kiffywin Privacy Policy

kiffywin ("kiffywin," "we," "us," or "our") is committed to protecting the privacy and personal data of all users ("you," "Player," or "User") of the kiffywin platform at kiffywin.vip. This Privacy Policy describes how we collect, use, disclose, store, and protect your personal information when you access or use our website, games, and related services (collectively, the "Platform").

This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC) of the Philippines.

By registering for a kiffywin account, accessing the Platform, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

For the purposes of the Philippine Data Privacy Act of 2012, kiffywin acts as the Personal Information Controller (PIC) in respect of the personal data you provide when using the Platform. As PIC, kiffywin determines the purposes and means of processing your personal information.

kiffywin has designated a Data Protection Officer (DPO) responsible for overseeing compliance with applicable data privacy laws and this Privacy Policy. You may contact our DPO using the details provided in Section 16 of this Policy.

kiffywin collects the following categories of personal data from users of the Platform:

3.1 Identity & Contact Information

• Full legal name as it appears on your government-issued ID
• Date of birth (used to verify the 21+ age requirement)
• Residential address, city, and province (e.g., Metro Manila, Cebu, Davao, Quezon City, Makati)
• Valid email address
• Mobile phone number registered in the Philippines
• Nationality and citizenship

3.2 Identity Verification (KYC) Documents

• Government-issued photo identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's license, UMID)
• Proof of address documents (e.g., utility bills, bank statements)
• Selfie or live photo for biometric verification purposes
• Source of funds documentation where required by anti-money laundering regulations

3.3 Financial Information

• GCash or PayMaya / Maya account details (mobile number only — we do not store PINs or passwords)
• Bank account details for bank transfer transactions (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank)
• Debit card details (card number, expiry — stored in tokenized form only)
• Transaction history, deposit and withdrawal records denominated in Philippine Peso (PHP / ₱)

3.4 Account & Gaming Activity Data

• Username and account preferences
• Game history, bet amounts, win/loss records, and session durations
• Bonus and promotion usage history
• Responsible gaming settings and self-exclusion records
• Customer support communications and complaint records

3.5 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Pages visited, features used, and time spent on the Platform
• Cookies and similar tracking technologies (see Section 11)
• Login timestamps and session logs

kiffywin collects your personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access and interact with the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from payment processors such as GCash and Maya; and publicly available information where permitted by law.
• Regulatory sources: Information received from PAGCOR, the Anti-Money Laundering Council (AMLC), or other competent Philippine authorities in connection with our legal and regulatory obligations.

kiffywin processes your personal data for the following purposes:

• Account management: To create, maintain, and manage your kiffywin account, including verifying your identity and eligibility to use the Platform.
• Service delivery: To provide access to games, process deposits and withdrawals in Philippine Peso, and deliver the features and functionality of the Platform.
• Legal compliance: To comply with our obligations under Philippine law, including the Data Privacy Act, Anti-Money Laundering Act, and PAGCOR regulatory requirements — including age verification to enforce the 21+ restriction.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal conduct.
• Responsible gaming: To monitor gaming behavior, enforce responsible gaming limits and self-exclusion requests, and identify players who may need support.
• Customer support: To respond to your inquiries, complaints, and support requests.
• Marketing and promotions: To send you relevant promotional offers and updates about kiffywin, where you have provided consent or where we have a legitimate interest to do so. You may opt out at any time.
• Platform improvement: To analyze usage patterns, conduct research, and improve the features, performance, and security of the kiffywin Platform.

Under the Philippine Data Privacy Act of 2012, kiffywin processes your personal data on the following legal bases:

• Consent: Where you have given clear, informed, and freely given consent to the processing of your personal data for a specific purpose, such as receiving marketing communications.
• Contractual necessity: Where processing is necessary to perform our contract with you — specifically, to provide the kiffywin Platform services as described in our Terms & Conditions.
• Legal obligation: Where processing is required to comply with applicable Philippine laws and regulations, including anti-money laundering laws, PAGCOR requirements, and tax obligations.
• Legitimate interests: Where processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights and freedoms.
• Vital interests: In exceptional circumstances, where processing is necessary to protect your vital interests or those of another person.

kiffywin does not sell your personal data. We may share your personal information with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment processors: GCash, PayMaya / Maya, and Philippine banks (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your deposits and withdrawals.
• KYC and identity verification providers: Third-party service providers that assist us in verifying your identity and age in compliance with Philippine regulations.
• Fraud prevention and security partners: Service providers that help us detect and prevent fraudulent activity and protect the integrity of the Platform.
• IT and infrastructure providers: Cloud hosting, data storage, and technical service providers who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine authorities, where required by law or court order.
• Professional advisors: Legal counsel, auditors, and other professional advisors, subject to confidentiality obligations.

