Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") explains how kiriya Gaming Corporation ("kiriya", "we", "us", "our") collects, uses, discloses, stores, and protects personal information from users ("you", "your", "User") of our online casino and gaming platform accessible at kiriya.cam and through our mobile applications. This Policy applies to all services, games, promotions, and communications provided by kiriya to players in the Philippines and other jurisdictions where our services are legally available.

We are committed to protecting your privacy and handling your personal data responsibly in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and other applicable data protection laws and regulations issued by the National Privacy Commission (NPC) of the Philippines. By creating an account and using kiriya's services, you acknowledge that you have read, understood, and consent to the practices described in this Privacy Policy.

2. Information We Collect

2.1 Personal Information Provided by You

When you register an account with kiriya, we collect personal information that you voluntarily provide to us. This information is necessary to create and maintain your account, process transactions, verify your identity, and comply with regulatory requirements under PAGCOR licensing and Philippine anti-money laundering laws. The personal information we collect includes:

• Identity Information: Full legal name, date of birth, nationality, gender, and government-issued identification numbers (such as passport number, driver's license number, or UMID number)
• Contact Information: Email address, mobile phone number, residential address, and postal code
• Financial Information: Bank account details, e-wallet account information (GCash, PayMaya), credit/debit card numbers, cryptocurrency wallet addresses, transaction history, deposit and withdrawal records
• Account Credentials: Username, password (stored in encrypted form), security questions and answers, and two-factor authentication settings
• Verification Documents: Copies of government-issued IDs, proof of address documents (utility bills, bank statements), selfie photos for identity verification, and proof of payment method ownership
• Communication Records: Chat transcripts with customer support, email correspondence, feedback forms, survey responses, and complaint records

2.2 Information Collected Automatically

When you access and use kiriya's platform, we automatically collect certain technical and usage information through cookies, web beacons, and similar tracking technologies. This information helps us improve our services, enhance security, prevent fraud, and personalize your gaming experience. Automatically collected information includes:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address), mobile network information
• Usage Data: Pages visited, games played, bet amounts, win/loss records, session duration, click patterns, features used, referral sources
• Location Data: IP address, geolocation data (country, city, region) to verify compliance with jurisdictional restrictions
• Connection Data: Internet service provider, connection speed, timestamps of access, error logs, crash reports
• Cookie Data: Unique identifiers, session tokens, preference settings, authentication status, marketing campaign tracking parameters

2.3 Information from Third Parties

In some cases, we may receive information about you from third-party sources to enhance our services, verify your identity, or comply with legal obligations. These sources include payment processors (for transaction verification), identity verification services (for KYC compliance), fraud prevention agencies (for security screening), and social media platforms (if you choose to link your account). We only collect such information with your consent or where permitted by law.

3. How We Use Your Information

kiriya uses your personal information for various purposes related to providing, maintaining, and improving our gaming services, complying with legal obligations, and communicating with you about your account. The specific purposes for which we process your data include:

3.1 Account Management and Service Provision

• Creating and maintaining your player account
• Authenticating your identity and verifying your age (21+ requirement)
• Processing deposits, withdrawals, and payment transactions
• Managing your gaming sessions and bet placements
• Calculating winnings, losses, and account balances
• Applying bonuses, promotions, and loyalty rewards
• Implementing responsible gaming tools (deposit limits, self-exclusion)

3.2 Legal and Regulatory Compliance

• Complying with PAGCOR licensing requirements and gaming regulations
• Fulfilling Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under the Anti-Money Laundering Act (AMLA)
• Responding to lawful requests from government authorities, courts, and law enforcement
• Maintaining records as required by gaming and financial regulations
• Reporting suspicious transactions to the Anti-Money Laundering Council (AMLC)
• Verifying that players are not located in restricted jurisdictions

3.3 Security and Fraud Prevention

• Detecting and preventing fraudulent activities, money laundering, and unauthorized access
• Monitoring for unusual betting patterns or bonus abuse
• Investigating disputes, chargebacks, and account security incidents
• Enforcing our Terms and Conditions and protecting our rights
• Maintaining the integrity and fairness of our games
• Protecting against cyber attacks, hacking attempts, and malicious software

3.4 Communication and Customer Support

• Responding to your inquiries, support requests, and complaints
• Sending transactional notifications (deposits, withdrawals, bonus awards)
• Providing important account and security updates
• Notifying you of changes to our terms, policies, or services
• Conducting customer satisfaction surveys and gathering feedback

