th15 Casino – Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how th15 ("the Company," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "the Player," or "the Data Subject") who access or use the th15 online gaming platform available at th15.app ("the Platform").

th15 is committed to handling your personal data responsibly, transparently, and in accordance with applicable Philippine law, including the Data Privacy Act of 2012 (RA 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). We also adhere to the data protection requirements applicable to online gaming operators under the regulatory framework of the Philippine Amusement and Gaming Corporation (PAGCOR).

By registering an account on th15, making a deposit, or otherwise using the Platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with this Policy, you must not use the th15 Platform.

This Policy should be read together with th15's Terms & Conditions, which are available at /terms-conditions.

2. Personal Data We Collect

th15 collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected and processed. The categories of personal data we collect include:

3. How We Collect Your Data

th15 collects personal data through the following means:

• Direct Collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions;
• Automated Collection: Technical data collected automatically when you access the Platform, including through cookies, log files, and similar tracking technologies;
• Third-Party Sources: Identity verification data from KYC service providers; fraud prevention data from security partners; payment data from payment processors including GCash, PayMaya, and banking partners;
• Regulatory Sources: Information received from PAGCOR or other regulatory authorities in connection with our compliance obligations.

4. How We Use Your Data

th15 uses your personal data for the following purposes:

5. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, th15 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and th15 — specifically, to operate your player account, process transactions, and deliver gaming services;
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including AML/CTF obligations, PAGCOR licensing requirements, and NPC data protection rules;
• Legitimate Interests: Processing is necessary for th15's legitimate interests in fraud prevention, platform security, and business improvement, provided these interests are not overridden by your rights and interests;
• Consent: For certain processing activities — such as sending marketing communications or using non-essential cookies — th15 relies on your freely given, specific, informed, and unambiguous consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

th15 does not sell or rent your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, for the purpose of processing your deposits and withdrawals;
• KYC & Identity Verification Providers: Third-party identity verification services used to verify your identity and age in compliance with regulatory requirements;
• Fraud Prevention & Security Partners: Service providers that assist th15 in detecting and preventing fraud, money laundering, and other prohibited activities;
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), law enforcement agencies, and other government bodies, where disclosure is required by law or regulatory obligation;
• IT & Infrastructure Providers: Cloud hosting, data storage, and technology service providers that support the operation of the th15 platform, subject to strict data processing agreements;
• Professional Advisers: Lawyers, auditors, and other professional advisers where necessary for legal, compliance, or business purposes.

7. Data Retention

th15 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. The following retention periods generally apply:

• Account Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AML record-keeping requirements;
• Transaction Records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations;
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, or longer if required by regulatory authorities;
• Gaming History: Retained for a minimum of three (3) years for dispute resolution and responsible gaming monitoring purposes;
• Technical & Log Data: Retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with th15's data disposal procedures.

8. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by th15:

To exercise any of your data subject rights, please contact th15's Data Protection Officer using the contact details in Section 14. th15 will respond to all verified data subject requests within fifteen (15) business days. In complex cases, this period may be extended by a further fifteen (15) business days, with prior notice to you.

If you believe th15 has not adequately addressed your data privacy concerns, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

9. Cookies & Tracking Technologies

th15 uses cookies and similar tracking technologies (such as web beacons and pixel tags) to operate and improve the Platform. The following categories of cookies are used:

• Essential Cookies: Strictly necessary for the Platform to function. These include session cookies that maintain your login state and security cookies that protect against fraud. These cannot be disabled.
• Performance Cookies: Used to collect anonymous information about how players use the Platform, such as which pages are visited most frequently. This data helps th15 improve platform performance.
• Functionality Cookies: Used to remember your preferences, such as language settings and display preferences, to provide a more personalized experience.
• Analytics Cookies: Used to analyze player behavior and gaming patterns in aggregate, to improve game offerings and promotional strategies.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the th15 Platform. For more information on managing cookies, refer to your browser's help documentation.

10. Security Measures

th15 implements appropriate 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 th15 Platform;
• Encryption of sensitive data at rest, including financial information and KYC documents;
• Access controls limiting personal data access to authorized personnel on a need-to-know basis;
• Regular security assessments and penetration testing of the Platform;
• Two-factor authentication options for player accounts;
• Secure payment processing through certified payment service providers;
• Staff training on data protection and information security.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, th15 will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with the Data Privacy Act.

11. Minors & Age Restriction

th15 employs age verification measures during the registration process to prevent minors from accessing the Platform. If th15 becomes aware that personal data has been collected from an individual under 21 years of age, that data will be deleted immediately and the associated account will be closed.

If you are a parent or guardian and believe that your child has provided personal data to th15, please contact our Data Protection Officer immediately using the details in Section 14.

12. Third-Party Services

The th15 Platform may contain links to or integrations with third-party services, including payment processors and game providers. This Privacy Policy applies only to the th15 Platform and does not cover the data practices of third-party services. th15 is not responsible for the privacy practices of third parties. We encourage you to review the privacy policies of any third-party services you interact with.

Where th15 engages third-party data processors, we ensure that appropriate data processing agreements are in place that require those processors to handle your personal data in accordance with the Data Privacy Act and this Privacy Policy.

13. Changes to This Privacy Policy

th15 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or regulatory obligations. When material changes are made, th15 will notify registered players via email or through a prominent notice on the Platform. The date of the most recent revision is indicated at the top of this page.

Your continued use of the th15 Platform following the publication of a revised Privacy Policy constitutes your acceptance of the changes. If you do not agree with the revised Policy, you must cease using the Platform and may request account closure in accordance with the Terms & Conditions.

14. Contact & Data Protection Officer

th15 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact: