

To exercise any of the above rights, please contact kinph's Data Protection Officer as detailed in Section 13. kinph will respond to all valid data subject requests within 30 days of receipt, consistent with NPC requirements.

10. Minors

The kinph Platform is strictly prohibited for individuals under 21 years of age, consistent with PAGCOR regulations. kinph does not knowingly collect personal data from individuals below the minimum age of 21. Age is verified through mandatory KYC procedures at account registration.

If kinph discovers that personal data has been collected from a person under 21 years of age, the account will be immediately closed, all balances will be managed in accordance with PAGCOR guidance, and the personal data will be securely deleted to the extent permitted by legal and regulatory obligations.

11. International Data Transfers

kinph's primary data processing infrastructure is located within the Asia-Pacific region. Where personal data is transferred to processors or sub-processors located outside the Philippines — including cloud service providers or game content delivery networks — kinph ensures that such transfers are subject to adequate safeguards consistent with the Data Privacy Act of 2012, including standard contractual data processing agreements that impose equivalent data protection obligations on the recipient.

kinph will not transfer your personal data to any jurisdiction identified by the NPC as having inadequate data protection standards without implementing appropriate additional safeguards.

12. Policy Amendments

kinph reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or kinph's data processing practices. Material changes to this Policy will be communicated to registered players via the registered email address and by notice on the Platform at least seven (7) days before the amendment takes effect.

The "Last updated" date at the top of this page indicates when this Policy was most recently revised. Your continued use of the kinph Platform following the effective date of any amendment constitutes your acknowledgement of the updated Policy. If you do not agree to the amended Policy, you must close your kinph account by contacting support.

13. Contact & Data Protection Officer

For any questions about this Privacy Policy, to exercise your data subject rights under the Data Privacy Act of 2012, or to raise a data privacy concern, please contact kinph's Data Protection Officer:

Alternatively, you may contact the kinph customer support team via 24/7 live chat on the Platform. All data privacy requests submitted through support will be escalated to the Data Protection Officer within one (1) business day.

Players who are not satisfied with kinph's response to a data subject request may lodge a complaint with the National Privacy Commission (NPC) of the Philippines through the NPC's official complaint process.