tmplay Privacy Policy

1. Introduction

tmplay ("we", "us", "our") operates the online gaming platform accessible at https://tmplay.net, which provides casino games, live dealer tables, bingo, slots, and sports betting services to players located in the Philippines. As an online gaming platform subject to PAGCOR regulatory oversight, tmplay processes personal data as a necessary part of delivering safe, compliant, and high-quality gaming services to Filipino players.

This Privacy Policy applies to all personal data collected by tmplay in connection with the registration, operation, and maintenance of player accounts, the provision of gaming services, and all related customer support, marketing, and compliance activities. It covers data collected through the tmplay website at https://tmplay.net, the mobile-optimised platform, and any associated communications channels including email and live chat support.

This Privacy Policy should be read together with the tmplay Terms & Conditions and any game-specific or promotion-specific terms published on the platform. By registering a tmplay account or continuing to use the platform, you confirm that you have read and understood this Privacy Policy.

2. Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), tmplay is the personal information controller in respect of all personal data collected and processed through the tmplay platform. tmplay has appointed a Data Protection Officer (DPO) who oversees all data privacy compliance matters and serves as the designated point of contact for data subject inquiries and requests.

Contact details for the tmplay Data Protection Officer are set out in Section 15 of this Privacy Policy. All data subject rights requests, privacy complaints, and DPA-related inquiries should be directed to the DPO using the contact details provided.

3. Data We Collect

tmplay collects personal data from players through several channels and at various stages of the player lifecycle. The categories of personal data we collect are described below.

3.1 Registration Data

When you open a tmplay account, we collect the information you provide during the registration process, including: full legal name, date of birth, nationality, Philippine residential address, valid email address, Philippine mobile number, and the username and password you select. This information is required to create your account and is used to verify your eligibility to use the tmplay platform.

3.2 KYC and Identity Verification Data

To comply with PAGCOR KYC requirements and the Philippines' Anti-Money Laundering Act (AMLA), tmplay collects copies of government-issued identity documents submitted for verification. Acceptable Philippine IDs include a valid passport, SSS card, UMID, PhilSys national ID, driver's licence, or PRC ID. We may also collect proof of address documents and, in certain circumstances, documentation evidencing the source of funds used for gaming deposits. This data is classified as sensitive personal information under the Data Privacy Act and is processed with enhanced security controls.

3.3 Financial Data

tmplay collects transaction data relating to deposits, withdrawals, and bonus claims made through your tmplay account. This includes the payment method used (e.g., GCash, Maya, BPI, BDO, Metrobank, Coins.ph, or USDT TRC20), transaction amounts in Philippine Peso (₱), transaction timestamps, and reference numbers. tmplay does not store full bank account numbers or complete e-wallet credentials — only the data necessary to record and reconcile transactions.

3.4 Gaming Activity Data

tmplay records all wagering activity associated with your account, including game sessions, wager amounts, game outcomes, sports betting selections, and bonus usage. This data is used for account management, dispute resolution, responsible gaming monitoring, and regulatory reporting to PAGCOR as required.

3.5 Technical and Device Data

When you access the tmplay platform, we automatically collect certain technical data including: IP address, device type and operating system, browser type and version, screen resolution, referring URL, session duration, pages visited, and clickstream data. This information is used for platform security, fraud prevention, and improving the player experience.

3.6 Communications Data

tmplay retains records of all communications between you and our customer support team, including live chat transcripts, support emails, and any attachments or screenshots shared during a support interaction. This data is used to resolve disputes, improve service quality, and maintain compliance records.

3.7 Marketing Preferences

Where you have provided consent, tmplay records your marketing communication preferences, including your opt-in status for promotional emails, SMS notifications, and in-platform push notifications. These preferences are stored and can be updated by you at any time through your account settings.

4. How We Use Your Data

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

• Account Creation and Management: To register your tmplay account, verify your identity, maintain your account, and provide access to platform features.
• KYC and Regulatory Compliance: To fulfil our obligations under PAGCOR regulations, the Philippine AMLA, and any other applicable laws requiring identity verification and transaction monitoring.
• Payment Processing: To process deposits and withdrawals through your chosen payment method, reconcile transactions, and investigate payment disputes.
• Gaming Services Delivery: To provide access to casino games, live dealer tables, bingo rooms, slots, and sports betting markets on the tmplay platform.
• Responsible Gaming: To monitor gaming patterns for indicators of problem gambling, enforce deposit limits and self-exclusion requests, and provide proactive responsible gaming interventions where warranted.
• Fraud Prevention and Security: To detect and prevent fraudulent account activity, money laundering, multi-accounting, bonus abuse, and other prohibited activities described in the tmplay Terms & Conditions.
• Customer Support: To respond to your inquiries, resolve disputes, and process complaints submitted to the tmplay support team.
• Platform Improvement: To analyse usage data in aggregate to improve the performance, usability, and game selection of the tmplay platform.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to players who have provided consent to receive such communications.
• Legal and Regulatory Obligations: To respond to lawful requests from PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council, or other Philippine government authorities.

