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 users ("you," "your," or "Player") who access and use the tm15.ph website, mobile interface, and related gaming services (collectively, the "Services").

This Privacy Policy describes how tm15.ph collects, uses, stores, discloses, and protects your personal information in connection with your use of the Platform. It also outlines the rights available to you under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations.

By registering an account, accessing the platform, or using any of our Services, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with this Privacy Policy, please discontinue use of the platform immediately.

2 Data We Collect

tm15.ph collects only the personal data that is necessary to provide our Services, comply with legal obligations, and maintain the security and integrity of the platform. The categories of personal data we collect include:

2.1 Identity & Registration Data

• Full legal name as it appears on your government-issued ID
• Date of birth (used to verify the 21+ age requirement)
• Gender
• Nationality and country of residence
• Government-issued identification number (e.g., PhilSys ID, passport, driver's license)

2.2 Contact Data

• Email address
• Mobile phone number
• Residential address (city, province, postal code)

2.3 Financial Data

• Payment method details (e.g., GCash account reference, PayMaya reference, bank account details for BPI, BDO, Metrobank, or UnionBank)
• Transaction history including deposits, withdrawals, and wagers
• Account balance information

2.4 Technical & Usage Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session duration and login timestamps
• Pages visited and features used within the platform
• Game history and betting activity

2.5 Communications Data

• Records of your communications with tm15.ph customer support
• Feedback, complaints, and survey responses
• Marketing preferences and opt-in/opt-out records

3 How We Collect Your Data

tm15.ph collects your personal data through the following means:

3.1 Directly From You

The majority of personal data we hold is provided directly by you when you register an account, complete identity verification (KYC), make a deposit or withdrawal, contact customer support, or participate in promotions and surveys.

3.2 Automatically

When you access the tm15.ph platform, certain technical data is collected automatically through cookies, web beacons, log files, and similar tracking technologies. This includes your IP address, device identifiers, browser type, and browsing behavior within the platform.

3.3 From Third Parties

We may receive personal data about you from third-party identity verification providers, payment processors, fraud prevention services, and regulatory databases where this is necessary to verify your identity, process payments, or comply with our legal obligations under Philippine law.

4 How We Use Your Data

tm15.ph uses your personal data for the following purposes. We will not use your data for any purpose that is incompatible with the purposes listed below without first obtaining your consent.

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, tm15.ph processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and tm15.ph — specifically, to provide you with access to the platform and gaming services.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering regulations, gaming regulations, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for our legitimate interests in preventing fraud, ensuring platform security, and improving our services, provided these interests are not overridden by your rights and freedoms.
• Consent: For certain processing activities — such as sending you marketing communications or using non-essential cookies — we rely on your freely given, specific, and informed consent. You may withdraw this consent at any time.

6 Data Sharing & Disclosure

tm15.ph does not sell, rent, or trade your personal data to third parties. We may share your personal data only in the following limited circumstances:

6.1 Service Providers

We engage trusted third-party service providers to assist in operating the platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud hosting services, and customer support tools. These providers are contractually bound to process your data only on our instructions and in accordance with applicable privacy laws.

6.2 Regulatory & Law Enforcement Authorities

We may disclose your personal data to Philippine government agencies, regulatory bodies, or law enforcement authorities where required by law, court order, or regulatory directive. This includes disclosures required under the Anti-Money Laundering Act (AMLA) and applicable gaming regulations.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of tm15.ph'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 the applicable privacy terms.

7 Cookies & Tracking Technologies

tm15.ph uses cookies and similar tracking technologies to enhance your experience on the platform, maintain your session, and analyze usage patterns. The types of cookies we use include:

• Essential Cookies: Required for the platform to function correctly. These include session cookies that keep you logged in and security cookies that help protect your account. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings and display options to provide a more personalized experience.
• Analytics Cookies: Help us understand how players use the platform so we can improve performance and user experience. Data collected is aggregated and anonymized where possible.
• Marketing Cookies: Used to deliver relevant promotional content. These are only activated with your consent and can be withdrawn at any time through your browser settings or account preferences.

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.

8 Data Retention

tm15.ph retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in accordance with AML and gaming regulatory requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations.
• Customer support communications: Retained for two (2) years from the date of the last interaction.
• Technical and usage data: Retained for up to twelve (12) months, after which it is anonymized or deleted.
• Marketing preferences: Retained until you withdraw consent or request deletion.

When personal data is no longer required, it is securely deleted or anonymized in accordance with our data disposal procedures.

9 Data Security

tm15.ph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and our servers
• Encryption of sensitive data at rest, including financial information and government ID details
• Role-based access controls ensuring that only authorized personnel can access personal data
• Regular security audits and vulnerability assessments of our platform infrastructure
• Multi-factor authentication options for player accounts
• Continuous monitoring for suspicious activity and potential data breaches
• Staff training on data protection obligations and secure data handling practices

While we take all reasonable steps to protect your data, no method of electronic transmission or storage is completely secure. You also play an important role in keeping your account safe — please use a strong, unique password for your tm15.ph login and never share your credentials with anyone.

10 Your Privacy Rights

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, how it is used, and with whom it is shared.
• Right to Access: You may request a copy of the personal data we hold about you at any time.
• Right to Rectification: If any of your personal data is inaccurate or incomplete, you have the right to request that it be corrected.
• Right to Erasure: You may request the 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 have the right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: If you believe your privacy rights have been violated, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact the tm15.ph Data Protection Officer using the contact details provided in Section 14 of this Policy. We will respond to all verified requests within thirty (30) days.

11 Children's Privacy

The tm15.ph platform is strictly intended for adults aged 21 years and older. We do not knowingly collect, process, or store personal data from individuals under the age of 21. The minimum age requirement is enforced through our registration and identity verification processes.

12 Third-Party Links

The tm15.ph platform may contain links to third-party websites or services for informational or operational purposes. This Privacy Policy applies solely to data processed by tm15.ph and does not cover the privacy practices of any third-party websites or services.

We encourage you to review the privacy policies of any third-party services you access. tm15.ph is not responsible for the privacy practices, content, or security of external websites.

13 Updates to This Policy

tm15.ph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or regulatory requirements. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered players via email or an in-platform notification.

Your continued use of the tm15.ph platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically to stay informed about how we protect your personal data.

14 Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the way tm15.ph handles your personal data, please contact our Data Protection Officer (DPO). We are committed to addressing all privacy-related inquiries promptly and transparently.

Data Protection Officer — tm15.ph
Email: [email protected]

For general support inquiries, you may also reach our customer support team at: [email protected]

We aim to respond to all privacy-related requests within fifteen (15) business days. For complex requests, we may require up to thirty (30) days and will notify you accordingly.