tm15ph Privacy Policy

1 Introduction

tm15ph ("we," "us," "our," or "the Company") is committed to protecting the privacy and personal data of all players and visitors who use the tm15ph platform. This Privacy Policy has been prepared in accordance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, its Implementing Rules and Regulations, and applicable PAGCOR regulatory requirements.

This Privacy Policy applies to all personal data collected through the tm15ph website at tm15ph.app, including all games, account features, customer support interactions, promotional activities, and payment processing services. It covers data collected both online and, where applicable, through any offline interactions with tm15ph.

We encourage you to read this Privacy Policy carefully and in full. If you have any questions about how we handle your personal data, please contact us using the details provided in Section 15.

2 Data Controller

For the purposes of applicable Philippine data protection law, tm15ph is the data controller responsible for the personal data collected through the tm15ph platform. As data controller, tm15ph determines the purposes and means of processing your personal data and is accountable for ensuring that such processing is carried out lawfully, fairly, and transparently.

tm15ph has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Privacy Policy and applicable data protection laws. You may contact the DPO directly using the contact details provided in Section 15 of this Privacy Policy.

3 Data We Collect

tm15ph collects the following categories of personal data from players and platform visitors:

3.1 Identity and Contact Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify the 21+ age requirement);
• Nationality and country of residence;
• Residential address, including barangay, city or municipality, and province;
• Valid email address;
• Philippine mobile number.

3.2 Account and Authentication Data

• tm15ph username and encrypted password;
• Security questions and answers (where applicable);
• Account registration date and history of account changes.

3.3 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine passport, driver's license, SSS/UMID card, PhilSys National ID);
• Proof of address documents (e.g., utility bills, bank statements);
• Proof of payment method ownership;
• Selfie or facial verification images where required for enhanced KYC.

3.4 Financial and Transaction Data

• Deposit and withdrawal transaction records, including amounts in Philippine Peso (PHP), timestamps, and payment method references;
• GCash, PayMaya, BPI, BDO, Metrobank, or UnionBank account references (partial identifiers only — we do not store full bank account numbers);
• Bonus and promotional credit history;
• Account balance history.

3.5 Gaming and Betting Data

• Game session records, including games played, bet amounts, outcomes, and session duration;
• Sports betting selections, odds accepted, and settlement records;
• Responsible gaming tool settings (deposit limits, loss limits, self-exclusion status).

3.6 Technical and Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Pages visited, features used, and time spent on the platform;
• Referring URLs and search terms used to find the tm15ph platform;
• Cookie identifiers and session tokens.

3.7 Communications Data

• Records of customer support interactions via live chat or email;
• Feedback, complaints, and dispute records;
• Marketing communication preferences and opt-in/opt-out records.

4 How We Collect Your Data

tm15ph collects personal data through the following means:

• Direct collection: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated collection: Technical and usage data collected automatically through cookies, web beacons, and similar tracking technologies when you access the tm15ph platform;
• Third-party sources: Identity verification data from KYC service providers; fraud detection signals from payment processors; and, where applicable, data from PAGCOR or other regulatory bodies for compliance purposes;
• Inferred data: Behavioral and preference data derived from your activity on the platform, such as your preferred game categories or typical session times.

5 How We Use Your Data

tm15ph uses your personal data for the following purposes:

tm15ph will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

6 Legal Basis for Processing

tm15ph processes your personal data on the following legal bases under the Data Privacy Act of 2012 and applicable regulations:

• Contractual necessity: Processing required to perform our obligations under the Terms and Conditions you agreed to upon registration, including account management, payment processing, and game provision;
• Legal obligation: Processing required to comply with PAGCOR regulatory requirements, anti-money laundering (AML) laws, and other applicable Philippine legislation;
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving our services — where such interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications and certain non-essential cookies, where you have provided explicit, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7 Data Sharing and Disclosure

7.1 Service Providers

tm15ph shares personal data with carefully selected third-party service providers who assist in operating the platform. These include KYC and identity verification providers, payment processors (including GCash, PayMaya, and partner banks), game software providers, fraud detection services, and customer support technology providers. All service providers are contractually bound to process your data only on tm15ph's instructions and in accordance with applicable data protection law.

7.2 Regulatory and Legal Disclosure

tm15ph may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), law enforcement agencies, or other government authorities where required by law, court order, or regulatory directive. Such disclosures are made only to the extent strictly necessary to fulfill the relevant legal obligation.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of tm15ph's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material changes to how your data is handled as a result.

