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Privacy Policy 🔐

This document outlines how KukiMuki collects, stores, and uses your personal information in the course of our business.

We take your privacy seriously and are committed to protecting your personal information.

This Privacy Policy is to be read in conjunction with our Terms and Conditions.

By using our website, opening an account, or placing a bet with us, you agree to this Privacy Policy.

We may amend this Privacy Policy at any time by posting an updated version on our website or apps.

By continuing to use our services after changes are made, you accept the revised Policy.

Last Updated: 05 October 2025

1. Who We Are (Controller)

Metaface Limited (Reg. No. 000048317), Sea Urchin Street, San Pedro Town,

Ambergris Caye, Belize, is the data controller for processing related to

www.kukimuki.com (the “Website”). Remote gaming services on the Website are

operated under Anjouan Licence No. ALSI-202507031-FI2 issued by the competent

authority of the Autonomous Island of Anjouan (Union of the Comoros).

This Policy applies globally. Where the GDPR/UK GDPR applies (e.g., for users in the

EEA/UK), we process personal data in accordance with those laws in addition to applicable

Belize/Anjouan requirements and AML/CTF obligations.

2. Scope and Relationship to Other Terms

This Privacy Policy should be read together with our Terms & Conditions and Cookie

Policy. Translations may be provided for convenience; in case of inconsistency, the

English version prevails. By using the Website, creating an account, or placing a bet

with us, you acknowledge this Privacy Policy.

3. Personal Data We Collect

Depending on your interactions with us, we may collect:

• Identification and contact data: name, date of birth, nationality, address, email,

phone.

• Verification (KYC) data: identity documents (passport/ID/driver’s licence), proof of

address (e.g., utility bill), payment method ownership proofs, selfies/liveness checks.

• Financial and transactional data: deposits, withdrawals, balances, chargebacks,

billing details.

• Gameplay and account data: gameplay history, preferences, responsible gambling

settings, bonus participation, loyalty data.

• Technical data: IP address, device identifiers, browser/OS, access logs, session

telemetry.

• Communications: support tickets, call recordings, emails/chats, feedback and

surveys.

• Marketing data: preferences, consent status, campaign interactions.

• Compliance data: sanctions/PEP screening results, fraud-risk indicators, internal

AML/CTF notes limited to what is necessary.

• Professional data (if provided): profession/job title for B2B or affiliate relations.

4. Sources of Personal Data

• Direct interactions: registration, KYC uploads, gameplay, payments, support.

• Third parties: KYC/AML vendors, sanctions/PEP databases, payment processors

and banks, fraud-prevention networks, affiliates/marketing platforms, public records,

and, where lawful, law-enforcement or regulatory bodies.

• Cookies and similar technologies: as described in our Cookie Policy and

Preference Center.

5. Purposes and Legal Bases (GDPR/UK GDPR)

We process personal data on the following legal bases:

• Contract: create/manage your account; provide games; operate wallets; process

payments; support.

• Legal obligation: KYC/AML/CTF checks; sanctions screening; responsible

gambling obligations; record-keeping; tax and regulatory reporting.

• Legitimate interests: service integrity; fraud prevention; network and information

security; service analytics and improvement; limited direct marketing to existing

customers where permitted.

• Consent: email/SMS/IM marketing where required by law; non-essential cookies

and similar technologies; specific promotions. You may withdraw consent at any time

without affecting the lawfulness of prior processing.

6. Screening (AML/CTF, Sanctions, PEP) and Special Categories

For AML/CTF, sanctions and PEP screening, and fraud prevention, we may check

identifiers against sanctions/PEP/watchlists from reputable vendors and public

sources. We do not intentionally process special categories of data (e.g., health data)

except where you provide such data to use responsible gambling tools; in such

cases, we process only what is necessary to deliver those features.

7. Recipients (Categories of Third Parties)

We share personal data with:

• Payment processors and banks (deposits, withdrawals, chargebacks).

• KYC/AML vendors (identity verification, sanctions/PEP screening, liveness).