3.5 Marketing and Personalization (With Your Consent)

• Sending promotional emails about new games, bonuses, and special offers
• Delivering personalized game recommendations based on your preferences
• Showing targeted advertisements and marketing campaigns
• Inviting you to participate in tournaments, competitions, and loyalty programs
• Conducting market research and analyzing player behavior to improve our offerings

You may opt out of marketing communications at any time by clicking the unsubscribe link in our emails or adjusting your communication preferences in your account settings. Please note that even if you opt out of marketing communications, we will still send you essential transactional and account-related messages.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, we must have a lawful basis to collect and process your personal information. kiriya relies on the following legal grounds:

• Consent: When you create an account and accept this Privacy Policy, you provide explicit consent for us to process your personal data for the purposes described herein. You may withdraw consent at any time by closing your account.
• Contract Performance: Processing is necessary to perform our contract with you (Terms and Conditions) and provide gaming services you have requested.
• Legal Obligation: We must process certain data to comply with legal requirements under PAGCOR regulations, the Anti-Money Laundering Act, tax laws, and other applicable Philippine legislation.
• Legitimate Interests: We process data to protect our legitimate business interests, such as fraud prevention, security enhancement, and improvement of services, provided these interests do not override your privacy rights.

5. Information Sharing and Disclosure

kiriya does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with carefully selected partners and service providers in the following circumstances:

5.1 Service Providers and Business Partners

We engage trusted third-party service providers to support our operations. These providers have access to personal information only to perform specific tasks on our behalf and are contractually obligated to maintain confidentiality and security. Service providers include:

• Payment processors (GCash, PayMaya, banks, cryptocurrency exchanges) for processing transactions
• Identity verification services for KYC/AML compliance
• Cloud hosting providers for data storage and computing infrastructure
• Customer support platforms for managing inquiries and communications
• Game providers and software developers for delivering gaming content
• Marketing and analytics platforms for campaign management and performance tracking
• Fraud detection and security services for protecting against unauthorized activities

5.2 Legal and Regulatory Authorities

We may disclose your information to government agencies, regulators, and law enforcement when required by law or in good faith belief that such disclosure is necessary to:

• Comply with PAGCOR inquiries and regulatory investigations
• Respond to court orders, subpoenas, or legal processes
• Report suspicious transactions to the Anti-Money Laundering Council (AMLC)
• Cooperate with tax authorities (Bureau of Internal Revenue)
• Protect the rights, property, or safety of kiriya, our users, or the public
• Investigate fraud, security breaches, or violations of our Terms and Conditions

5.3 Business Transfers

In the event of a merger, acquisition, corporate reorganization, or sale of all or a portion of our assets, your personal information may be transferred to the acquiring entity. We will notify you via email and/or prominent notice on our website of any change in ownership or use of your personal information, and you will have the opportunity to withdraw consent if the new entity's privacy practices differ substantially from this Policy.

5.4 With Your Consent

We may share your information with other third parties when you have provided explicit consent for such sharing, such as when you participate in co-branded promotions or choose to link your kiriya account with social media platforms.

6. Data Security Measures

kiriya implements robust technical, organizational, and physical security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security framework includes:

• Encryption: All sensitive data transmissions are protected using industry-standard SSL/TLS encryption. Passwords are stored using secure one-way hashing algorithms.
• Access Controls: Access to personal information is restricted to authorized employees and contractors who require it to perform their job functions. Multi-factor authentication is enforced for administrative access.
• Network Security: Firewalls, intrusion detection systems, and regular security audits protect our infrastructure from external threats.
• Data Segregation: Personal and financial data are stored in secure, segregated databases with strict access protocols.
• Regular Monitoring: Continuous monitoring for suspicious activities, unauthorized access attempts, and data breaches.
• Incident Response: Documented procedures for responding to and reporting data breaches in accordance with NPC requirements.
• Employee Training: Regular privacy and security training for all staff handling personal data.

Despite our best efforts, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and should immediately notify us of any unauthorized access.

7. Data Retention

kiriya retains your personal information only for as long as necessary to fulfill the purposes for which it was collected and to comply with legal, regulatory, and business requirements. Specific retention periods include:

Data Category	Retention Period	Reason
Account Information	Duration of account + 7 years	PAGCOR regulatory requirement, AML compliance
Transaction Records	7 years after transaction	Anti-Money Laundering Act, tax laws
Identity Verification Documents	7 years after account closure	KYC/AML regulatory obligations
Gaming Activity Logs	5 years	Regulatory compliance, dispute resolution
Marketing Communications	Until consent withdrawn or account closure	Consent-based processing
Support Communications	3 years	Customer service quality, dispute resolution

When your data is no longer required, we securely delete or anonymize it in accordance with data protection best practices. In some cases, we may retain anonymized or aggregated data indefinitely for statistical analysis and service improvement, as such data cannot identify you personally.

