Privacy Policy – tmt33 Data Protection

1. Introduction

This Privacy Policy ("Policy") is issued by tmt33 ("tmt33," "we," "us," or "our"), the operator of the online gaming platform accessible at tmt33.net ("the Platform"). This Policy describes how tmt33 collects, uses, stores, shares, and protects the personal information of individuals who register for or use the tmt33 Platform ("you" or "Player").

tmt33 is committed to protecting the privacy and personal data of all players, particularly those based in the Philippines. We process personal data in accordance with Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission ("NPC").

By registering a tmt33 account or using any part of the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please do not use the tmt33 Platform.

2. Personal Data We Collect

tmt33 collects personal data from you directly, automatically through your use of the Platform, and from third parties where permitted by law. The categories of personal data we collect include:

2.1 Registration & Identity Data

• Full legal name;
• Date of birth (to verify you are 21 years of age or older);
• Residential address (including city, province, and postal code);
• Email address;
• Mobile phone number;
• Username and encrypted password.

2.2 Identity Verification (KYC) Data

• Government-issued photo identification (e.g., Philippine passport, driver's license, SSS/UMID card, PhilSys National ID);
• Proof of address documents (e.g., utility bill, bank statement);
• Selfie or liveness verification image where required;
• Source of funds documentation where required by anti-money laundering regulations.

2.3 Financial & Transaction Data

• GCash or PayMaya account reference (masked);
• Philippine bank account details (masked) for withdrawal processing;
• Debit card details (masked, last 4 digits only);
• Deposit and withdrawal transaction history;
• Wagering history and game activity records.

2.4 Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session duration, pages visited, and features used;
• Login timestamps and access logs;
• Cookie identifiers and similar tracking data.

2.5 Communications Data

• Records of your communications with tmt33 customer support;
• Feedback, survey responses, and promotional opt-in preferences;
• Responsible gaming tool settings and self-exclusion requests.

3. How We Use Your Personal Data

tmt33 uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and administer your tmt33 account, including processing your registration, verifying your identity, and managing your login credentials;
• Age Verification: To confirm that you are 21 years of age or older, as required by Philippine law and tmt33 policy;
• Payment Processing: To process deposits and withdrawals via GCash, PayMaya, Philippine bank transfer, and debit card;
• Regulatory Compliance: To comply with Philippine gaming regulations, anti-money laundering (AML) obligations, and Know Your Customer (KYC) requirements;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, and other security threats;
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance;
• Responsible Gaming: To administer responsible gaming tools including deposit limits, cooling-off periods, and self-exclusion programs;
• Marketing & Promotions: To send you promotional offers, bonus notifications, and platform updates where you have consented to receive such communications;
• Platform Improvement: To analyze usage patterns, conduct research, and improve the features and performance of the tmt33 Platform;
• Legal Obligations: To comply with court orders, regulatory requests, and other legal obligations applicable to tmt33 under Philippine law.

4. Legal Basis for Processing

Under the Data Privacy Act of 2012, tmt33 processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform our obligations under the Terms and Conditions you agreed to upon registration, including account management and payment processing;
• Legal Obligation: Processing required to comply with Philippine law, including gaming regulations, AML obligations, and tax reporting requirements;
• Legitimate Interests: Processing necessary for tmt33's legitimate business interests, including fraud prevention, platform security, and service improvement, where these interests are not overridden by your rights;
• Consent: Processing based on your freely given, specific, and informed consent, including for marketing communications and optional data collection. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

tmt33 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 only to the extent necessary for the stated purpose:

5.1 Service Providers

tmt33 engages trusted third-party service providers to assist in operating the Platform, including payment processors (GCash, PayMaya, Philippine banks), identity verification providers, cloud hosting providers, and customer support platforms. These providers are contractually bound to process your data only on tmt33's instructions and in accordance with applicable data protection law.

5.2 Regulatory & Law Enforcement Authorities

tmt33 may disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, law enforcement agencies, or courts where required by Philippine law or a valid legal order.

5.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of tmt33's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.

6. Cookies & Tracking Technologies

tmt33 uses cookies and similar technologies (such as web beacons and local storage) on the Platform for the following purposes:

• Essential Cookies: Required for the Platform to function, including maintaining your login session and remembering your preferences. These cannot be disabled without affecting Platform functionality;
• Analytics Cookies: Used to understand how players use the Platform, which pages are most visited, and where technical issues occur. This data is aggregated and anonymized where possible;
• Functional Cookies: Used to remember your language preferences, game settings, and responsible gaming tool configurations.

You can manage or disable non-essential cookies through your browser settings. Note that disabling certain cookies may affect your experience on the tmt33 Platform. tmt33 does not use third-party advertising cookies or cross-site tracking technologies.

7. Data Retention

tmt33 retains your personal data for as long as your account is active and for a period thereafter as required by applicable law. Specific retention periods include:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required by Philippine AML regulations;
• Transaction records: Retained for a minimum of five (5) years in accordance with AMLC reporting obligations;
• Customer support records: Retained for three (3) years from the date of the last interaction;
• Marketing preferences: Retained until you withdraw consent or request deletion;
• Technical logs: Retained for up to twelve (12) months for security and fraud prevention purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with tmt33's data disposal procedures.

8. Data Security

tmt33 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• TLS/SSL encryption for all data in transit between your device and tmt33 servers;
• AES-256 encryption for sensitive data stored at rest, including payment details and identity documents;
• Multi-factor authentication options for player accounts;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Incident response procedures for detecting and responding to data breaches in accordance with NPC notification requirements.

While tmt33 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your tmt33 login credentials and for notifying us immediately if you suspect unauthorized access to your account.

9. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by tmt33:

• Right to be Informed: The right to know what personal data tmt33 collects and how it is used — which this Policy fulfills;
• Right of Access: The right to request a copy of the personal data tmt33 holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data, subject to tmt33's legal retention obligations;
• Right to Object: The right to object to certain types of processing, including direct marketing;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please contact tmt33's Data Protection Officer using the contact details in Section 13. We will respond to verified requests within fifteen (15) business days in accordance with NPC guidelines.

10. Children & Minors

The tmt33 Platform is strictly intended for individuals who are 21 years of age or older. tmt33 does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from an underage individual, we will immediately suspend the associated account, delete the data, and forfeit any associated balances in accordance with our Terms and Conditions.

If you are a parent or guardian and believe that a minor has registered a tmt33 account or provided personal data to us, please contact our support team immediately so we can take appropriate action.

11. Cross-Border Data Transfers

tmt33 primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or processed by service providers located outside the Philippines, such as cloud infrastructure providers or identity verification platforms operating in other jurisdictions.

Where such transfers occur, tmt33 ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses consistent with the requirements of the Data Privacy Act of 2012 and NPC guidelines on cross-border data transfers. tmt33 will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without your explicit consent or a valid legal basis.

12. Updates to This Privacy Policy

tmt33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. The date of the most recent revision is displayed at the top of this page. Where changes are material, tmt33 will notify registered players via email or an in-platform notification prior to the changes taking effect.

Your continued use of the tmt33 Platform following the effective date of any updated Policy constitutes your acceptance of the revised terms. We encourage you to review this Policy periodically to stay informed about how tmt33 protects your personal data.

13. Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by tmt33, please contact our Data Protection Officer (DPO):

If you are not satisfied with tmt33's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. For more information on your rights under the Data Privacy Act of 2012, visit the NPC's official resources.

For responsible gaming support, self-exclusion requests, or problem gambling assistance, please visit our Responsible Gaming page.