kitayamachu Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") is published by kitayamachu ("Company", "We", "Us", "Our"), the operator of the online gaming platform at kitayamachu.net. The Company is a PAGCOR-licensed operator and operates in full compliance with the Philippine Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and all issuances of the National Privacy Commission ("NPC").

This Policy applies to all personal data collected from individuals who access or use the kitayamachu platform, including registered players, visitors to the website, and individuals who contact kitayamachu's support team. "Personal data" means any information from which you can be directly or indirectly identified as an individual, whether considered in isolation or in combination with other information in our possession.

By registering for a kitayamachu account or using the platform in any capacity, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. Where processing is based on your consent, you retain the right to withdraw that consent at any time, subject to any overriding legal or regulatory obligations that require us to continue processing your data.

2 Legal Basis for Processing

kitayamachu processes your personal data on the following legal bases under the Philippine Data Privacy Act:

• Contractual Necessity: Processing is necessary for the performance of our contract with you — specifically, to create and manage your account, process deposits and withdrawals, and deliver the gaming services you have requested;
• Legal Obligation: Processing is necessary to comply with kitayamachu's legal and regulatory obligations, including PAGCOR licensing conditions, Anti-Money Laundering Act ("AMLA") compliance, Know Your Customer ("KYC") requirements, and mandatory record-keeping obligations;
• Legitimate Interest: Processing is necessary for the pursuit of kitayamachu's legitimate interests, including fraud detection, platform security, responsible gaming enforcement, and service improvement, provided such interests are not overridden by your rights and interests;
• Consent: Where none of the above bases apply, kitayamachu will seek your explicit consent before processing your personal data, including for direct marketing communications where required by law.

3 Data We Collect

kitayamachu collects personal data through your direct interactions with the platform and through automated technical means. The categories of data collected include:

kitayamachu does not collect special categories of personal data (such as health information, political opinions, or religious beliefs) unless specifically required for a regulatory purpose and with your explicit consent. We do not collect data from minors — the platform is restricted to individuals aged 21 and above.

4 How We Use Your Data

kitayamachu uses your personal data for the following specific purposes:

• Account Management: Creating, verifying, and maintaining your kitayamachu account; authenticating your identity on login; processing password resets and account security requests;
• Payment Processing: Processing deposits from and withdrawals to your nominated Philippine e-wallet or bank account; maintaining transaction records as required by law;
• Regulatory Compliance: Fulfilling KYC and anti-money laundering obligations under AMLA and PAGCOR requirements; reporting as required by regulatory authorities; age verification to enforce the 21+ restriction;
• Fraud Prevention & Security: Detecting, investigating, and preventing fraud, cheating, collusive betting, money laundering, and unauthorized account access; monitoring for unusual account activity;
• Responsible Gaming: Monitoring gaming patterns for signs of problem gambling; enforcing deposit limits, self-exclusion arrangements, and cooling-off periods; responding to responsible gaming requests;
• Service Improvement: Analyzing aggregate platform usage data to improve game offerings, platform performance, and user experience;
• Customer Support: Responding to your inquiries, resolving complaints, and providing technical support;
• Direct Marketing: Sending promotional communications about kitayamachu offers, bonuses, and new games — but only where you have not opted out of such communications. You may opt out at any time.

5 Cookies & Tracking Technologies

The kitayamachu website and platform use cookies and similar tracking technologies to deliver a functional and secure user experience. Cookies are small text files placed on your device by your browser when you visit the platform.

• Essential Cookies: Required for the platform to function — including session management, authentication, and security. These cannot be disabled without preventing you from using the platform.
• Analytics Cookies: Used to understand how players navigate the platform, which games are most popular, and where technical issues occur. Data collected through analytics cookies is aggregated and anonymized wherever practicable.
• Preference Cookies: Store your platform preferences such as language settings and display preferences to improve your experience on return visits.

You may control non-essential cookie settings through your browser's privacy or settings panel. Please note that disabling certain cookies may affect your ability to access some features of the kitayamachu platform. kitayamachu does not use third-party advertising cookies or cross-site behavioral tracking cookies for the purpose of targeted advertising on external websites.

6 Data Sharing & Disclosure

kitayamachu does not sell, rent, or trade your personal data to third parties for their own commercial purposes. Your data may be shared in the following limited and controlled circumstances:

• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council ("AMLC"), the National Privacy Commission, and other Philippine government agencies where required by law or regulatory direction;
• Payment Processors: GCash, Maya, BPI, BDO, Metrobank, and other approved payment service providers — solely to the extent necessary to process your transactions;
• KYC & Identity Verification Providers: Third-party identity verification services engaged by kitayamachu to fulfill KYC obligations — bound by strict data processing agreements and prohibited from using your data for any other purpose;
• Game Software Providers: Where game providers operate their own backend systems, limited technical data (such as session tokens and bet values) may be transmitted to those providers to deliver the game — no identifying personal data beyond what is technically necessary is shared;
• Legal & Professional Advisers: Legal counsel, auditors, and compliance consultants engaged by kitayamachu, bound by professional confidentiality obligations;
• Law Enforcement: Philippine law enforcement agencies where kitayamachu is legally compelled to disclose information, or where disclosure is necessary to prevent or investigate criminal activity.

