kishph Privacy Policy

1. Introduction

1.1 kishph ("we", "us", "our") is committed to protecting the privacy and personal data of all individuals who access or use the kishph platform, including registered players, prospective players, and visitors to the kishph.net website (collectively, "you" or "Data Subject").

1.2 This Privacy Policy has been prepared in compliance with Republic Act No. 10173, known as the Philippine Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations, as administered by the National Privacy Commission ("NPC") of the Philippines. Where kishph processes personal data of individuals located within the Philippines, the DPA governs that processing.

1.3 This Privacy Policy should be read in conjunction with kishph's Terms & Conditions, which constitute the primary agreement between you and kishph. In the event of any conflict between this Privacy Policy and the Terms & Conditions with respect to data privacy matters, this Privacy Policy shall prevail.

1.4 For the purposes of this Privacy Policy, "personal data" means any information from which you can be identified, directly or indirectly, including but not limited to your name, contact details, financial information, government-issued identification numbers, and device or usage data.

2. Personal Data We Collect

2.1 kishph collects personal data from you in several ways: directly when you register or interact with our platform, automatically when you use our Services, and from third parties such as payment processors and KYC verification providers.

2.1 Registration and Account Data

When you create a kishph account, we collect:

• Full legal name as it appears on your government-issued ID;
• Date of birth (to verify you meet the 21+ age requirement);
• Email address and mobile phone number;
• Residential address (barangay, city/municipality, province, zip code);
• Username and encrypted password;
• Preferred currency (Philippine Peso / PHP).

2.2 Identity Verification (KYC) Data

As required by applicable Philippine regulations and our internal compliance framework, kishph collects:

• Government-issued photo identification (Philippine National ID, Passport, Driver's License, SSS/GSIS/TIN/PhilHealth card);
• Selfie or live photo for biometric comparison against submitted ID;
• Proof of billing address where required;
• Source of funds documentation for accounts that meet certain deposit thresholds.

2.3 Financial and Transaction Data

• Deposit and withdrawal transaction history, amounts, and timestamps;
• Payment method identifiers (GCash mobile number, Maya account reference, bank account last digits, wallet IDs);
• Account balance history and bonus credit usage;
• Wagering history across all kishph game categories.

2.4 Technical and Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser type and version;
• Session start and end times, pages visited, and click-stream data;
• Cookie and similar tracking technology identifiers (see Section 6).

2.5 Communications Data

• Records of your interactions with kishph's Live Chat, email support, and Messenger or Viber channels;
• Feedback, complaints, and dispute records;
• Marketing preference settings and communication opt-in or opt-out records.

3. How We Use Your Personal Data

3.1 kishph uses your personal data for the following purposes:

4. Legal Basis for Processing

4.1 Contract Performance. The majority of kishph's data processing activities are necessary for the performance of the contract between you and kishph (i.e., the Terms & Conditions). Without this processing, kishph cannot deliver the Services to you.

4.2 Legal Obligation. Certain processing activities are required by Philippine law, including KYC verification under the Anti-Money Laundering Act, age verification under gaming regulations, and data retention requirements under the DPA and other applicable statutes.

4.3 Legitimate Interest. kishph processes some data based on its legitimate interests in maintaining platform security, detecting and preventing fraud, and improving the Services, provided that such interests are not overridden by your fundamental rights and freedoms.

4.4 Consent. Where kishph relies on your consent as the legal basis for processing — such as for sending promotional communications — you may withdraw that consent at any time by updating your communication preferences in your kishph account settings or by contacting our support team.

5. Data Sharing and Disclosure

5.1 kishph does not sell, rent, or trade your personal data. We may share your data only in the following circumstances:

5.1 Regulated Service Providers

kishph engages third-party service providers who process personal data on our behalf, strictly under written data processing agreements that require them to maintain confidentiality and implement appropriate security measures. These providers include:

• KYC and identity verification providers;
• Payment processors (GCash, Maya, BPI, BDO, UnionBank, Coins.ph, and others);
• Game content suppliers and platform technology providers;
• Customer support platform operators;
• Cloud hosting and data storage providers.

5.2 Regulatory and Law Enforcement Authorities

kishph may disclose personal data to Philippine government authorities, including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies, where such disclosure is required by law, court order, or regulatory directive.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or a material portion of kishph's assets, your personal data may be transferred to the acquiring entity, provided that the acquiring entity agrees to be bound by data protection obligations no less protective than those set out in this Privacy Policy.