8. Your Privacy Rights

Under the Data Privacy Act of 2012 and its implementing regulations, you have the following rights regarding your personal information:

8.1 Right to Be Informed

You have the right to be informed about the collection, use, and disclosure of your personal data. This Privacy Policy serves as our primary notice, and we will provide additional information upon request.

8.2 Right to Access

You may request a copy of the personal information we hold about you. We will provide this information in a commonly used electronic format within thirty (30) days of your request.

8.3 Right to Correction

If your personal information is inaccurate, incomplete, or outdated, you may request that we correct or update it. You can update most information directly through your account settings, or contact our support team for assistance.

8.4 Right to Erasure (Right to Be Forgotten)

You may request deletion of your personal data when it is no longer necessary for the purposes for which it was collected, when you withdraw consent, or when processing is unlawful. Please note that we may be required to retain certain information for legal compliance even after you request deletion.

8.5 Right to Object

You have the right to object to processing of your personal data for direct marketing purposes or when processing is based on legitimate interests. We will cease such processing unless we demonstrate compelling legitimate grounds that override your interests.

8.6 Right to Data Portability

You may request that we transfer your personal data to another service provider in a structured, commonly used, and machine-readable format, where technically feasible.

8.7 Right to Withdraw Consent

Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

8.8 Right to File a Complaint

If you believe we have violated your privacy rights or the Data Privacy Act, you have the right to file a complaint with the National Privacy Commission of the Philippines. Contact details: NPC ePLDT Bldg., Malugay St., Makati City; Email: [email protected]; Hotline: (+632) 8234-2228.

To exercise any of these rights, please submit a written request to our Data Protection Officer at [email protected]. We may require verification of your identity before processing your request to ensure security.

9. Cookies and Tracking Technologies

kiriya uses cookies, web beacons, and similar tracking technologies to enhance your experience, analyze usage patterns, and deliver personalized content. A cookie is a small text file stored on your device that allows us to recognize you and remember your preferences.

9.1 Types of Cookies We Use

• Essential Cookies: Required for basic site functionality, account authentication, and security. These cookies cannot be disabled.
• Performance Cookies: Collect anonymous information about how you use our site to help us improve performance and user experience.
• Functional Cookies: Remember your preferences (language, currency, game settings) to provide a more personalized experience.
• Marketing Cookies: Track your activity across websites to deliver relevant advertisements and measure campaign effectiveness.

9.2 Managing Cookie Preferences

Most web browsers allow you to manage cookie settings through your browser preferences. You can choose to block or delete cookies, though this may impact your ability to use certain features of our platform. To opt out of marketing cookies specifically, visit your account settings or use the cookie consent manager available on our website.

10. International Data Transfers

kiriya primarily operates within the Philippines and stores data on servers located in secure facilities within Philippine jurisdiction. However, some of our service providers may be located outside the Philippines, which may involve transferring your personal data to countries with different data protection standards.

When we transfer data internationally, we ensure appropriate safeguards are in place, such as standard contractual clauses, adequacy decisions, or binding corporate rules. We only transfer data to jurisdictions and entities that provide an adequate level of protection as determined by the National Privacy Commission or implement equivalent protective measures.

11. Children's Privacy

kiriya's services are strictly intended for individuals who are 21 years of age or older, as required by Philippine gaming laws. We do not knowingly collect personal information from individuals under 21 years of age. If we become aware that we have inadvertently collected information from a minor, we will take immediate steps to delete such information and terminate the associated account.

Parents or guardians who believe their child has provided personal information to kiriya should contact us immediately at [email protected] so we can take appropriate action.

12. Changes to This Privacy Policy

kiriya reserves the right to modify, update, or replace this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. We will notify you of material changes by posting the updated Policy on our website with a revised "Last Updated" date and, where appropriate, by sending an email notification to your registered address.

Your continued use of our services after changes become effective constitutes acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your information. If you do not agree with any changes, you may close your account by contacting customer support.

13. Contact Information

For questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact our Data Protection Officer:

• Data Protection Officer
• Email: [email protected]
• General Support Email: [email protected]
• Customer Support: Available 24/7 via live chat on kiriya.cam
• Mailing Address: kiriya Gaming Corporation, Data Privacy Office, Metro Manila, Philippines

We are committed to responding to all privacy inquiries within thirty (30) days. For urgent security matters, please contact us immediately through our 24/7 live chat support.