Privacy Policy

1. Who We Are

This Privacy Policy is issued by th15 ("th15," "we," "us," or "our"), the operator of the online gaming platform accessible at th15.vip and its associated subdomains and mobile applications (collectively, the "Platform").

th15 is the data controller responsible for the personal data of players and visitors collected through the Platform. We are committed to protecting your privacy and handling your personal data in accordance with the Republic Act No. 10173 (Data Privacy Act of 2012), its Implementing Rules and Regulations, and all applicable regulations issued by the National Privacy Commission (NPC) of the Philippines.

If you have any questions about this Privacy Policy or how th15 handles your personal data, please contact our Data Protection Officer at the details provided in Section 14 of this Policy.

2. Personal Data We Collect

th15 collects the following categories of personal data from players and Platform visitors:

2.1 Registration and Identity Data

• Full legal name
• Date of birth (for age verification — players must be 21 or older)
• Mobile number and email address
• Username and encrypted password
• Nationality and country of residence

2.2 Identity Verification (KYC) Data

• Government-issued photo identification (PhilSys card, passport, driver's license, or equivalent)
• Proof of address documents (utility bill, bank statement, or equivalent)
• Selfie or liveness verification image (where required)
• Proof of payment method ownership

2.3 Financial and Transaction Data

• GCash or Maya account reference (masked)
• Bank account details (masked, for withdrawal processing)
• Deposit and withdrawal history
• Transaction amounts, dates, and reference numbers

2.4 Gaming Activity Data

• Game session history, wager amounts, and outcomes
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, self-exclusion status)

2.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps and login history
• Cookie identifiers and similar tracking data (see Section 7)

2.6 Communications Data

• Records of your communications with th15 customer support
• Feedback, survey responses, and promotional opt-in preferences

3. How We Collect Your Data

th15 collects personal data through the following means:

• Directly from you: When you register an account, complete KYC verification, make deposits or withdrawals, contact customer support, or respond to surveys and promotions.
• Automatically: When you use the Platform, we automatically collect technical and device data through cookies, log files, and similar technologies (see Section 7).
• From third parties: We may receive data from identity verification service providers, payment processors (GCash, Maya, banks), fraud prevention services, and regulatory authorities where required by law.

4. How We Use Your Personal Data

th15 uses your personal data for the following purposes:

• To create and manage your th15 account and verify your identity and age (21+ requirement).
• To process deposits, withdrawals, and other financial transactions via GCash, Maya, and Philippine bank transfers.
• To provide access to games, bonuses, and other Platform features.
• To comply with our legal and regulatory obligations under PAGCOR regulations, the Data Privacy Act, and applicable anti-money laundering (AML) laws.
• To detect, investigate, and prevent fraud, cheating, money laundering, and other prohibited activities.
• To operate and enforce our responsible gaming tools, including deposit limits, loss limits, and self-exclusion.
• To provide customer support and respond to your enquiries and complaints.
• To send you transactional communications (account notifications, deposit confirmations, withdrawal updates).
• To send you promotional communications about th15 offers and events, where you have opted in to receive such communications.
• To analyze Platform usage and improve the th15 user experience for Filipino players.
• To maintain the security and integrity of the Platform.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable laws and regulations, including PAGCOR requirements, AML obligations, and KYC verification mandates.
• Legitimate interests: Processing for fraud prevention, platform security, and improving our services, where these interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

th15 does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We share your data only in the following limited circumstances:

• Payment processors: GCash, Maya, and Philippine banking partners, solely to process your deposits and withdrawals.
• Identity verification providers: Third-party KYC and AML service providers engaged to verify your identity and comply with regulatory requirements.
• Game providers: Game software providers may receive limited session data necessary to deliver game content. These providers are contractually bound to use such data only for game delivery purposes.
• Regulatory authorities: PAGCOR, the National Privacy Commission, and other competent Philippine authorities, where disclosure is required by law or regulatory directive.
• Law enforcement: Where required by a valid court order, subpoena, or other legal process issued by a competent Philippine authority.
• Service providers: Cloud hosting, customer support, and analytics providers engaged by th15 under strict data processing agreements that prohibit independent use of your data.

All third parties with whom th15 shares personal data are required to implement appropriate technical and organizational security measures and to process your data only in accordance with th15's instructions and applicable law.

7. Cookies and Tracking Technologies

th15 uses cookies and similar tracking technologies to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform.

7.1 Types of Cookies We Use

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without breaking core Platform functionality.
• Functional cookies: Remember your preferences such as language settings, responsible gaming limits, and display preferences to provide a more personalized experience.
• Analytics cookies: Help us understand how players use the Platform — which pages are visited most, where players drop off, and how features are used. This data is aggregated and anonymized where possible.
• Marketing cookies: Used to deliver relevant promotional content about th15 to players who have opted in to marketing communications. These are only set with your explicit consent.