5.4 With Your Consent

kishph may share your data with other third parties where you have given explicit consent for such sharing. You may withdraw this consent at any time.

6. Cookies and Similar Technologies

6.1 kishph uses cookies and similar tracking technologies on the kishph.net website to support platform functionality, enhance your user experience, analyze usage patterns, and deliver relevant content.

6.2 The following categories of cookies are used on kishph:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies, CSRF protection tokens, and load-balancing cookies. They cannot be disabled without breaking core functionality.
• Functional Cookies: Remember your preferences such as language settings, display preferences, and game lobby filters to provide a more personalized experience.
• Analytics Cookies: Collect anonymized data about how players navigate and interact with the kishph platform, helping us identify areas for improvement. No individually identifiable data is shared via these cookies.
• Security Cookies: Used for fraud detection, bot prevention, and responsible gaming monitoring purposes.

6.3 You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to use the kishph platform. Disabling functional or analytics cookies may affect your user experience but will not prevent you from accessing core platform features.

7. Data Retention

7.1 kishph retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulation.

7.2 As a general guideline:

• Active account data is retained for the duration of the player's account with kishph;
• KYC and identity verification records are retained for a minimum of five (5) years following account closure, in accordance with AMLC and PAGCOR requirements;
• Transaction and financial records are retained for a minimum of five (5) years from the date of the transaction;
• Customer support communications are retained for three (3) years from the date of closure of the relevant support case;
• Marketing consent records are retained until consent is withdrawn, plus an additional period as required for legal accountability purposes.

7.3 Upon expiry of the applicable retention period, kishph will securely delete or anonymize your personal data in accordance with its data disposal procedures.

8. Data Security

8.1 kishph implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, disclosure, alteration, destruction, and loss. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the kishph platform;
• Encryption of sensitive data at rest, including payment method identifiers and KYC documents;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Multi-factor authentication requirements for kishph staff accessing production systems;
• Regular penetration testing and security vulnerability assessments;
• Formal data breach detection, response, and notification procedures.

8.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, kishph will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals within a reasonable time thereafter, in accordance with the DPA's breach notification requirements.

9. Your Data Rights

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

9.2 To exercise any of the above rights, please contact kishph's Data Protection Officer at [email protected] with the subject line "Data Rights Request". kishph will acknowledge your request within five (5) business days and respond substantively within thirty (30) calendar days, as required by the DPA.

9.3 kishph may request proof of identity before processing a data rights request to ensure that personal data is not disclosed to, modified by, or deleted at the request of an unauthorized individual.

10. Minors and Age Restriction

10.1 The kishph platform is strictly for individuals aged 21 years and above. kishph does not knowingly collect personal data from individuals below the age of 21. If kishph discovers that personal data has been collected from an individual under 21, that data will be deleted immediately and the associated account will be permanently closed.

10.2 If you are a parent or guardian and believe that a minor may have registered on kishph, please contact us immediately at [email protected]. We will investigate and take appropriate action without delay.

11. Cross-Border Data Transfers

11.1 Some of kishph's third-party service providers — including cloud hosting providers and game content suppliers — may process personal data outside of the Philippines. Where such cross-border transfers occur, kishph ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under Philippine law.

11.2 These safeguards may include contractual data protection clauses, the recipient country's data protection law being recognized as adequate by the NPC, or other legally recognized transfer mechanisms. kishph will not transfer personal data to a recipient in a jurisdiction that does not offer adequate protections without first obtaining your explicit consent or as permitted under the DPA.

12. Changes to This Privacy Policy

12.1 kishph reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, kishph will notify registered players by email or through a prominent notice on the platform at least fourteen (14) days before the changes take effect.

12.2 The "Effective Date" at the top of this Privacy Policy indicates when the current version was last reviewed and published. We encourage you to review this Privacy Policy periodically to remain informed about how kishph protects your personal data.

12.3 Your continued use of the kishph platform after any changes to this Privacy Policy take effect constitutes your acceptance of the updated policy. If you do not agree with any change, you may close your account by contacting kishph Live Chat.

13. Contact and Data Protection Officer

13.1 kishph has appointed a Data Protection Officer ("DPO") responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests regarding the handling of your personal data, please contact the kishph DPO through any of the following channels:

• Email: [email protected] (Subject: "Privacy / Data Rights Request")
• Live Chat: Available 24/7 on the kishph platform
• Messenger: kishph Official
• Viber: kishph Community

13.2 If you are not satisfied with kishph's response to a data privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official government website.