kuyaph Privacy Policy

1 Introduction

kuyaph ("we," "us," or "our") operates the online gaming platform accessible at kuyaph.club (the "Platform"). kuyaph is a PAGCOR-registered and licensed online casino and sports betting platform serving players across the Philippines, including Manila, Cebu, Davao, Quezon City, Makati, and all other regions.

This Privacy Policy describes the types of personal data that kuyaph collects from individuals who visit, register on, or otherwise interact with the Platform; the purposes for which that data is collected and processed; the parties with whom it may be shared; and the rights available to you as a data subject under Philippine law.

By creating a kuyaph account or continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with its terms, please discontinue your use of the Platform and contact our Data Protection Officer to request account closure and data deletion.

2 Data Controller

The data controller responsible for your personal information is kuyaph, the operator of kuyaph.club, registered and licensed by the Philippine Amusement and Gaming Corporation (PAGCOR).

For all data privacy inquiries, requests to exercise data subject rights, and concerns regarding this Privacy Policy, you may contact our designated Data Protection Officer (DPO) at:

3 Personal Data We Collect

kuyaph collects personal data from you in several ways: information you provide directly during registration and use of the Platform; data collected automatically through your use of the Platform; and information obtained from third parties where required for regulatory compliance.

3.1 Information You Provide Directly

• Registration data: Full legal name, email address, Philippine mobile number, date of birth, and chosen username and password.
• Identity verification (KYC): Government-issued ID documents (PhilSys ID, Passport, Driver's License, SSS ID, UMID), selfie with ID, and proof of residential address. This is required by PAGCOR regulations before withdrawals are enabled.
• Payment information: GCash mobile number, PayMaya account details, BPI, BDO, or Metrobank account number and registered name. Note: kuyaph does not store complete bank account numbers — payment processing is handled by accredited third-party payment processors.
• Communications: Messages sent to kuyaph through live chat, email support, or any feedback mechanisms on the Platform.

3.2 Data Collected Automatically

• Technical data: IP address, browser type and version, device type (Android/iOS, mobile/desktop), operating system, and time zone setting.
• Usage data: Pages visited, game sessions initiated, bet amounts, game history, session duration, login timestamps, and navigation patterns within the Platform.
• Cookies and similar technologies: Session identifiers, preference cookies, and analytics cookies. See Section 7 for full details.
• Geolocation: General geographic location derived from your IP address, used to confirm access from within the Philippines in compliance with PAGCOR licensing requirements.

3.3 Data From Third Parties

• Identity verification partners: Results of automated document and facial verification checks performed by accredited KYC service providers.
• Payment processors: Transaction confirmation data from GCash, PayMaya, and banking partners — sufficient to confirm and record deposits and withdrawals.
• Fraud and AML screening: Data from anti-money laundering (AML) and sanctions screening services used to comply with Philippine anti-money laundering regulations.

4 How We Use Your Personal Data

kuyaph processes personal data for the following purposes:

• Account registration and management: To create and maintain your kuyaph account, verify your identity, and manage your login access.
• Service delivery: To provide access to games, process bets, calculate winnings, and deliver the overall Platform experience to you.
• Payment processing: To process deposits (via GCash, PayMaya, BPI, BDO, Metrobank) and withdrawals, and to maintain accurate financial records.
• Regulatory compliance: To fulfill kuyaph's legal obligations under PAGCOR's licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws and regulations.
• Responsible gaming: To monitor gaming behavior for signs of problem gambling and enforce deposit limits, cooling-off periods, and self-exclusion where applicable. kuyaph is required under PAGCOR regulations to implement these protections.
• Customer support: To respond to your inquiries submitted through live chat or email, and to resolve account issues, disputes, and complaints.
• Security and fraud prevention: To detect, investigate, and prevent unauthorized account access, fraudulent transactions, money laundering, and platform abuse.
• Analytics and improvement: To analyze aggregated usage data and improve the Platform's performance, user interface, and game offerings. This is done using anonymized or pseudonymized data wherever possible.
• Promotions and communications: To send you information about bonuses, promotions, and account-related updates via your registered email or SMS. You may opt out of promotional communications at any time by contacting support.