7.4 No Sale of Personal Data

tm15ph does not sell, rent, or trade your personal data to third-party advertisers or data brokers under any circumstances. Your information is not a commercial product.

8 Cookies & Tracking Technologies

The tm15ph platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and gather analytics data. The following types of cookies are used:

• Essential cookies: Required for the platform to function correctly, including session management, login authentication, and security features. These cannot be disabled without affecting platform functionality;
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the platform, helping us identify areas for improvement. These are only set with your consent;
• Preference cookies: Used to remember your settings and preferences, such as language and display options;
• Marketing cookies: Used to deliver relevant promotional content based on your interests, only where you have provided consent.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may impair your ability to use certain features of the tm15ph platform, including the ability to log in to your account.

9 Data Security

tm15ph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the tm15ph platform;
• Encryption of sensitive data at rest, including KYC documents and financial records;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication requirements for administrative access to systems holding personal data;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

While tm15ph takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are also responsible for maintaining the security of your tm15ph account credentials and for notifying us immediately if you suspect any unauthorized access.

10 Data Retention

tm15ph retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following retention guidelines:

• Active account data: Retained for the duration of your account's active status plus a minimum of five (5) years following account closure, as required by PAGCOR regulations and AML obligations;
• KYC and identity verification documents: Retained for a minimum of five (5) years from the date of verification or account closure, whichever is later;
• Transaction records: Retained for a minimum of five (5) years in compliance with anti-money laundering reporting requirements;
• Customer support records: Retained for three (3) years from the date of the interaction;
• Marketing preference records: Retained until you withdraw consent or request deletion, plus a reasonable period to demonstrate compliance;
• Technical and usage data: Retained in aggregated, anonymized form for analytics purposes; identifiable technical data is retained for up to 12 months.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with tm15ph's data disposal procedures.

11 Your Data Protection Rights

Under the Data Privacy Act of 2012 and applicable regulations, you have the following rights with respect to your personal data held by tm15ph:

• Right to be informed: The right to be notified of how your personal data is collected, used, and processed — which this Privacy Policy fulfills;
• Right of access: The right to request a copy of the personal data tm15ph holds about you, along with information about how it is being processed;
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your tm15ph account settings;
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to data portability: The right to receive your personal data in a structured, commonly used format and to transmit it to another data controller where technically feasible;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated.

To exercise any of these rights, please contact tm15ph's Data Protection Officer using the contact details in Section 15. We will respond to all verified requests within 15 business days. We may need to verify your identity before processing your request to protect against unauthorized access to your data.

12 Children's Privacy and Age Restrictions

The tm15ph platform is strictly intended for adults aged 21 years and older, in accordance with Philippine gaming regulations. tm15ph does not knowingly collect personal data from individuals under the age of 21.

As part of our registration and KYC process, we verify the age of all players. If tm15ph discovers that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the personal data in question, and return any deposits in accordance with applicable regulations.

If you are a parent or guardian and believe that your child has registered on the tm15ph platform, please contact us immediately using the details in Section 15 so that we can take appropriate action.

13 Marketing Communications

With your consent, tm15ph may send you promotional communications about new games, bonuses, special offers, and platform updates via email or SMS. You may opt in to marketing communications during registration or at any time through your account settings.

You may withdraw your consent to receive marketing communications at any time by:

• Updating your communication preferences in your tm15ph account settings;
• Clicking the "unsubscribe" link included in any marketing email;
• Contacting our customer support team and requesting removal from marketing lists.

Please note that withdrawing consent to marketing communications does not affect your receipt of transactional communications, such as deposit confirmations, withdrawal notifications, account security alerts, and important policy updates, which are sent as part of the tm15ph service.

14 Changes to This Privacy Policy

tm15ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The "Last Updated" date at the top of this page will always reflect the date of the most recent revision.

Where changes are material — meaning they significantly affect your rights or how your personal data is processed — tm15ph will provide advance notice via email to your registered address or via a prominent notice on the platform, with a minimum notice period of 7 days before the changes take effect.

Your continued use of the tm15ph platform after the effective date of any amendment to this Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree with the changes, you may request closure of your account and deletion of your personal data, subject to our legal retention obligations.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by tm15ph, please contact our Data Protection Officer:

• Email: [email protected]
• Subject Line: Please include "Privacy Request" or "Data Protection" in your subject line for faster routing
• Live Chat: Available 24/7 via the tm15ph platform
• Response Time: We aim to acknowledge all privacy-related requests within 3 business days and resolve them within 15 business days