tm15.ph Privacy Policy

1. Introduction

tm15.ph ("the Platform," "we," "us," or "our") is committed to protecting the privacy and personal data of all individuals who use our services at https://tm15ph.club. This Privacy Policy ("Policy") describes the types of personal information we collect from players and site visitors, the purposes for which that information is used, the conditions under which it may be disclosed, the security measures we employ to protect it, and the rights you hold as a data subject under Philippine law.

By registering an account on tm15.ph or using any feature of the Platform, 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 consent, you must not register an account or continue to use the Platform. This Policy is to be read together with the tm15.ph Terms and Conditions.

2. Data Controller

For the purposes of Republic Act No. 10173 (Data Privacy Act of 2012) and its Implementing Rules and Regulations, tm15.ph is the personal information controller in respect of the personal data of its registered players and site visitors. Questions regarding this Policy or requests to exercise data subject rights may be directed to the tm15.ph Data Protection Officer via the contact details provided in Section 14 of this Policy.

3. Personal Data We Collect

tm15.ph collects the following categories of personal information:

3.1 Registration and Account Data. When you create a tm15.ph account, we collect your full legal name, date of birth, nationality, residential address, mobile number, and username. This information is required to establish your account identity and to comply with PAGCOR KYC requirements.

3.2 Identity Verification Documents. To complete KYC verification before processing withdrawals, we may collect copies of government-issued identification documents (such as a Philippine passport, driver's licence, SSS ID, PhilSys National ID, or similar), proof of address documents, and, where applicable, source of funds documentation.

3.3 Financial Data. We collect transaction records related to deposits, withdrawals, bonuses, and wagers placed on the Platform. We also collect details of the payment methods used (such as GCash mobile number, PayMaya account reference, or bank account details for BPI, BDO, and Metrobank transfers) to the extent necessary to process and verify financial transactions.

3.4 Gaming Activity Data. We maintain records of your gameplay history, including games played, bets placed, outcomes, session duration, and account balance movements. This data is required for regulatory reporting, responsible gaming monitoring, dispute resolution, and fraud prevention purposes.

3.5 Device and Technical Data. When you access tm15.ph, we automatically collect device information including IP address, browser type and version, operating system, screen resolution, and referring URL. This information helps us deliver a consistent experience across the variety of devices used by Filipino players — from Samsung and Realme Android phones to iOS devices and desktop computers.

3.6 Communications Data. We retain records of communications between you and the tm15.ph support team, including live chat transcripts, support ticket content, and email correspondence. This is retained for service quality, training, and dispute resolution purposes.

4. How We Collect Personal Data

We collect personal data through the following means:

• Direct provision: Information you provide when completing the registration form, submitting KYC documents, making deposits or withdrawals, filling in support enquiries, or updating your account profile;
• Automated technical collection: Data collected automatically through your use of the Platform, including via server logs, session identifiers, and cookies (see Section 11);
• Payment processors: Transaction reference data received from GCash, PayMaya, BPI, BDO, Metrobank, and other payment intermediaries when you conduct financial transactions;
• Identity verification services: Data returned from third-party identity verification providers used to authenticate KYC documents submitted by players.

5. Purposes of Processing

tm15.ph processes your personal data for the following purposes:

• Creating and managing your player account;
• Verifying your identity and age (21 years minimum) as required by PAGCOR;
• Processing deposits, withdrawals, and bonus transactions;
• Providing customer support and resolving disputes;
• Complying with PAGCOR regulatory reporting obligations;
• Detecting, investigating, and preventing fraud, money laundering, and prohibited conduct as defined in the Terms and Conditions;
• Monitoring gameplay for responsible gaming purposes and administering player protection tools (deposit limits, self-exclusion, cooling-off periods);
• Complying with obligations under the Anti-Money Laundering Act (RA 9160, as amended) and submitting required reports to the Anti-Money Laundering Council (AMLC);
• Improving Platform functionality, game selection, and user experience based on aggregated and anonymised usage data;
• Sending transactional communications (deposit confirmations, withdrawal notifications, security alerts) to your registered mobile number or email address.

6. Legal Basis for Processing

6.1 Contractual Necessity. The majority of data processing at tm15.ph is necessary for the performance of the contract established by the Terms and Conditions — without processing your registration data, KYC documents, and financial transaction data, we cannot operate your account or provide the services you have requested.

6.2 Legal Obligation. Processing for KYC verification, AML reporting, PAGCOR compliance reporting, and data retention is required by Philippine law and PAGCOR's regulatory framework, independent of contractual consent.

