tmtplay Privacy Policy

tmtplay is committed to protecting the privacy and personal data of every player who uses our platform. This Policy has been prepared in accordance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC).

This Policy applies to all personal data collected through the tmtplay website, mobile platform, customer support channels, and any other service operated under the tmtplay brand. It covers data collected from players based in the Philippines — including those in Metro Manila, Cebu, Davao, Quezon City, Makati, and other regions — as well as any other users who access the platform.

We encourage you to read this Policy in full alongside our Terms and Conditions and Responsible Gaming Policy, both of which form part of the overall agreement between you and tmtplay.

For the purposes of the Data Privacy Act of 2012 and this Policy, tmtplay acts as the Personal Information Controller (PIC) in respect of the personal data it collects and processes through the tmtplay platform.

As the Personal Information Controller, tmtplay determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable Philippine data protection law.

Where tmtplay engages third-party service providers to process personal data on its behalf — such as payment processors, identity verification providers, or analytics platforms — those providers act as Personal Information Processors (PIPs) and are contractually bound to process your data only in accordance with tmtplay's instructions and applicable law.

tmtplay collects the following categories of personal data from players and platform visitors. We only collect data that is necessary for the purposes described in this Policy.

tmtplay collects personal data through the following channels and methods:

• Direct Registration: When you create a tmtplay account, you provide identity and contact data directly through the registration form.
• KYC Verification: When you submit identity verification documents as part of the Know Your Customer process, we collect and store copies of those documents.
• Deposits and Withdrawals: When you make a deposit or request a withdrawal, financial data is collected through our integrated payment processing partners, including GCash, PayMaya, BPI, BDO, and Metrobank.
• Platform Usage: As you use the tmtplay platform — browsing games, placing wagers, logging in — technical and usage data is automatically collected through server logs, cookies, and similar tracking technologies.
• Customer Support: When you contact tmtplay support via live chat or email, the content of those communications is recorded and stored.
• Third-Party Sources: In limited circumstances, tmtplay may receive data about you from third-party identity verification providers, fraud prevention services, or payment processors as part of our compliance obligations.

tmtplay uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your tmtplay player account, including processing your registration and verifying your identity.
• Age Verification: To confirm that you are at least 21 years of age, as required under Philippine gaming regulations. tmtplay does not permit access to real-money gaming by persons under 21.
• Payment Processing: To process deposits and withdrawals through your chosen payment method, including GCash, PayMaya, and Philippine bank transfers.
• Regulatory Compliance: To fulfill our obligations under applicable Philippine law, including anti-money laundering (AML) requirements, Know Your Customer (KYC) obligations, and reporting requirements to relevant regulatory authorities.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats to the tmtplay platform.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling and to administer responsible gaming tools such as deposit limits, loss limits, and self-exclusion requests.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance.
• Platform Improvement: To analyze usage patterns and player behavior in aggregate to improve the tmtplay platform, fix bugs, and develop new features.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided your consent to receive such communications. You may withdraw this consent at any time.
• Legal Proceedings: To establish, exercise, or defend legal claims in the event of a dispute.

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

• Contractual Necessity: Processing is necessary to perform the contract between you and tmtplay — specifically, to operate your player account, process transactions, and deliver the gaming services you have requested.
• Legal Obligation: Processing is necessary to comply with tmtplay's legal obligations under Philippine law, including AML regulations, KYC requirements, and gaming regulatory obligations.
• Legitimate Interests: Processing is necessary for tmtplay's legitimate interests in operating a secure, fair, and commercially viable gaming platform — including fraud prevention, platform security, and responsible gaming monitoring — provided those interests are not overridden by your rights and interests.
• Consent: For certain processing activities — particularly direct marketing communications — tmtplay relies on your freely given, specific, and informed consent. You have the right to withdraw this consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

tmtplay does not sell, rent, or trade your personal data to third parties for their own marketing purposes. 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: We share financial data with payment service providers — including GCash, PayMaya, BPI, BDO, and Metrobank — to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable financial regulations.
• Identity Verification Providers: We share identity documents and personal data with KYC and identity verification service providers to fulfill our regulatory obligations.
• Fraud Prevention Services: We may share technical and usage data with fraud detection and prevention service providers to protect the integrity of the tmtplay platform.
• Regulatory Authorities: We may disclose personal data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other competent Philippine authorities where required by law or regulatory instruction.
• Legal and Professional Advisors: We may share data with our legal counsel, auditors, and other professional advisors where necessary for the conduct of our business and the defense of legal claims.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of tmtplay's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

The tmtplay platform uses cookies and similar tracking technologies to enhance your experience, maintain session security, and collect usage analytics. The following types of cookies may be used:

• Essential Cookies: These cookies are strictly necessary for the tmtplay platform to function. They enable core features such as user authentication, session management, and security. These cookies cannot be disabled without affecting platform functionality.
• Analytics Cookies: These cookies collect anonymized data about how players use the tmtplay platform — such as which pages are visited most frequently and how long sessions last. This data helps us improve the platform experience.
• Functional Cookies: These cookies remember your preferences — such as your preferred language or display settings — to provide a more personalized experience on tmtplay.
• Security Cookies: These cookies help tmtplay detect and prevent fraudulent activity, unauthorized access attempts, and other security threats.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the tmtplay platform. For more information on managing cookies, refer to your browser's help documentation.

tmtplay retains your personal data for as long as is necessary to fulfill the purposes for which it was collected, subject to the following retention principles:

• Active Accounts: Personal data associated with an active tmtplay account is retained for the duration of the account's existence and for a period of at least five (5) years following account closure, in accordance with applicable AML and gaming regulatory requirements.
• Transaction Records: Financial transaction records, including deposit and withdrawal history, are retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• KYC Documents: Identity verification documents are retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Support Communications: Customer support records are retained for a period of three (3) years from the date of the relevant interaction.
• Marketing Data: Where you have consented to receive marketing communications, your contact details are retained for this purpose until you withdraw your consent or request deletion.

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

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

• SSL/TLS Encryption: All data transmitted between your device and the tmtplay platform is encrypted using industry-standard SSL/TLS protocols.
• Encrypted Storage: Sensitive personal data — including passwords and financial information — is stored in encrypted form using strong cryptographic algorithms.
• Access Controls: Access to personal data within tmtplay's systems is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations.
• Regular Security Audits: tmtplay conducts regular security assessments and penetration testing to identify and remediate vulnerabilities in our systems.
• Incident Response: tmtplay maintains a documented data breach response procedure. In the event of a breach affecting your personal data, we will notify you and the National Privacy Commission within the timeframes required by law.

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by tmtplay:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, used, and processed. This Privacy Policy fulfills that obligation.
• Right of Access: You have the right to request a copy of the personal data tmtplay holds about you, along with information about how it is being processed.
• Right to Rectification: You have the right to request correction of any inaccurate or incomplete personal data we hold about you. You can update basic account information directly through your tmtplay account settings.
• Right to Erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to tmtplay's legal retention obligations.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to tmtplay's overriding legitimate grounds.
• Right to Data Portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that tmtplay has processed your personal data in violation of the Data Privacy Act of 2012.

To exercise any of the above rights, please contact the tmtplay Data Protection Officer at [email protected]. We will respond to all verified requests within thirty (30) days of receipt, in accordance with NPC guidelines.

The tmtplay platform is strictly intended for adults aged 21 years and older. tmtplay does not knowingly collect personal data from persons under the age of 21. This restriction is consistent with Philippine gaming regulations, which prohibit participation in casino-style gaming by persons under 21 years of age.

If tmtplay becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. Any funds held in such an account will be handled in accordance with applicable regulatory requirements.

If you are a parent or guardian and believe that your child under the age of 21 has registered on the tmtplay platform, please contact our support team immediately so that we can take appropriate action.

The tmtplay platform may contain references to third-party services — such as payment providers like GCash and PayMaya — whose own privacy policies govern the collection and use of your data when you interact with those services directly.

tmtplay is not responsible for the privacy practices of third-party services. When you interact with a third-party payment provider or any other external service in connection with your tmtplay account, we encourage you to review that provider's privacy policy to understand how your data is handled.

This Policy applies solely to data collected and processed by tmtplay through the tmtplay platform. It does not extend to any third-party websites, applications, or services that may be referenced in connection with the tmtplay platform.

tmtplay reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The most current version of this Policy will always be available on this page, with the "Last Updated" date at the top reflecting the date of the most recent revision.

Where changes to this Policy are material — meaning they significantly affect your rights or the way we process your personal data — tmtplay will make reasonable efforts to notify registered players in advance of the changes taking effect, using the contact details associated with your account.

Your continued use of the tmtplay platform after any update to this Policy constitutes your acknowledgment of the revised Policy. If you do not agree with any updated terms, you should cease using the platform and may request account closure in accordance with our Terms and Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way tmtplay handles your personal data, please contact us through the following channels:

• Data Protection Officer Email: [email protected]
• General Support Email: [email protected]
• Live Chat: Available 24/7 through the tmtplay website
• Response Time: We aim to respond to all data privacy requests within 30 days of receipt

If you are not satisfied with our response to your data privacy inquiry, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the competent supervisory authority for data protection matters in the Philippines.