kg36 Privacy Policy

01 Introduction

kg36 ("we," "us," "our") operates an online gaming platform accessible at kg36.app, offering slots, live dealer games, sports betting, bingo, sabong, and related services to players based in the Philippines. In the course of providing these services, kg36 collects and processes certain personal data about the individuals who use the platform ("you," "your," "Player").

This Privacy Policy sets out in clear terms what personal data kg36 collects, the purposes for which it is processed, the legal bases that justify that processing, and the rights that are available to you under Philippine law — in particular, the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations issued by the National Privacy Commission (NPC).

This policy should be read alongside our Terms & Conditions, which govern the broader contractual relationship between you and kg36. In the event of any inconsistency between this Privacy Policy and the Terms & Conditions regarding the processing of personal data, this Privacy Policy shall prevail.

02 Data Controller

For the purposes of the Data Privacy Act of 2012, kg36 acts as the personal information controller in respect of the personal data collected through the kg36 platform. This means kg36 determines the purposes and means of processing your personal information.

Where kg36 engages third-party service providers (such as payment processors, identity verification providers, or game software licensors) to process personal data on its behalf, those parties act as personal information processors and are bound by data processing agreements that require them to process your data only on kg36's instructions and in accordance with applicable Philippine law.

If you have any questions about how kg36 handles your data, or wish to exercise any of your rights under the Data Privacy Act, please contact our Data Protection Officer at [email protected].

03 Data We Collect

The table below summarises the categories of personal data that kg36 collects and the primary purpose of each category:

kg36 does not intentionally collect sensitive personal information (as defined under RA 10173, such as health data, political affiliation, or religious beliefs) unless you voluntarily provide such information in the context of a responsible gaming assessment or support interaction. Where sensitive data is provided in this context, it is used solely for the stated purpose and is subject to heightened security controls.

04 How We Collect Data

kg36 collects personal data through the following channels:

• Account Registration. When you create a kg36 account, you provide identity and contact data directly through the registration form.
• KYC Verification. When you submit identity documents (such as a Philippine passport, driver's licence, or UMID card) to complete account verification, kg36 collects the data contained in those documents.
• Deposits and Withdrawals. Financial data is collected each time you initiate a transaction on the kg36 platform, including the payment method used, amount, and timestamp.
• Platform Usage. Technical and gaming data is collected automatically as you use the kg36 website and games, including through cookies, server logs, and session tracking technologies.
• Customer Support. When you contact kg36 support via email or live chat, we record that interaction and any personal data you include in your message.
• Third-Party Verification Providers. For KYC and fraud prevention purposes, kg36 may receive data about you from third-party identity verification services, subject to those providers' own privacy terms.

05 How We Use Your Data

kg36 processes your personal data for the following purposes:

• Providing and maintaining the platform. To create and manage your account, process your bets and transactions, deliver game content, and ensure the platform operates correctly.
• Identity and age verification. To confirm that you are at least 21 years of age and that the information you have provided is accurate, as required by Philippine gaming regulations.
• Anti-money laundering and fraud prevention. To detect, investigate, and prevent fraudulent activity, money laundering, and other illegal conduct, including cooperation with PAGCOR, the AMLC, and other relevant Philippine authorities where legally required.
• Responsible gaming. To monitor gameplay patterns and identify indicators of problem gambling behaviour, enabling us to apply responsible gaming tools such as deposit limits, session reminders, and self-exclusion where appropriate.
• Customer support. To respond to your queries, resolve disputes, and maintain records of our interactions for quality assurance and legal compliance purposes.
• Communications. To send you transactional communications (account notices, deposit confirmations, withdrawal updates) and, where you have opted in, promotional communications about kg36 offers.
• Platform improvement. To analyse aggregated and anonymised usage data in order to understand how Players interact with kg36 and improve the platform's features, performance, and game selection.
• Legal compliance. To meet our obligations under Philippine law, including the Data Privacy Act, Anti-Money Laundering Act, and applicable gaming regulations.

06 Legal Basis for Processing

Under the Data Privacy Act of 2012, every processing activity must be grounded in a lawful basis. kg36 relies on the following bases:

• Contractual necessity. Processing required to perform the contract between kg36 and you (the Player), including account management, game delivery, and payment processing.
• Legal obligation. Processing required to comply with applicable Philippine laws and regulations, including KYC, AML obligations, and regulatory reporting.
• Legitimate interests. Processing for fraud prevention, platform security, and responsible gaming monitoring where these interests are not overridden by your rights as a data subject.
• Consent. For optional processing activities — such as sending you marketing communications or using non-essential cookies — kg36 relies on your freely given, specific, and informed consent, which you may withdraw at any time.