6.3 Legitimate Interest. Processing for fraud prevention, security monitoring, and Platform improvement is conducted on the basis of tm15.ph's legitimate interest in operating a secure and legally compliant gaming platform, subject to your interests and fundamental rights not overriding those interests.

6.4 Consent. Where tm15.ph relies on your consent as the legal basis for processing — for example, for optional marketing communications — you may withdraw that consent at any time by contacting support or updating your communication preferences in your account settings. Withdrawal of consent does not affect the lawfulness of processing that occurred prior to withdrawal.

7. Data Sharing and Disclosure

tm15.ph does not sell your personal data to third parties. We share personal data only in the following circumstances:

• Payment processors: GCash, PayMaya, BPI, BDO, and Metrobank receive the minimum transaction data necessary to process your deposits and withdrawals;
• Game software providers: Licensed game developers and live casino operators may receive your player session data (anonymised where possible) for game integrity and RNG audit purposes;
• Identity verification providers: Third-party KYC service providers receive the identity documents you submit for verification processing;
• PAGCOR: As our regulator, PAGCOR is entitled to access player data and transaction records as required by its regulatory mandate and the terms of tm15.ph's operating licence;
• AMLC and law enforcement: We are legally obligated to file suspicious transaction reports with the Anti-Money Laundering Council and to cooperate with lawful requests from Philippine law enforcement authorities;
• Professional advisers: Legal, accounting, and audit service providers who are bound by professional confidentiality obligations.

All third parties with whom we share personal data are required to process that data in accordance with applicable privacy law and with data processing agreements that reflect the requirements of the Data Privacy Act of 2012.

8. Data Retention

tm15.ph retains personal data for the period necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and KYC records: five (5) years from account closure, as required by PAGCOR and AML regulations;
• Financial transaction records: five (5) years from the date of each transaction;
• Gaming activity logs: three (3) years from the date of each session, unless required longer for ongoing dispute or regulatory investigation;
• Support communications: two (2) years from the date of the last communication in a given support thread.

Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in a manner that prevents re-identification.

9. Security Measures

tm15.ph implements technical and organisational security measures appropriate to the sensitivity of the personal data we hold. These include:

• SSL/TLS encryption on all Platform pages and API endpoints;
• Encryption of sensitive data fields (including identity document images and financial account references) at rest;
• Access controls limiting personal data access to authorised personnel on a need-to-know basis;
• Multi-factor authentication requirements for administrative system access;
• Regular security assessments and vulnerability testing;
• Staff training on data privacy obligations and the requirements of the Data Privacy Act of 2012.

In the event of a personal data breach that is likely to result in harm to affected data subjects, tm15.ph will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, as required by the Data Privacy Act of 2012.

10. Your Rights as a Data Subject

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

• Right to be informed: You have the right to be informed of how your personal data is being processed, as set out in this 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 any inaccurate or incomplete personal data we hold about you;
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to our legal retention obligations;
• Right to object: You may object to processing of your personal data based on legitimate interest, in which case we will assess whether our legitimate interests override your objection;
• Right to data portability: You may request that personal data you have provided to us be transferred to you or to another service in a structured, machine-readable format where technically feasible;
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

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

11. Cookies and Tracking Technologies

tm15.ph uses cookies and similar technologies to operate the Platform, authenticate logged-in sessions, remember your preferences, and collect aggregated analytics on Platform usage. Strictly necessary cookies (required for login session management and security) cannot be disabled. Analytics cookies that help us understand how Filipino players use tm15.ph may be controlled through your browser settings. Disabling analytics cookies will not affect your ability to use the Platform but may result in a less personalised experience.

12. Children and Minors

tm15.ph does not knowingly collect personal data from any individual under the age of twenty-one (21). The Platform is strictly limited to adult players meeting the minimum age requirement. If we become aware that we have inadvertently collected personal data from a person under 21, we will delete that data promptly and close the associated account. Parents or guardians who believe a minor has registered an account on tm15.ph should contact support immediately.

13. Changes to This Privacy Policy

tm15.ph reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or Platform practices. Material changes will be communicated to registered players via in-platform notification or to the email address on file, with at least fourteen (14) days' notice before the updated Policy takes effect. Your continued use of the Platform following the effective date of any updated Policy constitutes your acceptance of the revised terms.

14. Contact and Data Protection Officer

For questions, concerns, or requests relating to this Privacy Policy or your data subject rights, please contact the tm15.ph Data Protection Officer at: [email protected]

You may also submit a complaint or enquiry to the National Privacy Commission of the Philippines at its official offices. Contact details for the NPC are available on the NPC's official Philippine government website.

This Privacy Policy was last reviewed and updated on 1 June 2026. All previous versions are superseded by this document.