km88a Privacy Policy

km88a is a PAGCOR-regulated online casino and sports betting platform operating at km88a.app and serving Filipino players across the Philippines. In the context of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, km88a acts as the Personal Information Controller (PIC) in respect of all personal data collected from players, visitors, and prospective registrants who interact with our Platform.

As a Personal Information Controller, km88a determines the purposes and means of processing your personal data. Where we engage third-party service providers to process data on our behalf — such as payment processors, KYC verification providers, or cloud hosting partners — those parties act as Personal Information Processors (PIPs) and are contractually bound to process your data only in accordance with our documented instructions and applicable Philippine privacy law.

This Privacy Policy applies to all personal data collected through the km88a website at km88a.app, including all game pages, account management features, customer support channels, and promotional communications. It applies to both registered players and unregistered visitors to the Platform.

km88a collects personal data that is adequate, relevant, and limited to what is necessary for the purposes described in this Policy. The categories of personal data we collect are set out in the table below:

km88a does not intentionally collect sensitive personal information as defined under Section 3(l) of the Data Privacy Act — such as health data, political opinions, or religious beliefs — unless specifically required by PAGCOR's responsible gaming framework (for example, documentation supporting a self-exclusion request on medical grounds).

km88a collects personal data through the following channels and methods:

• Direct submission: Data you provide voluntarily when creating an account, completing KYC verification, requesting a withdrawal, contacting our support team, or responding to a survey or promotion.
• Automated technical collection: Data collected automatically when you visit km88a.app, including IP address, device identifiers, browser configuration, and cookie-based tracking data. This collection occurs whether or not you are a registered player.
• Payment processors: When you deposit or withdraw using GCash, Maya, BPI, BDO, UnionBank, USDT, or Coins.ph, our payment processing partners may share transaction confirmation data and your linked account reference with km88a for reconciliation purposes.
• KYC verification providers: When you submit government-issued identification documents for age and identity verification, our KYC partners process those documents and return a verification result to km88a. The original document images may be retained by our KYC provider subject to their own data retention obligations under Philippine law.
• Third-party game providers: Game session data, including bet amounts, game outcomes, and session timestamps, is generated within our third-party game provider systems and shared with km88a for transaction records and regulatory reporting purposes.

km88a processes your personal data only for the following documented purposes. We do not process your data in any manner incompatible with these stated purposes without prior consent or lawful authority:

• Account creation and management: To register your km88a account, verify your identity and age (21+ requirement), maintain your account profile, and process account closure requests.
• Transaction processing: To process your deposits and withdrawal requests through your nominated payment method, and to maintain accurate financial records of all transactions on your account.
• Regulatory compliance: To fulfil km88a's obligations under PAGCOR licensing conditions, the Philippine Anti-Money Laundering Act (RA 9160 as amended), the Terrorism Financing Prevention and Suppression Act, and NPC data governance requirements. This includes filing Suspicious Transaction Reports (STRs) and Covered Transaction Reports (CTRs) with the Anti-Money Laundering Council (AMLC) where required by law.
• Responsible gaming: To administer deposit limits, self-exclusion requests, reality checks, and other responsible gaming tools activated on your account, and to monitor for indicators of problem gambling behaviour in compliance with PAGCOR's responsible gaming framework.
• Customer support: To respond to your enquiries, resolve disputes, and maintain a record of support communications for quality assurance and regulatory purposes.
• Fraud and security: To detect, investigate, and prevent fraudulent activity, collusion, money laundering, multiple account abuse, unauthorised access, and other prohibited conduct on the Platform.
• Platform improvement: To analyse aggregated usage data, identify performance issues, improve game recommendations, and enhance the overall km88a player experience.
• Marketing communications: To send you promotional offers, bonus notifications, and event announcements by email or SMS — but only where you have provided consent or where km88a has a legitimate interest in communicating with existing registered players. You may opt out of marketing communications at any time.

