Privacy Policy —
Your Data, Protected by tm15.ph

This Privacy Policy ("Policy") describes how tm15.ph ("tm15.ph", "Platform", "We", "Us", "Our") collects, uses, stores, shares, and protects the personal data of individuals who visit, register on, or use the services offered through tm15ph.net and any associated subdomains or mobile-optimized versions of the site.

tm15.ph is a PAGCOR-registered online casino and sports betting platform serving players across the Philippines. As a regulated gaming operator, tm15.ph is subject to both the general data privacy requirements of Philippine law and the specific data handling obligations imposed by PAGCOR as a condition of registration.

This Policy is incorporated by reference into the tm15.ph Terms & Conditions, which govern your use of the Platform. By registering an Account or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy applies to all personal data collected by tm15.ph in connection with the operation of the Platform, including data collected from:

• Registered players who hold an active tm15.ph Account;
• Individuals in the process of registering an Account (including abandoned registrations);
• Visitors to tm15ph.net who have not registered but whose browsing data may be collected via cookies and analytics tools;
• Individuals who contact tm15.ph customer support via Live Chat or email;
• Former players whose Accounts have been closed but whose data is retained for regulatory purposes.

This Policy does not apply to the privacy practices of third-party game providers, payment processors, or other third parties whose services are accessible through the Platform. Those parties operate under their own privacy policies, and tm15.ph encourages you to review those policies independently.

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its Implementing Rules and Regulations ("DPA"), tm15.ph acts as the Personal Information Controller (PIC) with respect to personal data collected through the Platform. This means tm15.ph determines the purposes and means by which your personal data is processed.

Where tm15.ph engages third-party service providers to process data on its behalf (for example, payment processors, KYC verification services, or cloud infrastructure providers), those providers act as Personal Information Processors (PIPs) and are bound by data processing agreements that require them to handle your data with equivalent levels of protection.

The categories of personal data collected by tm15.ph depend on your interaction with the Platform. The table below summarizes the main categories:

tm15.ph collects personal data through the following means:

• Directly from you — information you submit through the registration form, KYC verification process, deposit and withdrawal forms, Account settings, and customer support channels;
• Automatically from your device — technical data collected via cookies, web beacons, and server logs when you visit or use the Platform (see Section 10);
• From payment processors — transaction confirmation data received from GCash, Maya, BPI, BDO, Metrobank, and other payment providers when you make a deposit or withdrawal;
• From KYC verification services — identity verification data returned by third-party KYC providers engaged by tm15.ph to verify government-issued IDs;
• From fraud detection services — device fingerprinting and behavioral signals used by tm15.ph's anti-fraud systems to identify suspicious account activity.

Under the Philippine Data Privacy Act, tm15.ph must have a lawful basis for processing your personal data. The following table sets out the primary purposes for which tm15.ph processes your data and the corresponding legal basis:

• Contract performance — processing your registration, managing your Account, processing deposits and withdrawals, and delivering gaming services. Legal basis: performance of a contract to which you are a party.
• Legal and regulatory compliance — KYC identity verification, anti-money laundering (AML) monitoring, PAGCOR reporting, AMLC reporting, and compliance with the Data Privacy Act. Legal basis: compliance with a legal obligation.
• Fraud prevention and platform security — detecting and preventing fraudulent activity, unauthorized account access, bonus abuse, and prohibited conduct. Legal basis: legitimate interests of tm15.ph and protection of other players.
• Responsible gaming — monitoring gaming behavior to identify indicators of problem gambling and applying responsible gaming tools. Legal basis: legal obligation (PAGCOR responsible gaming requirements) and protection of the data subject's vital interests.
• Customer support — resolving complaints, responding to inquiries, and maintaining support records. Legal basis: contract performance and legitimate interests.
• Marketing communications — sending promotional offers, bonus notifications, and platform updates via SMS or email. Legal basis: your consent (which you may withdraw at any time by updating your communication preferences in Account Settings).
• Platform improvement — analyzing aggregated, anonymized usage data to improve the Platform's features, game selection, and user experience. Legal basis: legitimate interests.

tm15.ph is legally required to share certain player data with regulatory authorities including PAGCOR and the Anti-Money Laundering Council (AMLC). Data shared in this context is limited to what is specifically required by applicable regulations and is treated as confidential by the receiving authority.

tm15.ph engages third-party service providers to assist in operating the Platform. These providers process your data solely on tm15.ph's instructions and may not use it for any other purpose. Categories of service providers include:

• Payment processing companies (GCash, Maya, BPI, BDO, and other payment partners);
• Identity verification (KYC) service providers;
• Cloud hosting and data storage providers;
• Anti-fraud and cybersecurity service providers;
• Customer support platform providers;
• SMS and email delivery service providers (for OTPs and account notifications).

All third-party processors are bound by data processing agreements that require compliance with the DPA and equivalent data protection standards.