5. Legal Bases for Processing

Under the Philippine Data Privacy Act, tmplay processes your personal data on the following legal bases:

6. Sharing of Personal Data

tmplay does not sell or rent your personal data to third parties. We share personal data only in the following circumstances and only to the minimum extent necessary for the stated purpose:

6.1 Service Providers and Data Processors

tmplay engages third-party service providers who process personal data on our behalf and under our instruction, including: payment gateway and e-wallet processors (GCash, Maya, and partner banks), KYC and identity verification technology providers, cloud hosting and data centre operators, customer support software providers, and fraud detection platform providers. All such providers are contractually bound to process data only in accordance with tmplay's instructions and applicable Philippine data protection law.

6.2 Game Content Providers

Third-party game studios whose games are available on the tmplay platform may receive limited technical data (such as session tokens and game round identifiers) necessary to deliver their games. These providers do not receive personally identifiable registration or financial data beyond what is strictly necessary for game delivery and RNG certification auditing.

6.3 Regulatory and Law Enforcement Authorities

tmplay will share personal data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue (BIR), and Philippine law enforcement authorities where we are required to do so by law, court order, or PAGCOR regulatory directive. Such disclosures are made without prior notice to the affected player where legally required or where prior notice would compromise an investigation.

6.4 Corporate Transactions

In the event of a merger, acquisition, restructuring, or sale of assets involving the tmplay operating entity, player personal data may be transferred to a successor entity as part of that transaction. Players will be notified of any such transfer and of any material change to this Privacy Policy resulting from it, as required by the Data Privacy Act.

7. Data Retention

tmplay retains personal data for the periods specified below, after which data is securely deleted, destroyed, or anonymised in accordance with our data retention schedule:

Where a legal dispute, regulatory investigation, or PAGCOR audit is in progress at the time the retention period expires, tmplay will retain the relevant personal data for the duration of those proceedings.

8. Cookies and Tracking Technologies

tmplay uses cookies and similar tracking technologies on the tmplay website to deliver and improve the platform experience. Cookies are small text files placed on your device when you visit the tmplay website. The types of cookies used by tmplay are as follows:

• Strictly Necessary Cookies: These cookies are essential for the tmplay platform to function correctly. They enable secure login sessions, maintain your account session state, and ensure that security features operate correctly. These cookies cannot be disabled without impairing platform functionality.
• Functional Cookies: These cookies remember your preferences on the tmplay platform, such as your preferred language setting, display preferences, and responsible gaming reminder settings. Disabling these cookies may affect your platform experience.
• Analytics Cookies: tmplay uses anonymised analytics data to understand how players navigate the platform, which games are most popular, and where technical issues may arise. Analytics cookies do not identify you personally — data is processed in aggregate form only.
• Marketing Cookies: Where you have provided consent, tmplay may use cookies to track the effectiveness of promotional campaigns and deliver relevant content within the tmplay platform. These cookies are only active for players who have opted in to marketing communications.

You can manage your cookie preferences through your browser settings or through the cookie management tool available on the tmplay platform. Note that blocking strictly necessary cookies will prevent access to certain platform features.

9. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, every tmplay player has the following data subject rights in respect of their personal data held by tmplay:

• Right to Be Informed: The right to be told what personal data tmplay holds about you and how it is being used — which is the primary purpose of this Privacy Policy.
• Right of Access: The right to request a copy of the personal data that tmplay holds about you, together with information about the purposes of processing and the categories of recipients to whom data has been disclosed.
• Right to Rectification: The right to request that tmplay correct any inaccurate or incomplete personal data held in your account. For basic account details, you may update information directly through your tmplay account settings.
• Right to Erasure: The right to request that tmplay delete your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent, or where processing is unlawful. Note that this right is subject to tmplay's legal retention obligations under PAGCOR regulations and the AMLA.
• Right to Data Portability: The right to receive a copy of 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 the processing of your personal data for direct marketing purposes at any time, and to object to processing based on legitimate interest where you believe that your interests override tmplay's legitimate interest.
• Right to Restrict Processing: The right to request that tmplay restricts the processing of your personal data in certain circumstances, for example while the accuracy of data is being contested or a complaint is under investigation.
• Right to Complain: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that tmplay has processed your personal data in breach of the Data Privacy Act.