7 Data Retention

kitayamachu retains your personal data only for as long as is necessary for the purposes for which it was collected, or as required by applicable law and PAGCOR regulations. The following general retention periods apply:

• Active Account Data: Retained for the duration of your account's active status plus the applicable post-closure retention period;
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years following the relevant transaction, as required under AMLA and applicable tax regulations;
• KYC Documentation: Identity verification documents are retained for five (5) years following account closure, in compliance with PAGCOR requirements;
• Responsible Gaming Records: Self-exclusion and problem gambling records are retained for the duration of any exclusion period plus five (5) years, to prevent circumvention;
• Support Communications: Customer support records are retained for three (3) years to facilitate follow-up, audit, and dispute resolution.

Upon expiry of the applicable retention period, your personal data will be securely deleted or irreversibly anonymized. Where deletion is not technically feasible (e.g., data held in encrypted backups), the data will be isolated and protected until secure deletion is possible.

8 Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the kitayamachu platform;
• Encryption of stored sensitive data including passwords (hashed and salted using industry-standard cryptographic methods) and financial account details;
• Role-based access controls limiting internal access to personal data to employees who require it for their specific job function;
• Two-factor authentication available for all kitayamachu accounts and mandatory for administrative access;
• Regular third-party security audits and penetration testing as part of PAGCOR compliance;
• Incident response procedures for the detection, reporting, and remediation of personal data breaches, including notification to the National Privacy Commission and affected players in accordance with NPC requirements.

No data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. While kitayamachu takes all commercially reasonable precautions, you acknowledge that your use of the platform is at your own risk in respect of circumstances beyond kitayamachu's reasonable control. You are responsible for maintaining the security of your own account credentials.

9 Your Data Rights

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

• Right to be Informed: The right to be notified of the data processing activities kitayamachu carries out in relation to your personal data — which this Privacy Policy fulfills;
• Right to Access: The right to obtain a copy of the personal data kitayamachu holds about you and information about how that data is being used;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data held by kitayamachu;
• Right to Erasure (Right to be Forgotten): The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to kitayamachu's legal and regulatory retention obligations;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format;
• Right to Object: The right to object to processing of your personal data based on legitimate interest, including direct marketing;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission if you believe kitayamachu has processed your data in violation of the DPA.

To exercise any of these rights, please contact kitayamachu's Data Protection Officer at the contact details provided in Section 13. kitayamachu will respond to verified data subject requests within fifteen (15) working days, extendable by a further fifteen (15) working days where the request is complex or involves multiple requests.

10 Children's Privacy

The kitayamachu platform is strictly restricted to individuals aged 21 years and above. kitayamachu does not knowingly collect or process personal data from individuals under the age of 21. Registration requires identity verification, and accounts found to belong to persons under 21 are immediately closed.

If you believe that a minor has provided personal data to kitayamachu, please contact us immediately at the details in Section 13. kitayamachu will investigate and delete any such data promptly upon verification, and the matter will be reported to PAGCOR as required under our licensing conditions.

11 International Data Transfers

kitayamachu's primary data storage and processing infrastructure is located within the Philippines. In certain cases, personal data may be transferred to or accessed from outside the Philippines — for example, where a game software provider or technology partner operates infrastructure in another country.

Where such international transfers occur, kitayamachu ensures that appropriate safeguards are in place to protect your personal data in accordance with the DPA and NPC standards. These safeguards may include binding contractual clauses, adequacy assessments, or other mechanisms recognized under Philippine data protection law. kitayamachu will not transfer personal data to jurisdictions that do not provide an adequate level of protection without first implementing appropriate safeguards.

12 Amendments to This Policy

kitayamachu reserves the right to update or amend this Privacy Policy at any time. Material changes to this Policy — including changes to the categories of data collected, the purposes for which data is used, or your rights — will be communicated to registered players via their registered mobile number or email address prior to the changes taking effect.

The "Effective" date displayed in the hero section above reflects the date of the most recent revision. We encourage you to review this Policy periodically. Your continued use of the kitayamachu platform following the publication of any amended Policy constitutes your acknowledgment of and agreement to the updated terms.

13 Contact Us & Data Protection Officer

If you have questions, concerns, or requests relating to this Privacy Policy or kitayamachu's handling of your personal data, you may contact us through the following channels. kitayamachu has designated a Data Protection Officer ("DPO") in compliance with NPC requirements:

• Data Protection Officer: kitayamachu DPO
• Email: support at kitayamachu.net (plain text — not a clickable link)
• Live Chat: Available 24/7 through the kitayamachu platform
• Messenger / Viber: 8AM – 11PM Philippine Standard Time (PHT)

If you are not satisfied with kitayamachu's response to your data privacy concern, you may escalate your complaint to the National Privacy Commission of the Philippines through their official channels.