tmt33 Privacy Policy

In this Privacy Policy, the following terms shall have the meanings assigned below, unless context requires otherwise:

"tmt33", "we", "us", or "our" refers to the operator of the tmt33 Platform at tmt33.club, which is the Personal Information Controller (PIC) responsible for the collection and processing of personal data described in this Policy.

"Platform" means the tmt33 website accessible at tmt33.club, including all associated pages, game interfaces, account management systems, payment gateways, and customer support channels.

"Player" or "Data Subject" refers to any individual who registers a tmt33 account or otherwise provides personal information to tmt33.

"Personal Data" or "Personal Information" means any information from which the identity of an individual can be reasonably and directly ascertained, or when put together with other information, would directly and certainly identify an individual, as defined under the Data Privacy Act of 2012.

"Sensitive Personal Information" means personal information of a particularly private nature, including government-issued identification numbers, financial account details, and any other data classified as sensitive under the Data Privacy Act.

"DPA" means the Data Privacy Act of 2012, Republic Act No. 10173 of the Philippines, together with its Implementing Rules and Regulations (IRR).

"NPC" means the National Privacy Commission of the Philippines, the government body responsible for administering and enforcing the DPA.

"Processing" refers to any operation performed on personal data, whether automated or manual, including collection, recording, organisation, storage, updating, retrieval, consultation, use, disclosure, and destruction.

tmt33 is a PAGCOR-regulated online casino and sports betting platform serving Filipino players across the Philippines. This Privacy Policy applies to all personal data collected and processed by tmt33 in connection with your registration, use of account services, participation in games, use of payment facilities, and interaction with customer support on the tmt33 Platform.

This Policy applies to all registered tmt33 Players regardless of their location within the Philippines — including players in Metro Manila, Cebu, Davao, Pampanga, Iloilo, Cagayan de Oro, and all other provinces and regions. It also applies to casual visitors to tmt33.club who have not registered an account, to the extent that non-account browsing data (such as cookies) is collected.

tmt33 acts as the Personal Information Controller (PIC) for all personal data described in this Policy, as that term is defined under the Data Privacy Act of 2012. Third-party service providers who process data on tmt33's behalf act as Personal Information Processors (PIPs) under written data processing agreements.

tmt33 collects the following categories of personal data from Players, depending on the services used and the stage of the account lifecycle:

tmt33 collects personal data through the following channels and mechanisms:

4.1 Direct Collection from You

The majority of personal data tmt33 holds is provided directly by Players during account registration (name, mobile number, email, date of birth, residential address), KYC identity verification (government ID submission), and during customer support interactions. Players may also provide data by updating their account profile, setting responsible gaming preferences, or participating in promotional programmes.

4.2 Automated Collection During Platform Use

When you access the tmt33 Platform, technical data is automatically collected including your device's IP address, browser type and version, operating system, referring URLs, pages visited, session timestamps, and game interaction logs. This data is collected through server logs, session management systems, and analytics tools operated by tmt33.

4.3 Payment Processing Intermediaries

When you initiate a deposit or withdrawal via GCash, Maya, BPI, BDO, or another approved payment method, tmt33 receives a transaction confirmation reference from the payment provider confirming the amount, transaction status, and a masked identifier for your payment method. tmt33 does not receive or store your full payment account number, OTP codes, or authentication credentials.

4.4 KYC Verification Providers

For identity verification, tmt33 works with accredited third-party KYC service providers who may process the images of your submitted identification documents on tmt33's behalf under a formal data processing agreement. These providers conduct automated and manual verification checks as required under PAGCOR's player onboarding requirements.

4.5 Cookies and Tracking Technologies

tmt33 uses cookies and similar technologies on the Platform as described in Section 10 of this Policy. These technologies may collect technical and usage data automatically when you browse tmt33.club.

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

• Contractual Necessity: Processing required to fulfil the tmt33 service agreement with the Player, including account creation, wallet management, game access, deposit and withdrawal processing, and customer support.
• Legal Obligation: Processing required to comply with tmt33's legal obligations under Philippine law, including PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) compliance, Know-Your-Customer (KYC) regulations, tax reporting obligations, and data breach notification duties.
• Legitimate Interests: Processing carried out for tmt33's legitimate business interests where these interests are not overridden by the Player's rights — including fraud prevention, responsible gaming monitoring, platform security, and service improvement analytics.
• Consent: For certain non-essential processing activities (such as marketing communications and promotional personalisation), tmt33 relies on the Player's explicit consent, which may be withdrawn at any time without affecting the lawfulness of prior processing.

tmt33 uses the personal data collected for the following specific and legitimate purposes:

• Account Management: Creating and maintaining your tmt33 account, verifying your identity during login, managing your Wallet balance, and processing your account preferences and settings.
• KYC & Age Verification: Verifying that you meet the minimum 21-year age requirement mandated by PAGCOR, and fulfilling identity verification obligations required before withdrawal processing.
• Payment Processing: Processing GCash deposits and withdrawals, Maya payments, bank transfers, and other approved transactions. Matching payment reference numbers to your Wallet for crediting purposes.
• Fraud Prevention & AML Compliance: Monitoring transaction patterns for suspicious activity, fulfilling obligations under the Anti-Money Laundering Act, and reporting to PAGCOR and the Anti-Money Laundering Council (AMLC) where required.
• Responsible Gaming: Administering player-set deposit limits, loss limits, and self-exclusion requests; monitoring gaming behaviour for indicators of potential problem gambling; and complying with PAGCOR's responsible gaming requirements.
• Customer Support: Responding to your enquiries, resolving disputes, processing complaints, and maintaining records of support interactions for quality assurance and compliance purposes.
• Platform Security: Detecting and preventing unauthorised access, account takeovers, and technical security incidents; maintaining audit logs for security investigation purposes.
• Service Improvement: Analysing aggregated, anonymised usage data to improve game performance, user interface design, and overall Platform functionality.
• Marketing Communications (with consent): Sending promotional offers, bonus notifications, and platform updates to Players who have consented to receive marketing communications. Players may withdraw this consent at any time.
• Regulatory Reporting: Providing player data to PAGCOR, the NPC, the AMLC, and other competent Philippine authorities where legally required.

tmt33 does not sell or commercially trade Player personal data. tmt33 shares personal data with third parties only in the following defined circumstances:

7.1 Payment Service Providers

Transaction data is shared with GCash (G-Xchange, Inc.), Maya (PayMaya Philippines, Inc.), BPI, BDO, Metrobank, and other payment processors as necessary to execute deposit and withdrawal requests. These providers receive only the transaction data required to process the payment and are not authorised to use such data for any other purpose.

7.2 KYC Verification Providers

Identity document data submitted during KYC verification is processed by accredited third-party verification service providers under data processing agreements consistent with DPA requirements. These providers perform identity and document authenticity checks on tmt33's behalf.

7.3 Regulatory Authorities

tmt33 may disclose Player data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council, the Bureau of Internal Revenue, and other competent Philippine government agencies where disclosure is required by law, court order, or regulatory direction.

7.4 Technology Infrastructure Providers

tmt33 uses reputable cloud infrastructure, hosting, and analytics service providers who may process technical and usage data as part of Platform operations. All such providers are engaged under appropriate data processing agreements.

7.5 Game Software Providers

Third-party game software licensors who provide live casino, slot, or sports betting data feeds to tmt33 may receive limited technical session data necessary for game delivery. These providers do not receive personally identifiable Player data beyond what is technically required for game session management.

tmt33 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following retention guidelines apply:

• Account Data & KYC Records: Retained for the duration of the account relationship and for a minimum of five (5) years after account closure, as required for PAGCOR compliance and Anti-Money Laundering Act record-keeping obligations.
• Transaction Records: Retained for a minimum of five (5) years, consistent with AMLC record-keeping requirements for covered and suspicious transaction reporting.
• Customer Support Records: Support interaction logs are retained for three (3) years from the date of interaction for quality assurance and dispute resolution purposes.
• Technical & Log Data: Server logs and security event records are retained for twelve (12) months from the date of generation, unless a specific retention extension is required for an ongoing security investigation.
• Marketing Data: Marketing consent records and preference data are retained for the duration of the consent plus three (3) years following withdrawal of consent, for compliance demonstration purposes.
• Responsible Gaming Records: Self-exclusion, cooling-off, and limit records are retained for five (5) years from the date of the record's creation, for regulatory compliance and to prevent circumvention of exclusion periods.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that the individual can no longer be identified. Where deletion is not technically feasible (for example, in backup systems), tmt33 will isolate such data from further active processing until deletion is possible.

tmt33 implements appropriate technical and organisational measures to protect Player personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include but are not limited to:

• Transport Encryption: All data transmitted between Players' devices and tmt33's servers is encrypted using TLS (Transport Layer Security), preventing interception in transit.
• At-Rest Encryption: Sensitive personal data and identity documents stored in tmt33's systems are encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. tmt33 employees and contractors who require access to personal data as part of their role are subject to confidentiality obligations and access logging.
• Two-Factor Authentication: Administrative access to tmt33's data systems requires multi-factor authentication. Players are also encouraged to enable 2FA on their accounts for personal data protection.
• Intrusion Detection: tmt33 employs real-time intrusion detection and monitoring systems to identify and respond to security incidents promptly.
• Regular Security Audits: tmt33's security posture is subject to periodic technical audits and penetration testing by independent security specialists.

tmt33 uses cookies and similar technologies on the Platform to deliver a functional and personalised experience. The following types of cookies are used:

10.1 Strictly Necessary Cookies

These cookies are essential for the operation of the tmt33 Platform. They include session management cookies that keep you logged in during an active session, security tokens that protect against CSRF attacks, and cookies that remember your cookie consent preferences. These cookies cannot be disabled without affecting core Platform functionality.