To exercise any of the above rights, please submit a written request to the tmplay Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request". tmplay will verify your identity before processing any request and will respond within fifteen (15) business days of receipt of a verified request.

10. Data Security

tmplay implements a comprehensive set of technical and organisational security measures to protect personal data from unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption: All personal data stored on tmplay servers is encrypted at rest using AES-256 encryption. All data transmitted between your device and the tmplay platform is encrypted in transit using TLS 1.3.
• Access Controls: Access to personal data within tmplay's internal systems is restricted to authorised personnel on a role-based, need-to-know basis. All access events are logged, monitored, and subject to periodic audit.
• Two-Factor Authentication: tmplay offers two-factor authentication (2FA) to all players as an additional layer of account security. We strongly encourage all Filipino players to enable 2FA on their tmplay accounts.
• Penetration Testing: tmplay engages independent security specialists to conduct regular penetration testing and vulnerability assessments of the platform infrastructure.
• Staff Training: All tmplay personnel with access to personal data receive mandatory data privacy and security training as part of their onboarding and on an ongoing annual basis.
• Incident Response: tmplay maintains a documented data security incident response plan that is tested and updated regularly. In the event of a security incident affecting personal data, tmplay will follow the breach notification procedures described in Section 13 of this Privacy Policy.

While tmplay takes all reasonable steps to secure your personal data, no online platform can guarantee absolute security. Players are encouraged to use strong, unique passwords for their tmplay accounts, enable 2FA, and notify tmplay immediately at [email protected] if they suspect unauthorised access to their account.

11. Children and Minors

The tmplay platform is strictly restricted to persons who are 21 years of age or older, in accordance with PAGCOR regulations governing online gaming in the Philippines. tmplay does not knowingly collect personal data from any person under the age of 21.

Age verification is conducted as part of the KYC process for all tmplay accounts. Where tmplay discovers, at any point, that a registered account belongs to a person under the age of 21, the account will be immediately suspended, all balances frozen, and the matter referred to PAGCOR in accordance with our regulatory obligations. Any personal data collected from an underage person will be deleted as promptly as practicable following discovery, subject to any legal retention obligations.

12. Cross-Border Data Transfers

tmplay's primary data processing infrastructure is located within the Philippines. In certain circumstances, personal data may be processed by tmplay's service providers in data centres located outside the Philippines — for example, where cloud hosting providers operate regionally across Southeast Asia, or where KYC verification technology providers operate international processing infrastructure.

Where personal data is transferred outside the Philippines, tmplay ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Philippine Data Privacy Act. These safeguards include contractual data processing agreements with all international service providers that incorporate the data protection obligations required by the National Privacy Commission.

Players who wish to obtain more information about the specific safeguards in place for any cross-border data transfers may contact the tmplay Data Protection Officer at [email protected].

13. Personal Data Breach Notification

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of affected players, tmplay will notify the National Privacy Commission within seventy-two (72) hours of becoming aware of the breach, in accordance with the requirements of the Philippine Data Privacy Act and the NPC's implementing rules.

Where a breach is assessed to result in a high risk to the rights and freedoms of affected players — for example, where sensitive personal information such as KYC documents or financial data is involved — tmplay will also notify affected players directly by email to the registered email address on their tmplay account. Such notification will include: a description of the nature of the breach, the categories of data affected, the likely consequences of the breach, and the measures tmplay has taken or proposes to take to address the breach and mitigate its effects.

tmplay maintains a data breach register in accordance with NPC requirements. All confirmed security incidents affecting personal data are investigated, documented, and reviewed as part of tmplay's ongoing security improvement programme.

14. Amendments to This Privacy Policy

tmplay reserves the right to amend this Privacy Policy at any time to reflect changes in applicable Philippine law, PAGCOR regulatory requirements, our data processing activities, or the services we provide. Where a material change is made to this Privacy Policy, tmplay will provide notice to registered players by email or through an in-platform notification at least seven (7) days before the amended policy takes effect.

The current effective version of this Privacy Policy, with the effective date clearly stated, is always available at https://tmplay.net/privacy-policy. We encourage all tmplay players to review this Privacy Policy periodically. Continued use of the tmplay platform after the effective date of any amendment constitutes acceptance of the revised Privacy Policy.

If you do not accept the terms of the revised Privacy Policy, you may request account closure and deletion of your personal data (subject to tmplay's legal retention obligations) by contacting the support team at [email protected].

15. Contact the Data Protection Officer

For all data privacy inquiries, data subject rights requests, privacy complaints, or questions about this Privacy Policy, please contact the tmplay Data Protection Officer using the details below:

This Privacy Policy was last updated and is effective as of 1 January 2026. All previous versions of the tmplay Privacy Policy are superseded by this document.