07 Sharing Your Data

kg36 does not sell, rent, or trade your personal data to third parties for commercial purposes. We share your data only in the following limited circumstances:

• Payment processors. Financial data is shared with our payment service partners (such as GCash, Maya, BPI, BDO, and other accepted providers) solely for the purpose of processing your deposits and withdrawals.
• Identity verification providers. Identity and document data is shared with licensed KYC and AML screening providers to fulfil our regulatory verification obligations.
• Game software licensors. Certain technical and gaming data may be shared with third-party game providers whose titles are hosted on the kg36 platform, solely for the purpose of delivering and auditing game outcomes.
• Regulatory and law enforcement authorities. kg36 may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other Philippine government bodies when legally required to do so or when we reasonably believe disclosure is necessary to protect the rights, property, or safety of kg36 or its Players.
• Professional advisers. Legal counsel, auditors, and other professional advisers who are bound by obligations of confidentiality may receive limited personal data where necessary to provide services to kg36.

Where personal data is shared with third-party processors, kg36 enters into data processing agreements that require those parties to maintain appropriate security standards and process data only on kg36's documented instructions.

08 Data Retention

kg36 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in compliance with anti-money laundering record-keeping requirements under RA 9160.
• Transaction and financial records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with AML and tax record-keeping obligations.
• Gaming history: Retained for a minimum of three (3) years from the date of each session, for dispute resolution and regulatory audit purposes.
• Support communications: Retained for two (2) years from the date of the last interaction, unless retention for a longer period is required in connection with an unresolved dispute or legal claim.
• Marketing consent records: Retained for the duration of your marketing subscription plus one (1) year following unsubscription, as evidence of consent.

When personal data is no longer required and no legal obligation mandates its continued storage, kg36 securely deletes or anonymises it in a manner that prevents recovery or re-identification.

09 Security Measures

kg36 implements a range of technical and organisational measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and kg36 servers;
• Encryption at rest for databases containing personal and financial data;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of platform infrastructure;
• Multi-factor authentication requirements for administrative access to kg36 systems;
• Incident response procedures for detecting, assessing, and notifying the NPC and affected Players in the event of a personal data breach, in accordance with NPC Circular 16-03.

While kg36 takes all reasonable precautions to protect your data, no online system is entirely immune to security risks. You are encouraged to use a strong, unique password for your kg36 account and to enable any available two-factor authentication options.

10 Cookies & Tracking Technologies

kg36 uses cookies and similar tracking technologies (such as web beacons and local storage objects) on the kg36 website. These technologies serve the following purposes:

• Strictly necessary cookies: Required for the platform to function, including session management, login authentication, and security token validation. These cannot be disabled without impairing platform functionality.
• Performance cookies: Collect anonymised data about how Players navigate and interact with the kg36 platform, helping us identify and fix technical issues and improve overall performance.
• Functional cookies: Remember your preferences, such as language settings and display options, to provide a more consistent experience across sessions.
• Analytics cookies: Used to generate aggregated statistical reports about platform usage. kg36 uses this data internally and does not share individual-level analytics data with third parties.

On your first visit to kg36.app, you will be presented with a cookie consent notice. You may withdraw your consent to non-essential cookies at any time by adjusting the cookie settings available in your account preferences or by clearing cookies from your browser. Please note that disabling certain cookies may affect the functionality of the kg36 platform.

11 Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by kg36:

To exercise any of the above rights, please submit a written request to [email protected] with the subject line "Data Subject Rights Request." kg36 will acknowledge your request within five (5) business days and respond substantively within fifteen (15) business days, or within such extended period as permitted under NPC regulations for complex requests.

Please note that certain rights are subject to exceptions. For example, kg36 may decline an erasure request where continued retention of your data is required to comply with a legal obligation or to establish, exercise, or defend a legal claim.

12 Minors & Age Verification

kg36 is strictly an adult gaming platform. In accordance with Philippine law and our own terms of service, all Players must be at least 21 years of age to register and use kg36 services. kg36 does not knowingly collect personal data from individuals under the age of 21.

As part of the account registration and KYC process, kg36 requires all Players to submit valid government-issued identification confirming their date of birth. Accounts where the Player is found to be under 21 will be immediately suspended and all associated funds will be dealt with in accordance with applicable regulations.

If you are a parent or guardian and you believe that a minor has created a kg36 account or provided personal data to kg36 without your consent, please contact us immediately at [email protected] and we will take prompt action to investigate and, where confirmed, delete the relevant data and close the account.

13 Policy Changes

kg36 reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or platform features. When material changes are made, kg36 will publish the revised policy on this page with an updated effective date, and will notify registered Players via email or in-platform notice where reasonably practicable.

Your continued use of the kg36 platform following the publication of a revised Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree with the revised policy, you should discontinue use of the platform and may request account closure in accordance with the Terms & Conditions.

We encourage you to review this Privacy Policy periodically to stay informed about how kg36 is protecting your information.

14 Contact & Complaints

If you have any questions, concerns, or complaints about this Privacy Policy or the way kg36 processes your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: "Privacy / Data Protection Enquiry"
• Support Hours: 8:00 AM – 10:00 PM Philippine Standard Time (PHT), 7 days a week

If you are not satisfied with kg36's response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012. Information about how to file a complaint with the NPC is available on the NPC's official website.

For responsible gaming concerns, self-exclusion requests, or problem gambling support, please visit our Responsible Gaming page or call the NCMH Crisis Hotline at 1553, which is available 24 hours, free of charge within the Philippines.