Privacy Policy

1. Introduction and Scope

This Privacy Policy (the "Policy") explains how th15 ("we," "us," "our," or the "Company") collects, uses, discloses, stores, and protects personal information obtained from users ("you," "your," or "Player") of our online gaming platform, website, mobile applications, and related services (collectively, the "Platform" or "Services").

th15 is committed to protecting your privacy and handling your personal data transparently, securely, and in compliance with applicable data protection laws and regulations, including but not limited to the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and other relevant privacy legislation in jurisdictions where we operate.

By accessing, registering an account, or using th15 Services, you acknowledge that you have read, understood, and consent to the data processing practices described in this Privacy Policy. If you do not agree with this Policy, you must discontinue use of our Platform immediately.

2. Information We Collect

th15 collects various categories of personal information to provide, maintain, and improve our Services, ensure regulatory compliance, prevent fraud, and deliver personalized gaming experiences. The information we collect includes:

2.1 Information You Provide Directly

When you register for a th15 account, use our Services, or contact customer support, you voluntarily provide personal information including:

• Account Registration Data: Full legal name, date of birth, gender, residential address, email address, mobile phone number, username, and password.
• Identity Verification Documents: Government-issued identification (passport, driver's license, national ID), proof of address (utility bills, bank statements), and photographs for verification purposes.
• Financial Information: Payment method details including bank account information, e-wallet credentials (GCash, Maya), cryptocurrency wallet addresses, transaction history, and source of funds documentation.
• Communication Data: Contents of your communications with our customer support team via live chat, email, phone, or other channels, including attachments and metadata.
• Marketing Preferences: Your consent choices regarding promotional communications, newsletter subscriptions, and marketing material delivery preferences.
• Responsible Gaming Information: Self-imposed deposit limits, session time limits, self-exclusion requests, and reality check preferences.

2.2 Information Collected Automatically

When you access or use th15 Services, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers, mobile network information, and hardware specifications.
• Connection Data: IP address, geographic location (country, region, city), internet service provider, connection type, and network quality metrics.
• Usage and Activity Data: Pages viewed, features accessed, links clicked, games played, bet amounts, win/loss records, session duration, login timestamps, navigation patterns, and interaction sequences.
• Cookies and Tracking Technologies: Data collected through cookies, web beacons, pixels, local storage, and similar tracking technologies as detailed in Section 8.
• Security and Fraud Prevention Data: Access logs, authentication records, security event logs, fraud detection signals, and behavioral biometric data used to identify irregular or suspicious activity.

2.3 Information from Third Parties

We may receive personal information about you from third-party sources including:

• Payment Processors: Transaction verification data, payment method validation, and fraud screening results from GCash, Maya, banks, and other financial service providers.
• Identity Verification Services: Age verification results, identity authentication confirmations, address validation, and sanctions screening reports from specialized verification providers.
• Analytics and Marketing Partners: Aggregated demographic data, behavioral segments, marketing campaign performance metrics, and attribution data from advertising partners.
• Affiliate and Referral Partners: Referral source information, campaign identifiers, and promotional channel attribution data.
• Public Sources: Information from publicly accessible databases, registries, and government records used for identity verification and compliance purposes.

3. How We Use Your Information

th15 processes your personal information for specific, legitimate purposes necessary to operate our gaming platform and comply with legal obligations. We use your data for the following purposes:

3.1 Service Delivery and Account Management

• Creating, maintaining, and managing your th15 account and user profile.
• Processing deposits, withdrawals, and other financial transactions securely.
• Providing access to games, betting markets, live dealer tables, and other gaming products.
• Processing and settling wagers, calculating winnings, and updating account balances.
• Managing bonuses, promotions, loyalty rewards, and VIP program benefits.
• Responding to customer support inquiries and resolving technical issues.
• Authenticating your identity and authorizing account access.

3.2 Regulatory Compliance and Legal Obligations

• Verifying your age, identity, and eligibility to use online gaming services.
• Complying with anti-money laundering (AML) regulations and know-your-customer (KYC) requirements.
• Maintaining transaction records and audit trails as required by gaming regulations.
• Reporting suspicious transactions or activities to relevant authorities when legally required.
• Responding to lawful requests from law enforcement, regulatory agencies, and courts.
• Enforcing our Terms and Conditions and other legal agreements.

3.3 Security, Fraud Prevention, and Risk Management

• Detecting and preventing fraudulent transactions, account takeovers, and unauthorized access.
• Identifying patterns of bonus abuse, collusion, or other prohibited activities.
• Monitoring for irregular betting patterns that may indicate problem gambling.
• Protecting the security and integrity of our Platform, systems, and databases.
• Conducting security audits, vulnerability assessments, and incident response activities.

3.4 Service Improvement and Personalization

• Analyzing usage patterns to improve Platform functionality, performance, and user experience.
• Personalizing game recommendations based on your preferences and playing history.
• Customizing promotional offers and bonuses tailored to your interests.
• Conducting market research and gathering feedback to enhance our Services.
• Testing new features, games, and services through pilot programs and A/B testing.

3.5 Marketing and Communications

• Sending promotional emails, SMS messages, and push notifications about new games, bonuses, and special offers (with your consent where required by law).
• Delivering targeted advertising on third-party platforms based on your interests and behaviors.
• Informing you about platform updates, policy changes, and important service announcements.
• Conducting customer satisfaction surveys and requesting reviews or testimonials.

3.6 Responsible Gaming and Player Protection

• Implementing and enforcing deposit limits, session time limits, and self-exclusion requests.
• Identifying behaviors that may indicate problem gambling and offering appropriate support resources.
• Preventing underage gambling through robust age verification mechanisms.
• Providing access to responsible gaming tools and educational materials.

4. Legal Basis for Processing

th15 processes your personal information based on the following legal grounds:

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms and Conditions you accepted when registering your account and to provide the Services you requested.
• Legal Obligations: Processing is required to comply with applicable laws and regulations, including gaming licensing requirements, AML/KYC regulations, tax laws, and court orders.
• Legitimate Interests: Processing serves our legitimate business interests in operating a secure, efficient gaming platform, preventing fraud, improving services, and conducting marketing activities, provided these interests are not overridden by your fundamental rights and freedoms.
• Consent: Where required by law, we obtain your explicit consent before processing certain categories of personal data, particularly for marketing communications and non-essential cookies.
• Vital Interests: In rare circumstances, processing may be necessary to protect your vital interests or those of another person, such as preventing self-harm or responding to emergencies.

5. How We Share Your Information

th15 does not sell your personal information to third parties. However, we may share your data with specific categories of recipients for legitimate business purposes:

5.1 Service Providers and Business Partners

We share personal information with trusted third-party service providers who perform functions on our behalf, including:

• Payment Processors: GCash, Maya, banks, and cryptocurrency payment gateways that process deposits and withdrawals.
• Identity Verification Providers: Companies that verify your age, identity, address, and conduct sanctions screening.
• Cloud Hosting and IT Infrastructure: Service providers that host our databases, applications, and technical infrastructure.
• Customer Support Tools: Platforms providing live chat, email management, and customer relationship management systems.
• Analytics and Marketing Services: Companies that help us analyze user behavior, measure marketing effectiveness, and deliver targeted advertising.
• Game Providers: Software companies whose games appear on our Platform, receiving limited information necessary to deliver gaming experiences.

All service providers are contractually obligated to maintain data confidentiality, process information only as instructed, and implement appropriate security measures.

5.2 Legal and Regulatory Authorities

We disclose personal information to law enforcement, regulatory agencies, courts, and government authorities when legally required or necessary to:

• Comply with valid legal requests, subpoenas, court orders, or regulatory inquiries.
• Report suspicious transactions or activities as required by anti-money laundering regulations.
• Cooperate with gaming license compliance audits and regulatory investigations.
• Protect the rights, property, and safety of th15, our users, or the public.