10.2 Performance & Analytics Cookies

These cookies collect anonymised information about how visitors interact with the tmt33 Platform — which pages are visited most frequently, how long Players spend on each section, and where errors occur. This data is used solely to improve the Platform and is not used to identify individual Players.

10.3 Functional Cookies

Functional cookies remember your Platform preferences such as your preferred language, game display settings, and responsible gaming reminder configurations. They allow tmt33 to provide a more personalised experience without requiring you to re-enter preferences on every visit.

You may control cookie preferences through your browser settings. Most modern browsers on Android and iOS devices used by Philippine players (Chrome, Samsung Internet, Safari) allow you to block or delete cookies. Blocking strictly necessary cookies may impair your ability to log in and use the tmt33 Platform.

Under the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by tmt33. These rights may be exercised by submitting a written request to tmt33's designated Data Protection Officer (DPO) via the contact details in Section 14:

• Right to Be Informed: The right to be notified of what personal data is being collected about you, the purpose for processing, and the identity of tmt33 as Personal Information Controller — as set out in this Privacy Policy.
• Right of Access: The right to obtain a copy of your personal data that tmt33 holds, together with information about how it is being processed. Requests will be responded to within 15 business days.
• Right to Rectification: The right to request correction of any inaccurate, incomplete, or outdated personal data. Standard account profile corrections may be made directly in your account settings. Corrections to KYC identity data require supporting documentation.
• Right to Erasure / "Right to Be Forgotten": The right to request deletion of your personal data where it is no longer necessary for the purpose it was collected, where you withdraw consent and no other legal basis exists, or where processing is unlawful. This right is subject to tmt33's retention obligations under PAGCOR and AMLC regulations.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Object: The right to object to processing based on legitimate interests or for direct marketing purposes. Where you object to marketing, tmt33 will cease processing your data for that purpose immediately.
• Right to Complain: The right to lodge a complaint with the National Privacy Commission if you believe tmt33 has processed your personal data in violation of the DPA. The NPC's contact details are available on the NPC's official government website.

The tmt33 Platform is strictly restricted to individuals who are at least twenty-one (21) years of age, consistent with PAGCOR's minimum age requirement for online casino and sports betting in the Philippines. tmt33 does not knowingly collect personal data from individuals under the age of 21.

All registered accounts are subject to age verification during KYC, and tmt33 reserves the right to request proof of age at any point in the account lifecycle. Where tmt33 discovers that an account has been registered by an individual under the age of 21, the account will be immediately closed and any collected personal data will be deleted, subject to any record-keeping obligations required by law.

tmt33 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or regulatory guidance from the National Privacy Commission or PAGCOR. The effective date at the top of this document indicates when the current version came into force.

For material changes — those that substantively alter the rights of Data Subjects or the nature of data processing — tmt33 will provide at least fourteen (14) days' advance notice via email to the registered address and/or a prominent notice on the Platform before the changes take effect. For changes required by law or regulatory direction, tmt33 may implement changes with immediate effect and communicate them as promptly as practicable.

Continued use of the tmt33 Platform following the effective date of any updated Privacy Policy constitutes acknowledgement of the updated Policy. If you do not accept the updated Privacy Policy, you should cease using the Platform and may request account closure in accordance with the procedure described in tmt33's Terms & Conditions.

tmt33 has appointed a Data Protection Officer (DPO) in accordance with the requirements of the Data Privacy Act of 2012. For any privacy-related enquiries, requests to exercise your data subject rights, or concerns about tmt33's data processing practices, please contact tmt33's DPO using the following channels:

• Email: [email protected] — use the subject line "Data Privacy Request" for DPA-related correspondence (plain text — not a clickable link)
• Live Chat: Available 24/7 on tmt33.club — mention "Data Privacy" to the support agent for routing to the DPO team
• Response Time: tmt33 will acknowledge all data subject requests within five (5) business days and will endeavour to fully resolve requests within thirty (30) days, consistent with DPA requirements

For complaints that cannot be resolved through tmt33's internal process, Data Subjects have the right to escalate to the National Privacy Commission (NPC) of the Philippines. Information on how to file a complaint with the NPC is available on the NPC's official government website. For responsible gaming concerns, additional resources are available at tmt33's Responsible Gaming page.

This Privacy Policy was last reviewed and updated on 1 January 2026 and supersedes all previous versions of tmt33's Privacy Policy.