All third parties with whom kiffywin shares personal data are required to process such data only for the specified purpose and in accordance with applicable Philippine data privacy laws.

Some of kiffywin's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to recipients in other countries, kiffywin ensures that appropriate safeguards are in place to protect your data, including:

• Contractual clauses that require the recipient to protect your data to a standard equivalent to Philippine law.
• Transfers only to countries or organizations that provide an adequate level of data protection as recognized by the National Privacy Commission.
• Your explicit consent to the transfer, where required.

kiffywin will not transfer your personal data internationally in a manner that undermines your rights under the Philippine Data Privacy Act of 2012.

kiffywin retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. Our general retention periods are as follows:

• Account data: Retained for the duration of your account and for a period of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements.
• KYC and identity documents: Retained for a minimum of five (5) years from the date of collection or the date of the last transaction, whichever is later, as required by the Anti-Money Laundering Act.
• Transaction records: Retained for five (5) years from the date of each transaction.
• Customer support records: Retained for three (3) years from the date of resolution of the relevant inquiry or complaint.
• Marketing consent records: Retained until you withdraw your consent or for three (3) years from the date of last interaction, whichever is earlier.
• Technical and usage logs: Retained for up to twelve (12) months, unless a longer period is required for security or legal purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.

kiffywin implements comprehensive technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Encryption: SSL/TLS encryption for all data in transit; AES-256 encryption for sensitive data at rest.
• Access controls: Role-based access controls ensuring that only authorized personnel can access personal data, on a strict need-to-know basis.
• Two-factor authentication: Available for all kiffywin accounts to protect against unauthorized login.
• Regular security audits: Periodic penetration testing, vulnerability assessments, and security reviews of our systems and infrastructure.
• Staff training: Regular data privacy and security training for all kiffywin personnel who handle personal data.
• Incident response: A documented data breach response procedure, including notification to the National Privacy Commission and affected individuals within the timeframes required by Philippine law.

kiffywin uses cookies and similar tracking technologies to enhance your experience on the Platform, analyze usage patterns, and support security functions. The types of cookies we use include:

• Strictly necessary cookies: Essential for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled.
• Performance and analytics cookies: Used to collect anonymized information about how users interact with the Platform, helping us identify areas for improvement. These are only set with your consent.
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming limits. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the kiffywin Platform. kiffywin does not use cookies to serve third-party advertising.

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

• Right to be informed: The right to be informed about how your personal data is collected and processed, as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data kiffywin holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your kiffywin account settings.
• 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 our legal retention obligations.
• 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 direct marketing purposes or where processing is based on legitimate interests.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 16. We will respond to all verified requests within thirty (30) days, as required by Philippine law.

The kiffywin Platform is strictly intended for individuals aged 21 years and above, in accordance with Philippine law governing casino-style gambling. kiffywin does not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered on the kiffywin Platform, please contact us immediately using the details in Section 16.

The kiffywin Platform may contain links to third-party websites or services, such as payment provider portals. This Privacy Policy applies solely to the kiffywin Platform and does not cover the privacy practices of any third-party websites or services.

kiffywin is not responsible for the privacy practices or content of third-party websites. We encourage you to review the privacy policies of any third-party sites you visit before providing them with your personal information.

kiffywin reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidance. When material changes are made, we will notify registered users via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.

The date of the most recent revision is displayed at the top of this page. Your continued use of the kiffywin Platform following the effective date of any update constitutes your acceptance of the revised Privacy Policy. We recommend reviewing this Policy periodically to stay informed about how we protect your data.

The current version of this Privacy Policy is always available at kiffywin.vip/privacy-policy.

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by kiffywin, please contact our Data Protection Officer:

• Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 via the chat widget on the kiffywin Platform
• Response Time: We aim to respond to all data privacy requests within thirty (30) days as required by Philippine law.

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.