5.3 Business Transfers

If th15 undergoes a merger, acquisition, reorganization, sale of assets, or similar corporate transaction, your personal information may be transferred to the successor entity as part of the transaction, subject to continued protection under this Privacy Policy or an equivalent policy.

5.4 Aggregated and De-identified Data

We may share aggregated, anonymized, or de-identified data that cannot reasonably identify you with business partners, researchers, advertisers, and other third parties for analytics, market research, and industry reporting purposes.

6. Data Security Measures

th15 implements comprehensive technical, administrative, and physical security measures to protect your personal information against unauthorized access, alteration, disclosure, or destruction:

6.1 Technical Security Controls

• Encryption: All data transmissions between your device and our servers use industry-standard SSL/TLS encryption. Sensitive data at rest is encrypted using advanced encryption standards (AES-256).
• Access Controls: Role-based access controls limit employee access to personal information on a need-to-know basis. Multi-factor authentication is required for administrative access.
• Network Security: Firewalls, intrusion detection systems, and continuous monitoring protect our infrastructure from cyber threats.
• Secure Development Practices: Regular security audits, penetration testing, and code reviews identify and remediate vulnerabilities.
• Data Backup and Recovery: Regular encrypted backups ensure data availability and business continuity in case of system failures or disasters.

6.2 Administrative Security Controls

• Employee Training: All staff members undergo mandatory data protection and security awareness training.
• Confidentiality Agreements: Employees and contractors sign non-disclosure agreements protecting customer information.
• Background Checks: Personnel with access to sensitive data undergo background verification.
• Incident Response Plan: We maintain documented procedures for identifying, responding to, and reporting security incidents.

6.3 Physical Security Controls

• Data centers housing our servers implement restricted access controls, surveillance systems, and environmental protections.
• Physical media containing personal information is securely stored and disposed of through certified destruction methods.

Despite these measures, no system is completely secure. You are responsible for maintaining the confidentiality of your account credentials and notifying us immediately of any unauthorized access or security breaches.

7. Data Retention and Deletion

th15 retains personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements.

Data Category	Retention Period	Retention Basis
Account and Profile Data	Duration of account + 5 years after closure	Regulatory compliance, dispute resolution
Transaction Records	7 years from transaction date	AML/KYC regulations, tax compliance
Identity Verification Documents	5 years after account closure	Regulatory requirements, fraud prevention
Communication Records	3 years from last interaction	Customer service quality, dispute resolution
Marketing Data	Until consent withdrawal + 30 days	Consent management, legal compliance
Usage and Analytics Data	2 years from collection	Service improvement, trend analysis

After the applicable retention period expires, personal information is securely deleted or anonymized. Certain data may be retained longer when required by law, such as records subject to ongoing legal proceedings or regulatory investigations.

8. Cookies and Tracking Technologies

th15 uses cookies, web beacons, pixels, and similar tracking technologies to enhance your experience, analyze Platform usage, and deliver personalized content and advertising. Cookies are small text files stored on your device that allow us to recognize your browser and capture certain information.

8.1 Types of Cookies We Use

• Essential Cookies: Necessary for Platform functionality, including authentication, session management, and security features. These cannot be disabled without impairing core services.
• Performance Cookies: Collect information about how you use our Platform, including pages visited, errors encountered, and performance metrics, helping us improve functionality.
• Functional Cookies: Remember your preferences, settings, and choices (such as language, currency, and game favorites) to provide a personalized experience.
• Targeting/Advertising Cookies: Track your browsing activity across websites to deliver relevant advertisements and measure campaign effectiveness.

8.2 Managing Cookie Preferences

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies or alert you when cookies are being sent. Please note that disabling certain cookies may limit your ability to use specific Platform features. You can manage cookie preferences through your browser settings or our cookie consent tool available on the Platform.