5 Legal Basis for Processing

Under the Data Privacy Act of 2012 and its Implementing Rules, kuyaph processes your personal data on the following legal grounds:

• Contractual necessity: Processing is necessary to perform our obligations under the Terms and Conditions you agreed to upon registration — including maintaining your account, processing payments, and providing gaming services.
• Legal obligation: Processing is required to comply with PAGCOR licensing conditions, AMLA reporting requirements, NPC regulations, and other applicable Philippine laws.
• Legitimate interests: Processing is necessary for kuyaph's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and service improvement — provided these interests are not overridden by your fundamental rights.
• Consent: Where kuyaph processes data for purposes not covered by the grounds above (such as certain marketing communications), we will obtain your explicit consent, which you may withdraw at any time without affecting the lawfulness of prior processing.

6 Data Sharing and Disclosure

kuyaph does not sell, rent, or trade your personal information. We share your data only in the following circumstances and only to the extent necessary:

• Payment processors: GCash (G-Xchange Inc.), PayMaya Philippines Inc., and accredited banking partners receive the minimum data necessary to process transactions (e.g., account number, transaction amount, name for matching purposes).
• Identity verification providers: Accredited KYC and AML screening service providers receive identity document data for the purpose of regulatory compliance checks. These providers are bound by data processing agreements and Philippine privacy law.
• PAGCOR and regulatory authorities: kuyaph is legally required to provide transaction records, account data, and other information to PAGCOR upon authorized request, and to the Anti-Money Laundering Council (AMLC) in connection with reporting obligations under AMLA.
• Law enforcement: kuyaph will disclose personal data to Philippine law enforcement authorities or courts where legally compelled by a valid court order, subpoena, or other lawful government demand.
• Game and technology providers: Game software providers (such as Pragmatic Play, PG Soft, JILI, and others) may receive session data (e.g., bet amounts, round results) necessary to power their game logic. These providers do not receive your identity or payment details.
• Professional advisors: kuyaph's legal, audit, and compliance advisors may access your data on a strictly need-to-know basis under professional confidentiality obligations.

All third parties who receive personal data from kuyaph are required to process it only for the stated purpose and in accordance with applicable Philippine data protection laws. kuyaph maintains data processing agreements with all data processors to ensure compliance.

7 Cookies and Tracking Technologies

kuyaph uses cookies and similar technologies to operate the Platform, improve your experience, and fulfill certain security and regulatory obligations. The types of cookies we use include:

• Strictly necessary cookies: Essential for Platform operation — session management, login authentication, security token storage. These cannot be disabled without preventing core functionality.
• Functional cookies: Remember your preferences (language, display settings) to personalize your experience across sessions.
• Analytics cookies: Collect anonymized data on how visitors use the Platform — pages viewed, session duration, navigation flows — to help kuyaph improve the user experience.
• Security cookies: Used to detect suspicious login patterns and prevent unauthorized account access.

kuyaph does not use third-party advertising or cross-site tracking cookies. You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to log in and use the Platform.

8 Data Retention

kuyaph retains your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy, subject to the following specific retention schedules:

• Account and identity data: Retained for the duration of your account's existence and for a minimum of five (5) years after account closure, as required by PAGCOR regulations and AMLA reporting obligations.
• Transaction records: All deposit and withdrawal records are retained for a minimum of five (5) years following the date of the transaction, in compliance with AMLA and PAGCOR requirements.
• Game history: Individual game session records are retained for two (2) years from the date of the session, or longer if required for the resolution of an active dispute.
• Customer support communications: Support interactions are retained for two (2) years from the date of the last interaction.
• KYC documents: Identity verification documents are retained for five (5) years following account closure, as required by applicable anti-money laundering regulations.

When data retention periods expire, kuyaph securely deletes the data or anonymizes it so that it can no longer be attributed to you. Data deletion requests submitted by you (see Section 10) are processed subject to these minimum legal retention requirements — we cannot delete data that we are legally required to retain.

9 Security Measures

kuyaph implements appropriate technical and organizational 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 transmission between your device and kuyaph's servers.
• Encryption of sensitive data fields (including identity document details and payment information) at rest in our databases.
• Role-based access controls limiting internal staff access to personal data on a strict need-to-know basis.
• Two-factor authentication (SMS OTP) for all player accounts and for kuyaph staff systems handling personal data.
• Regular penetration testing and security audits of the Platform infrastructure.
• Intrusion detection systems and continuous monitoring of server activity for anomalous patterns.
• Documented incident response procedures, including NPC breach notification procedures where a personal data breach meets the reporting threshold under RA 10173.

10 Your Data Subject Rights

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

• Right to be informed: The right to know that kuyaph is collecting and processing your personal data, the purposes for which it is collected, and how it is used — as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data that kuyaph holds about you, including information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. For most account details, you may update information directly in your account settings.
• Right to erasure (right to be forgotten): The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected. This right is subject to kuyaph's legal retention obligations (see Section 8).
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another controller where technically feasible.
• Right to object: The right to object to the processing of your personal data for purposes of direct marketing or profiling, and to certain processing based on legitimate interests.
• Right to damages: The right to be compensated for any damages sustained as a result of inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of your personal data, subject to applicable law.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data rights have been violated. The NPC can be reached at privacy.gov.ph.

To exercise any of these rights, submit a written request to kuyaph's Data Protection Officer at [email protected] with the subject line "Data Privacy Request." Include your full name, registered account email, and a clear description of your request. kuyaph will respond within fifteen (15) business days of receipt.

11 Minors and Age Restriction

kuyaph is strictly an adult platform. In compliance with PAGCOR regulations and Philippine law, kuyaph's gaming services are available exclusively to individuals who are 21 years of age or older. kuyaph does not knowingly collect personal data from individuals under 21 years old.

Age verification is a mandatory component of kuyaph's KYC process. All accounts must be verified with a valid Philippine government-issued ID prior to withdrawal access, and accounts confirmed to belong to individuals under the age of 21 will be immediately suspended and any remaining balance returned to the player's registered payment method.

If kuyaph becomes aware that it has inadvertently collected personal data from a person under 21 years of age, that data will be promptly deleted and the account closed. If you have reason to believe that a minor has created a kuyaph account, please contact us immediately at [email protected].

12 International Data Transfers

As a platform operating primarily within the Philippines, kuyaph processes most personal data on servers located in or serving the Philippine market. However, certain technology and service providers engaged by kuyaph — such as game software providers and cloud infrastructure services — may operate from outside the Philippines.

Where personal data is transferred to entities outside the Philippines, kuyaph ensures that such transfers comply with the Data Privacy Act's requirements for cross-border data sharing, including the implementation of appropriate contractual safeguards (standard contractual clauses or equivalent measures) to ensure that your data receives a level of protection equivalent to that required under Philippine law.

kuyaph does not transfer identity verification documents or payment details to entities outside the Philippines without explicit contractual data protection terms and regulatory justification.

13 Changes to This Privacy Policy

kuyaph reserves the right to update or modify this Privacy Policy at any time. Any material changes — changes that affect your rights or significantly alter how your personal data is processed — will be communicated to you through one or more of the following methods:

• A notice prominently displayed on the kuyaph Platform or login page for a period of at least 30 days before the change takes effect.
• An email notification to your registered kuyaph account email address.
• An in-account notification message visible upon your next login.

The "Last Updated" date at the top of this Privacy Policy reflects the most recent revision. Continued use of the Platform after the effective date of any changes constitutes your acceptance of the updated Privacy Policy. If you do not agree with the updated terms, you have the right to close your account and request data deletion under Section 10.

Non-material changes (such as typographical corrections, clarifications that do not affect your rights, or administrative updates) may be made without prior notice.

14 Contact Us & Data Protection Officer

For all inquiries, concerns, complaints, or requests related to this Privacy Policy or your personal data rights, contact kuyaph's Data Protection Officer:

If you are not satisfied with kuyaph's response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the government body responsible for administering and implementing the Data Privacy Act of 2012 and may be contacted through official Philippine government channels.