Under the Philippine Data Privacy Act of 2012, km88a relies on the following lawful bases for processing your personal data:

• Contractual necessity: Processing required to fulfil the km88a Terms and Conditions — which constitute a binding contract between you and km88a — including account registration, deposit processing, game access, and withdrawal handling.
• Legal obligation: Processing required to comply with km88a's obligations under Philippine law, including PAGCOR licensing conditions, the Anti-Money Laundering Act, the Data Privacy Act itself, and lawful orders from competent Philippine courts or government authorities.
• Legitimate interests: Processing carried out for km88a's legitimate business interests, including fraud prevention, security monitoring, platform analytics, and responsible gaming monitoring — where such interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for purposes not covered by the above bases — principally marketing communications and optional data sharing with promotional partners — where you have provided clear, informed, and freely given consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

km88a does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your personal data only in the following circumstances and only to the extent strictly necessary:

• Payment processors: GCash (Mynt), Maya (PayMaya Philippines), BPI, BDO, UnionBank, and other payment partners receive transaction reference data necessary to process your deposits and withdrawals. These entities are independently regulated financial institutions bound by their own privacy and data security obligations under Philippine law.
• KYC and identity verification providers: Third-party KYC providers receive copies of your identity documents and return a verification result. All KYC providers engaged by km88a are contractually bound to process your data solely for identity verification purposes and to comply with the Philippine Data Privacy Act.
• Game content providers: Third-party game studios and live casino operators receive game session data necessary to determine game outcomes and calculate payouts. They do not receive your full identity profile.
• PAGCOR: km88a shares player activity reports, transaction data, and responsible gaming records with PAGCOR as required by our operating licence. This reporting is mandatory and not subject to player objection.
• Anti-Money Laundering Council (AMLC): km88a files STRs and CTRs with AMLC as required under RA 9160 and its amendments. The filing of such reports is a legal obligation and may not be disclosed to the data subject in certain circumstances.
• Law enforcement and courts: km88a will disclose personal data to Philippine law enforcement agencies, the NPC, or competent courts when required to do so by a valid legal order, warrant, or regulatory directive.
• Cloud and IT infrastructure providers: km88a uses reputable cloud hosting and IT service providers to operate the Platform. These providers act as Personal Information Processors under written agreements and have no independent right to use your data.

km88a uses cookies — small text files placed on your device — and similar tracking technologies (such as web beacons, pixel tags, and local storage objects) on km88a.app. These technologies serve the following purposes:

• Essential cookies: Required for the Platform to function correctly. These include session cookies that keep you logged in during your visit, security cookies that help detect fraudulent access attempts, and load-balancing cookies. You cannot opt out of essential cookies without ceasing to use the Platform.
• Functional cookies: Store your preferences such as language settings, game display options, and responsible gaming tool configurations, so these are remembered between sessions.
• Analytics cookies: Help km88a understand how players use the Platform by collecting anonymised data on page views, session durations, click-stream paths, and feature usage. This data is aggregated and does not identify you personally.
• Marketing cookies: Used only with your consent to track the effectiveness of our promotional campaigns. These cookies do not share your data with third-party advertisers.

You can manage your cookie preferences at any time through your browser settings. Most modern browsers allow you to refuse, delete, or receive notification of cookie placement. Note that refusing functional or analytics cookies may affect the quality of your experience on km88a.app but will not prevent you from accessing the core gaming features.

km88a retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. Our standard retention periods are as follows:

When the applicable retention period expires, km88a will securely delete or anonymise your personal data in accordance with NPC-recommended data disposal practices. Anonymised and aggregated data that cannot identify you may be retained indefinitely for statistical analysis purposes.

km88a implements a comprehensive set of technical and organisational security measures designed to protect your personal data from unauthorised access, disclosure, alteration, loss, or destruction. Our security framework includes:

• Encryption in transit: All data transmitted between your browser and km88a.app is encrypted using TLS 1.2 or higher. We enforce HTTPS across the entire Platform with no unencrypted fallback.
• Encryption at rest: Sensitive personal data stored in our databases — including identity documents, financial references, and authentication credentials — is encrypted at the field or database level using AES-256 encryption.
• Access controls: Access to personal data within km88a is restricted on a strict need-to-know basis. All staff with access to personal data undergo privacy and security training and are bound by confidentiality obligations.
• Password security: Player passwords are stored as salted cryptographic hashes using bcrypt. km88a staff cannot view your password in plain text. We strongly recommend enabling two-factor authentication (2FA) on your km88a account.
• Penetration testing and audits: km88a conducts regular third-party security assessments and penetration tests to identify and remediate vulnerabilities in our Platform infrastructure.
• Incident response: km88a maintains a documented personal data breach response plan. In the event of a breach likely to harm your rights and freedoms, we will notify the National Privacy Commission within 72 hours of discovery and notify affected players without undue delay, in accordance with NPC Circular 16-03.