9. Your Privacy Rights and Choices

Depending on your jurisdiction, you may have specific rights regarding your personal information. th15 respects these rights and provides mechanisms for you to exercise them:

9.1 Access and Portability Rights

• Right to Access: You can request a copy of the personal information we hold about you, including details about how it is processed.
• Right to Data Portability: You can request your personal information in a structured, commonly used, machine-readable format for transfer to another service provider.

9.2 Correction and Update Rights

• Right to Rectification: You can correct inaccurate or incomplete personal information through your account settings or by contacting customer support.
• We encourage you to keep your account information up-to-date to ensure accurate service delivery.

9.3 Deletion and Restriction Rights

• Right to Erasure: You can request deletion of your personal information, subject to legal retention obligations and legitimate business needs.
• Right to Restriction: You can request that we limit how we use your personal information in certain circumstances.
• Account closure requests may be subject to identity verification and completion of pending transactions.

9.4 Objection and Consent Withdrawal Rights

• Right to Object: You can object to processing based on legitimate interests, including direct marketing activities.
• Right to Withdraw Consent: Where processing is based on consent, you can withdraw it at any time without affecting the lawfulness of processing before withdrawal.
• You can unsubscribe from marketing emails using the link provided in each message or through your account preferences.

9.5 Automated Decision-Making Rights

You have the right not to be subject to decisions based solely on automated processing, including profiling, that produce legal effects or similarly significantly affect you. th15 uses automated fraud detection and responsible gaming monitoring systems, but significant decisions (such as account suspensions) involve human review.

9.6 How to Exercise Your Rights

To exercise any of these rights, please contact our Data Protection Officer using the contact information in Section 12. We will respond to your request within the timeframe required by applicable law (typically 30 days). We may request additional information to verify your identity before processing certain requests to protect your privacy and security.

10. International Data Transfers

th15 operates globally and may transfer your personal information to countries outside the Philippines for processing and storage. When we transfer data internationally, we implement appropriate safeguards to ensure your information receives adequate protection, including:

• Standard contractual clauses approved by data protection authorities.
• Adequacy decisions recognizing equivalent data protection standards in the recipient country.
• Binding corporate rules and certification mechanisms where applicable.
• Your explicit consent for specific transfers where required by law.

Our primary data processing operations are conducted in secure facilities with robust data protection frameworks. All international transfers comply with applicable data protection laws, including the Philippine Data Privacy Act of 2012.

11. Children's Privacy

th15 Services are strictly intended for individuals aged 21 years or older, in compliance with Philippine gambling regulations. We do not knowingly collect, use, or disclose personal information from individuals under the age of 21.

If we discover that we have inadvertently collected personal information from a minor, we will take immediate steps to delete such information from our systems and terminate the associated account. Parents or guardians who believe their child has provided personal information to th15 should contact us immediately using the details in Section 12.

We implement age verification mechanisms during registration and may request additional documentation to confirm age eligibility. Attempting to circumvent age verification or providing false age information violates our Terms and Conditions and may result in account termination and reporting to relevant authorities.

12. Changes to This Privacy Policy

th15 reserves the right to update this Privacy Policy periodically to reflect changes in our data practices, legal requirements, or business operations. Material changes will be communicated through prominent notice on our Platform, email notification to registered users, or other appropriate channels at least 30 days before the changes take effect.

Your continued use of th15 Services after the effective date of any Privacy Policy revision constitutes acceptance of the updated terms. We encourage you to review this Privacy Policy regularly to stay informed about how we protect your information. The "Last Updated" date at the top of this Policy indicates when the most recent changes were made.

13. Contact Information and Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact our dedicated Data Protection Officer:

We aim to respond to all privacy-related inquiries within 5 business days. For account-specific issues or general customer support, please contact our 24/7 support team through the live chat feature on our Platform.

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines or the relevant data protection authority in your jurisdiction.