Third-party game providers (such as Pragmatic Play, PG Soft, JILI, and Evolution Gaming) may receive limited technical data — such as an anonymized player session token — necessary to deliver game content. Game providers do not receive your identity data, financial data, or Philippine mobile number.

tm15.ph may disclose personal data to law enforcement agencies, courts, or other government bodies where required by law, a valid court order, or where tm15.ph reasonably believes disclosure is necessary to prevent crime or protect the safety of individuals.

tm15.ph retains personal data only for as long as is necessary for the purposes described in this Policy or as required by applicable law. The primary retention periods are as follows:

• Active Account data — retained for the duration of the Account and for a period of five (5) years following Account closure, as required for compliance with PAGCOR record-keeping obligations and the Anti-Money Laundering Act;
• Transaction and financial records — retained for a minimum of five (5) years following the date of the transaction, in compliance with RA 9160 (AMLA) requirements;
• KYC documents — retained for five (5) years following Account closure or the date the verification was completed, whichever is later;
• Customer support records — retained for three (3) years from the date of the last interaction;
• Marketing consent records — retained for as long as required to demonstrate consent and for one (1) year following withdrawal of consent;
• Technical and log data — retained for up to twelve (12) months for security monitoring and fraud detection purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be attributed to a specific individual.

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

• TLS 1.3 / 256-bit SSL encryption for all data transmitted between user devices and tm15.ph servers;
• Encrypted data storage for sensitive data fields including passwords (hashed and salted), government ID numbers, and financial identifiers;
• Access controls — internal access to player data is restricted to staff who require it to perform their job function, on a need-to-know basis;
• Multi-factor authentication for internal systems access by tm15.ph employees;
• Regular security audits and penetration testing of Platform infrastructure;
• OTP two-factor authentication for player Account logins from new devices or IP addresses;
• Continuous fraud monitoring to detect and respond to suspicious access patterns in real time.

While tm15.ph employs robust security measures, no digital platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your Account credentials and for notifying tm15.ph promptly if you suspect unauthorized access to your Account.

Cookies are small text files placed on your device by a website when you visit it. They allow the website to recognize your device on subsequent visits and to remember certain information about your session and preferences. tm15.ph uses cookies and similar tracking technologies (such as local storage and session tokens) to operate and improve the Platform.

• Strictly necessary cookies — essential for Platform operation. These include session authentication cookies, security tokens, and load balancing cookies. These cookies cannot be disabled without preventing you from using the Platform.
• Functional cookies — remember your preferences such as language settings, game lobby filters, and responsible gaming settings between sessions.
• Analytics cookies — collect anonymized data about how visitors use the Platform (e.g., most visited game categories, session length, navigation paths). This data is used in aggregate form to improve the Platform.
• Security cookies — used by tm15.ph's fraud detection systems to identify device fingerprints and detect anomalous behavior patterns.

You can control non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies, or to be notified before a cookie is placed. Please note that disabling certain cookies may affect your ability to use some features of the Platform. tm15.ph does not currently serve third-party advertising cookies.

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules, you have the following rights with respect to your personal data held by tm15.ph:

To exercise any of the rights above, please contact our Data Protection Officer via the details provided in Section 16. tm15.ph will respond to all verifiable rights requests within fifteen (15) business days. We may need to verify your identity before processing a request.

tm15.ph does not knowingly collect personal data from individuals under the age of 21. Age confirmation is required during registration, and identity verification (KYC) includes date-of-birth verification against government-issued ID. If tm15.ph discovers or is notified that personal data has been collected from a person under 21 years of age, the relevant Account will be immediately suspended, the data will be deleted to the extent permitted by regulatory requirements, and PAGCOR will be notified in accordance with regulatory obligations.

Parents or guardians who become aware that a minor in their care has registered on tm15.ph are encouraged to contact our support team immediately at [email protected].

Some of tm15.ph's service providers — including cloud infrastructure providers and game server operators — may be located outside the Philippines. Where personal data is transferred to a country that may not have data protection laws equivalent to the Philippine DPA, tm15.ph ensures that adequate safeguards are in place, including:

• Data processing agreements that incorporate standard contractual clauses requiring the recipient to provide DPA-equivalent protections;
• Transfers to jurisdictions that have been assessed as providing adequate data protection standards;
• Where required, prior approval from the National Privacy Commission for cross-border transfers.

In all cross-border transfer scenarios, the data is limited to what is strictly necessary for the service provider to perform their contracted function.

In the event of a personal data breach that is likely to adversely affect the rights and freedoms of data subjects, tm15.ph will:

• Conduct an immediate internal investigation to determine the nature, scope, and impact of the breach;
• Notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, as required under NPC Circular 16-03;
• Notify affected data subjects without undue delay where the breach is likely to result in a high risk to their rights and interests, providing clear information about what data was affected and what steps they should take;
• Implement immediate remedial measures to contain the breach and prevent recurrence.

Notifications to affected players will be sent to the mobile number or email address registered to their tm15.ph Account.

tm15.ph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or PAGCOR regulatory directives. Material changes to this Policy will be communicated to registered players via SMS or email at least seven (7) days prior to the changes taking effect, and a revised Policy will be posted on this page with an updated effective date.

Your continued use of the Platform after the effective date of any revised Policy constitutes acceptance of the updated terms. If you do not agree with changes to this Policy, you may request Account closure in accordance with the Terms & Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by tm15.ph, please contact us through the following channels:

• Live Chat: Available 24/7 directly on the tm15.ph website — the fastest way to reach our team
• Email (General Support & DPO): [email protected]

When contacting us about a data privacy matter, please include your registered username (or registered mobile number) and a clear description of your request. This helps us process your request accurately and within the required timeframe.

If you believe that tm15.ph has not adequately addressed your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC). Information about the NPC complaints process is available on the NPC's official website.