Effective Date: March 20, 2026  |  Last Updated: March 20, 2026  |  Applies to: Abot Kamay WiFi captive portal and website

This Privacy Policy describes how Abot Kamay Digital Inc. (AKD) ("we", "us", "our") collects, uses, stores, and protects personal information in connection with the Abot Kamay WiFi service. This policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012, and its Implementing Rules and Regulations.

1. Data Controller

Abot Kamay Digital Inc.
Metro Manila, Philippines
Email: Founder@abotkamay.net

2. What Information We Collect

2.1 WiFi Portal Users

When you connect to an Abot Kamay WiFi network, we collect:

  • Device MAC address — used to authenticate your session and enforce time limits
  • IP address — assigned by the network for routing purposes
  • Session data — connection start/end time, duration, SSID, and access point identifier
  • Ad view data — which advertisement was shown, whether it was completed, and view duration
  • Venue identifier — the physical location where you connected

We do not collect your name, email address, phone number, or any other personally identifying information from WiFi portal users unless you voluntarily provide it.

2.2 Website Visitors

If you fill out a contact form on our website, we collect:

  • Name, email address, company name, and the message content you submit

2.3 Automatically Collected Data

  • Standard web server logs (browser type, referring URL, pages visited)
  • No third-party analytics or tracking cookies are used on this website

3. How We Use Your Information

  • Session authentication — to grant or deny WiFi access based on ad completion
  • Time-limit enforcement — to manage 10-minute free access sessions
  • Ad delivery and verification — to select, display, and verify ad views on behalf of advertisers
  • Aggregate analytics — to report anonymized statistics to venue partners and advertisers (e.g., total sessions, completion rates)
  • Service improvement — to diagnose technical problems and improve system performance
  • Contact handling — to respond to inquiries submitted via our website

We do not sell your personal data to third parties. We do not use your data for behavioral profiling or cross-site tracking.

4. Legal Basis for Processing

We process personal data on the following lawful bases under RA 10173:

  • Consent — By connecting to the WiFi portal and proceeding past the consent screen, you consent to the processing described in this policy
  • Legitimate interests — For network security, fraud prevention, and aggregate analytics that do not override your rights
  • Contractual necessity — To fulfill the WiFi service you requested

5. Data Sharing

We may share data with:

  • Venue partners — Aggregated, anonymized session statistics only (no individual user data)
  • Advertisers — Aggregated ad performance data only (no individual user data)
  • Infrastructure providers — Cloud hosting and database providers operating under data processing agreements
  • Legal authorities — If required by Philippine law, court order, or to protect the rights and safety of users

6. Data Retention

  • Session records — Retained for 90 days, then permanently deleted
  • Ad view records — Retained for 1 year for billing and reporting purposes
  • Contact form submissions — Retained for 1 year, then deleted
  • Aggregated analytics — May be retained indefinitely (contains no personal data)

7. Data Security

We implement industry-standard technical and organizational measures to protect your data:

  • All data in transit is encrypted via TLS/HTTPS
  • Database access is restricted and monitored
  • MAC addresses are stored in hashed form where feasible
  • Access to production systems is limited to authorized personnel
  • Regular backups stored on encrypted off-site storage (Backblaze B2)

8. Your Rights Under RA 10173

As a data subject, you have the right to:

  • Be informed — Know what data we collect and how we use it (this policy)
  • Access — Request a copy of the personal data we hold about you
  • Correction — Request correction of inaccurate data
  • Erasure — Request deletion of your data, subject to legal retention requirements
  • Object — Object to processing based on legitimate interests
  • Data portability — Request your data in a structured, machine-readable format
  • Lodge a complaint — File a complaint with the National Privacy Commission (NPC) at privacy.gov.ph

To exercise any of these rights, contact us at Founder@abotkamay.net. We will respond within 15 business days.

9. Cookies

The Abot Kamay WiFi captive portal uses sessionStorage (not persistent cookies) to maintain your session state during the ad viewing process. This data is cleared when you close the browser tab. Our website does not use tracking or advertising cookies.

10. Children's Privacy

Our service is not directed to children under 13 years of age. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us and we will promptly delete it.

11. Changes to This Policy

We may update this Privacy Policy from time to time. Changes will be posted on this page with an updated effective date. Material changes will be announced via the marquee banner on our website. Continued use of the service after changes constitutes acceptance of the updated policy.

12. Contact

For privacy-related inquiries, data subject requests, or complaints:

Abot Kamay Digital Inc.
Data Privacy Officer
Email: Founder@abotkamay.net
Address: Metro Manila, Philippines

Only public-facing files are listed below. Internal and non-public documents are intentionally excluded.