• Game providers (gameplay delivery, RNG settlement, dispute investigation).

• IT/security and cloud providers (hosting, monitoring, defence).

• Affiliates/marketing platforms (with consent or as permitted by law).

• Supervisory and law-enforcement authorities where legally required.

• Corporate successors in case of merger, acquisition, or asset sale.

All vendors act under data-processing contracts with confidentiality and security

obligations.

8. International Transfers and Safeguards

Where we transfer personal data outside the EEA/UK, we implement appropriate

safeguards such as EU Standard Contractual Clauses and the UK IDTA/Addendum,

together with supplementary measures (e.g., encryption in transit/at rest, access

controls). Storage and processing locations may vary. A copy or summary of

safeguards is available on request.

9. Retention

We keep personal data no longer than necessary for the purposes collected:

• Account/contract data: account lifetime plus 6 years (claims/defence).

• KYC/AML and transactional data: 5–7 years after the business relationship ends

(legal obligation).

• Marketing data: until opt-out/consent withdrawal; thereafter we retain minimal

suppression data to honour your preference.

After expiry, data is deleted or irreversibly anonymised.

10. Security (Technical and Organisational Measures)

We apply measures appropriate to risk, including encryption in transit/at rest, access

controls, segregation of environments, least-privilege access, security monitoring,

incident response, vendor due diligence, and regular testing. Two-Factor

Authentication (2FA) is available for player accounts and strongly recommended.

11. Cookies and Preference Management

We use cookies and similar technologies. Non-essential cookies (analytics/ads) are

used only with your consent. Manage preferences at any time via our Cookie

Banner/Preference Center. See our Cookie Policy for categories, purposes, retention,

and vendors.

12. Marketing Communications

We send marketing communications only with your consent where required by law

(or under legitimate interests where permitted). You can opt out at any time via

account settings or the unsubscribe link. We maintain a suppression list to ensure

your preference is respected.

13. Automated Decisions and Profiling

We use automated tools to detect fraud/abuse, support AML/CTF screening, provide

responsible gambling features (e.g., affordability indicators, session limits), and

manage bonus eligibility. Where required by law, you may request human review,

express your point of view, and contest a decision.

14. Children

Our services are 18+. We do not knowingly collect data from minors. If we learn that

a minor has provided data, we will delete it and close the account. Parents/guardians

may contact privacy@kukimuki.com.

15. Your Rights (EEA/UK where applicable)

You have the right to access, rectification, erasure, restriction, objection (including to

direct marketing), and data portability; and to withdraw consent at any time. You also

have rights related to automated decision-making, including profiling (see Section

13). To exercise your rights, contact privacy@kukimuki.com. We will respond within

one month (extendable by two months for complex requests).

16. Complaints

You can contact us at privacy@kukimuki.com. If you are in the EEA/UK, you may

also lodge a complaint with your local Data Protection Authority. This is in addition to

any gaming-related complaint routes to the Anjouan Supervisory Authority described

in the Terms & Conditions.

17. Responsible Gambling Data

We may process limited behavioural data (e.g., session duration, spend patterns) to

provide responsible gambling tools (reality checks, limits, self-exclusion) on the basis

of legal obligation and/or legitimate interests, as applicable.

18. Business Transfers

In the event of a merger, acquisition, or asset sale, personal data may be transferred

to the successor, subject to continuity of safeguards and this Policy (or an equivalent

policy providing no lesser protection).

19. Unsolicited Information

If we receive personal data we did not request, we will promptly assess whether it is

necessary. If not, we will delete or anonymise it and record the handling for

accountability.

20. Updates to this Policy

We will post updates with a “Last Updated” date and, for material changes, provide

reasonable advance notice (e.g., on-site notice/email). Your continued use after the

effective date indicates acceptance.

21. Contact

Privacy: privacy@kukimuki.com

Support: support@kukimuki.com

Postal: Metaface Limited, Sea Urchin Street, San Pedro Town, Ambergris Caye, Belize