As a data subject under the Philippine Data Privacy Act of 2012, you are entitled to exercise the following rights in relation to your personal data held by km88a:

• Right to be Informed: The right to know that your personal data is being collected and processed, the purposes of processing, and the basis on which it is shared with third parties — all of which are set out in this Policy.
• Right of Access: The right to request a copy of the personal data km88a holds about you, together with information about how it is processed. km88a will provide this within a reasonable timeframe and subject to identity verification.
• Right to Rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you. You can update most profile information directly through your Account Settings page; for KYC-related data, please contact our support team.
• Right to Erasure or Blocking: The right to request that km88a delete or block your personal data where it is no longer necessary for the purposes for which it was collected, where you withdraw consent, or where the data has been unlawfully processed. Note that this right is subject to km88a's mandatory retention obligations under PAGCOR and AML regulations.
• Right to Object: The right to object to processing carried out on the basis of km88a's legitimate interests, including profiling for responsible gaming purposes or analytical processing. km88a will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests.
• Right to Data Portability: The right to receive a copy of your personal data in a structured, commonly used, machine-readable format, and to transmit that data to another personal information controller where technically feasible.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe km88a has violated your rights under the Data Privacy Act. Information on the NPC complaint process is available through official Philippine government channels.

To exercise any of the above rights, please submit your request by email to [email protected] with the subject line "Data Privacy Request." We will acknowledge your request within three (3) business days and respond within the timeframes prescribed by NPC guidelines. Identity verification will be required before any request is processed.

The km88a Platform is not directed at, designed for, or intended to be used by minors under any circumstances. During registration, all applicants are required to provide their date of birth, and this information is cross-verified during the mandatory KYC process against a government-issued Philippine identification document.

If km88a discovers or is notified that it has inadvertently collected personal data from a person under the age of 21, we will:

• Immediately suspend the relevant account;
• Delete all personal data associated with the account to the extent not required for regulatory reporting;
• Notify PAGCOR in accordance with our licensing obligations; and
• Void and withhold any winnings credited to the account, as required by PAGCOR's underage gambling policy.

If you believe a minor has accessed or registered on the km88a Platform, please notify us immediately at [email protected].

Certain km88a service providers — including cloud infrastructure partners, game content providers, and cybersecurity service providers — may be located outside the Philippines. Where your personal data is transferred to a recipient in another country, km88a ensures that adequate safeguards are in place in compliance with Section 21 of the Philippine Data Privacy Act and NPC guidelines on cross-border data transfers.

Safeguards implemented by km88a for cross-border transfers include:

• Contractual clauses in all data processing agreements requiring offshore processors to implement data protection standards equivalent to those required under Philippine law;
• Transfer impact assessments conducted prior to engaging any offshore processor that will handle Philippine player data;
• Preference for processors located in jurisdictions with adequacy decisions recognised by the NPC, where such jurisdictions are available and operationally suitable.

km88a does not transfer your personal data internationally for purposes beyond those described in this Policy, and does not permit offshore processors to use your data for their own commercial purposes.

km88a reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, updates to Philippine privacy law or NPC guidelines, changes in PAGCOR regulatory requirements, or improvements to our platform's privacy framework.

When we make material changes to this Policy — such as adding new categories of data collection, new purposes for processing, or changes to your rights — we will provide advance notice to registered players via email to the address registered on your km88a account, or via a prominent on-platform notification prior to the changes taking effect.

Non-material changes such as typographical corrections, reorganisation of existing content for clarity, or updates to contact information may be made without prior notice. The "Effective Date" at the top of this Policy always reflects when the current version came into force.

Your continued use of km88a.app after the effective date of any revised Policy constitutes your acknowledgment of the changes. If you disagree with any revised Policy, you should cease using the Platform and may request account closure by contacting our support team.

km88a has designated a Data Protection Officer (DPO) in compliance with Section 21(c) of the Philippine Data Privacy Act and NPC Circular 17-01. The DPO is responsible for ensuring km88a's compliance with data privacy obligations and serves as the primary point of contact for data subjects exercising their rights under this Policy.

For all privacy-related enquiries, data subject rights requests, or concerns about how km88a handles your personal data, please contact us using the following details:

• Email: [email protected] — please use the subject line "Data Privacy Request" or "DPO Enquiry" for routing purposes.
• Response time: km88a acknowledges all privacy-related enquiries within three (3) Philippine business days and provides a substantive response within the timeframes prescribed by NPC guidelines.
• Support hours: Our support team is available 24/7 to assist with account-related and privacy-related enquiries.

If you are not satisfied with km88a's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. Information on filing a complaint with the NPC is available through official Philippine government channels.