tm15.ph Privacy Policy

1. Introduction

tm15.ph ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all players and visitors who use the tm15.ph website at tm15ph.org and its associated services (collectively, the "Services"). This Privacy Policy describes how we collect, use, store, share, and protect your personal information, and explains the rights available to you under applicable Philippine law.

This Privacy Policy applies to all personal data processed by tm15.ph in connection with your use of the Platform, whether you are a registered player, a visitor browsing the site, or a person who contacts our customer support team. By accessing or using the Services, you acknowledge that you have read and understood this Privacy Policy.

This Policy should be read together with our Terms and Conditions and Responsible Gaming Policy. If you have any questions about how tm15.ph handles your personal data, please contact our Data Protection Officer using the contact details provided in Section 10 of this Policy.

2. Data Controller Information

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, tm15.ph is the personal information controller responsible for the personal data collected through the Platform.

If you have questions, concerns, or requests relating to your personal data, you may contact our Data Protection Officer at: [email protected]

3. Personal Data We Collect

tm15.ph collects personal data that you provide directly to us, data generated through your use of the Platform, and data received from third parties in connection with our legal and regulatory obligations. The categories of personal data we collect include:

3.1 Registration and Account Data

• Full legal name;
• Date of birth (for age verification — you must be 21 or older);
• Email address;
• Mobile number;
• Residential address (including city, province, and postal code);
• Username and encrypted password;
• Government-issued identification details (for KYC verification).

3.2 Financial and Transaction Data

• Deposit and withdrawal transaction records;
• Payment method details (e.g., GCash account reference, bank account details, debit card details — stored in tokenized form only);
• Account balance history;
• Bonus and promotion redemption records.

3.3 Gaming Activity Data

• Game session logs (games played, bets placed, outcomes);
• Wagering history;
• Responsible gaming tool usage (deposit limits set, self-exclusion requests).

3.4 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;
• Cookie identifiers and session tokens.

3.5 Communications Data

• Records of your communications with our customer support team;
• Feedback, survey responses, and complaints submitted to tm15.ph.

4. How We Use Your Personal Data

tm15.ph processes your personal data for the following purposes and on the following legal bases:

5. Sharing Your Personal Data

tm15.ph does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors and e-wallet providers — GCash, Maya, and partner banks, solely to process your deposits and withdrawals;
• Identity verification providers — third-party KYC service providers who assist us in verifying your identity and age in compliance with regulatory requirements;
• Game software providers — licensed game studios whose titles are available on the tm15.ph platform, who may receive anonymized session data for game performance purposes;
• Regulatory and law enforcement authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities, where we are required by law to disclose information;
• IT and infrastructure service providers — cloud hosting, security, and analytics vendors who process data on our behalf under strict data processing agreements;
• Professional advisors — lawyers, auditors, and accountants, subject to professional confidentiality obligations.

All third parties with whom tm15.ph shares personal data are required to handle that data in accordance with applicable Philippine privacy law and our contractual requirements. We do not permit our service providers to use your personal data for their own purposes beyond the specific services they provide to us.

6. Cookies and Tracking Technologies

tm15.ph uses cookies and similar tracking technologies (such as web beacons and local storage) to operate the Platform, remember your preferences, analyze usage patterns, and deliver a personalized experience. The types of cookies we use include:

• Strictly necessary cookies — essential for the Platform to function, including session management and security tokens. These cannot be disabled.
• Functional cookies — remember your preferences such as language settings and display options to improve your experience.
• Analytics cookies — help us understand how players use the Platform so we can improve features and performance. Data collected is aggregated and anonymized where possible.
• Marketing cookies — used to deliver relevant promotional content about tm15.ph to you on the Platform. These are only set with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the tm15.ph platform. For more information on managing cookies in popular browsers, refer to your browser's help documentation.

7. Data Retention

tm15.ph retains your personal data for as long as your account is active and for a period thereafter as required by applicable law and regulation. Specifically:

• Account and transaction records are retained for a minimum of five (5) years following account closure, in compliance with Philippine anti-money laundering regulations;
• KYC and identity verification documents are retained for the period required by PAGCOR regulations and the AMLA;
• Customer support communications are retained for three (3) years;
• Technical and usage logs are retained for up to twelve (12) months, after which they are anonymized or deleted;
• Marketing consent records are retained for the duration of your consent and for a reasonable period thereafter as evidence of that consent.

When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, tm15.ph will securely delete or anonymize that data.

8. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by tm15.ph:

• Right to be informed — you have the right to know what personal data we collect about you and how it is used, which is the purpose of this Privacy Policy;
• Right of access — you may request a copy of the personal data we hold about you;
• Right to rectification — you may request correction of inaccurate or incomplete personal data;
• Right to erasure — you may 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 — you may object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to data portability — you may request a copy of your personal data in a structured, commonly used, machine-readable format;
• Right to lodge a complaint — you have the right to lodge a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected]. We will respond to your request within thirty (30) days as required by the Data Privacy Act. We may need to verify your identity before processing your request.

9. Security Measures

tm15.ph implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the tm15.ph platform;
• Encryption of sensitive data at rest, including payment method details and identity documents;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security assessments and penetration testing of our systems;
• Multi-factor authentication requirements for account access;
• Continuous monitoring for suspicious activity and potential security incidents.

While tm15.ph takes all reasonable steps to protect your personal data, no method of transmission over the internet or electronic storage is completely secure. You are also responsible for keeping your tm15.ph Login credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

10. Changes to This Privacy Policy

tm15.ph may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or platform features. When we make material changes, we will notify registered players by email and post a prominent notice on the Platform prior to the changes taking effect.

The date at the top of this Policy indicates when it was last updated. We encourage you to review this Policy periodically to stay informed about how tm15.ph protects your personal information. Your continued use of the Platform following the posting of an updated Privacy Policy constitutes your acceptance of the changes.

For any questions about this Privacy Policy or our data practices, please contact us at: [email protected]