7.2 Managing Cookies

You can control and manage cookies through your browser settings. Most browsers allow you to refuse new cookies, delete existing cookies, and set preferences for specific websites. Please note that disabling strictly necessary cookies may prevent you from accessing certain features of the th15 Platform, including account login and payment processing.

For marketing and analytics cookies, you may withdraw your consent at any time by updating your cookie preferences in your th15 account settings or through your browser controls.

8. Data Security

th15 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction:

• Encryption in transit: All data transmitted between your device and the th15 Platform is encrypted using TLS 1.2 or higher (HTTPS).
• Encryption at rest: Sensitive personal data stored on th15 servers is encrypted using AES-256 encryption.
• Access controls: Access to personal data is restricted to th15 personnel and authorized service providers who require it to perform their duties. All access is logged and audited.
• Two-factor authentication: th15 supports and encourages the use of two-factor authentication (2FA) for player accounts to reduce the risk of unauthorized access.
• Regular security assessments: th15 conducts regular vulnerability assessments and penetration testing to identify and remediate security weaknesses.
• Incident response: th15 maintains a data breach response plan. In the event of a personal data breach that poses a risk to your rights and freedoms, th15 will notify the National Privacy Commission and affected players in accordance with the Data Privacy Act's breach notification requirements.

While th15 takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying th15 immediately if you suspect unauthorized access to your account.

9. Data Retention

th15 retains your personal data for as long as necessary to fulfill the purposes described in this Privacy Policy, or as required by applicable law and regulation. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years following account closure, as required by PAGCOR regulations and AML obligations.
• Financial and transaction data: Retained for a minimum of five (5) years from the date of the transaction, in accordance with Philippine financial record-keeping requirements.
• KYC documents: Retained for the duration of your account and for five (5) years following account closure.
• Customer support records: Retained for three (3) years from the date of the last interaction.
• Marketing preferences and consent records: Retained until you withdraw consent or close your account, plus one (1) year for audit purposes.
• Technical and device data (logs): Retained for up to twelve (12) months for security and fraud prevention purposes.

When personal data is no longer required, th15 will securely delete or anonymize it in accordance with our data disposal procedures. Anonymized data that can no longer identify you may be retained indefinitely for statistical and analytical purposes.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by th15:

• Right to be informed: The right to know what personal data th15 collects about you and how it is used — which this Privacy Policy fulfills.
• Right of access: The right to request a copy of the personal data th15 holds about you, along with information about how it is processed.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data. You can update most account information directly through your th15 account settings.
• Right to erasure: 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 our legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format where processing is based on consent or contract.
• Right to withdraw consent: Where processing is based on your consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe th15 has not handled your personal data in accordance with applicable law.

To exercise any of these rights, please contact th15's Data Protection Officer using the contact details in Section 14. th15 will respond to all 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.

Please note that certain rights may be limited where th15 is required to retain or process your data to comply with legal obligations, including PAGCOR regulatory requirements and AML laws.

11. Children's Privacy

The th15 Platform is strictly intended for adults aged 21 years and above. th15 does not knowingly collect personal data from individuals under the age of 21. If th15 discovers or has reasonable grounds to believe that personal data has been collected from a person under 21, th15 will immediately delete that data and close the associated account.

If you are a parent or guardian and believe that your child has registered on the th15 Platform or provided personal data to th15, please contact us immediately at the details provided in Section 14 so that we can take prompt action.

12. International Data Transfers

th15 primarily stores and processes personal data within the Philippines. In some cases, personal data may be transferred to and processed by service providers located outside the Philippines — for example, cloud infrastructure providers or game software vendors operating internationally.

Where personal data is transferred outside the Philippines, th15 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include contractual data processing agreements incorporating standard data protection clauses approved by the National Privacy Commission, or transfers to jurisdictions that have been assessed as providing an adequate level of data protection.

By using the th15 Platform, you acknowledge and consent to the transfer of your personal data as described in this section, subject always to the protections described above.

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 practices, legal obligations, or regulatory requirements. Material changes to this Privacy Policy will be communicated to registered players via email or prominent notice on the Platform at least seven (7) days before the changes take effect.

The "Last Updated" date at the top of this Privacy Policy indicates when the most recent changes were made. We encourage you to review this Privacy Policy periodically to stay informed about how th15 protects your personal data.

Your continued use of the th15 Platform after the effective date of any amendment constitutes your acknowledgment of the updated Privacy Policy. If you do not agree with the changes, you should cease using the Platform and contact us to close your account.

14. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or th15's handling of your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the th15 Platform
• Response Time: Within 15 business days for data subject requests

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with th15's response to your privacy concern. The NPC can be reached through its official government channels.