88tmt Privacy Policy

1 Introduction

88tmt ("88tmt," "we," "us," or "our") is committed to protecting the privacy and personal data of every player who uses our platform at https://88tmt.org (the "Platform"). This Privacy Policy describes how we collect, use, store, disclose, and protect personal information in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA"), its Implementing Rules and Regulations ("IRR"), and the guidelines of the National Privacy Commission ("NPC").

This Policy applies to all personal data processed in connection with your use of the 88tmt Platform, including data collected during account registration, identity verification, gameplay, financial transactions, and customer support interactions. It applies to all registered players and visitors to 88tmt.org.

By registering an account with 88tmt or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you should not use the Platform.

2 Definitions

The following terms, as used in this Privacy Policy, have the meanings set out below:

3 Data Controller Identity

88tmt is the Personal Information Controller for all personal data processed through the 88tmt Platform. 88tmt operates under a PAGCOR license and is subject to the jurisdiction of Philippine regulatory authorities, including the National Privacy Commission ("NPC") and the Anti-Money Laundering Council ("AMLC").

For questions, requests, or complaints relating to your personal data, you may contact 88tmt's designated Data Protection Officer through the following channels:

• Live Chat: Available 24/7 through your logged-in 88tmt account
• Email (DPO): [email protected]

All data subject requests submitted to the DPO will be acknowledged within three (3) business days and substantively responded to within fifteen (15) business days, as required under the DPA's IRR.

4 Personal Data We Collect

88tmt collects personal data in several categories, as described in the table below. The specific data collected depends on how you use the Platform and your account verification status.

5 How We Collect Personal Data

88tmt collects personal data through the following channels and methods:

• Account Registration: Information you provide when creating your 88tmt account, including your name, mobile number, and chosen credentials.
• KYC Verification: Identity documents and biometric data (liveness selfie) submitted during the account verification process, either directly or through our third-party KYC provider.
• Deposits and Withdrawals: Payment method details and transaction records generated when you deposit or withdraw via GCash, Maya, BPI, BDO, or other approved channels.
• Gameplay: Automatically generated records of your gaming sessions, including games played, stakes, outcomes, and session duration.
• Device and Browser Data: Technical data collected automatically when you access the Platform, including your IP address, device type, operating system, and browser version.
• Customer Support Interactions: Records of your communications with the 88tmt support team through live chat or email.
• Cookies and Tracking Technologies: See Section 11 for full details on our use of cookies.
• Third-Party Sources: In limited circumstances, we may receive data about you from fraud prevention agencies, credit reference agencies, or regulatory authorities where required for compliance purposes.

6 Purposes of Processing and Legal Basis

88tmt processes your personal data for the following purposes, each of which is supported by one or more lawful bases under the Philippine Data Privacy Act:

• Account creation and management — necessary for the performance of our contract with you as a registered player.
• KYC identity and age verification — required by law under PAGCOR's licensing conditions and the AMLA; also necessary to comply with our obligation to restrict access to players aged 21 and above.
• Processing deposits and withdrawals — necessary for the performance of our contract with you.
• Game operation and result recording — necessary for the performance of our contract and required by PAGCOR for audit purposes.
• Fraud prevention and security monitoring — legitimate interest in protecting the Platform, its players, and the integrity of gaming operations.
• Anti-money laundering compliance — required by law under the AMLA (RA 9160 as amended by RA 10365 and RA 11521).
• Responsible gaming monitoring and intervention — required by PAGCOR regulations and legitimate interest in player welfare.
• Customer support — necessary for the performance of our contract and legitimate interest in player satisfaction.
• Regulatory reporting — required by law; PAGCOR and AMLC reporting obligations.
• Platform improvement and analytics — legitimate interest in improving the 88tmt experience, using aggregated and pseudonymised data where possible.
• Marketing communications — with your explicit consent only; you may withdraw consent at any time.

Where processing is based on your consent (e.g., for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing that occurred before the withdrawal.

7 Sharing Your Personal Data

88tmt does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. We share personal data only in the limited circumstances described below, and only to the extent necessary for the stated purpose:

• Payment Service Providers: GCash (G-Xchange Inc.), Maya (Voyager Innovations), and other Philippine banking and payment partners — to process your deposits and withdrawals. These providers act as Personal Information Processors under contracts that require them to maintain appropriate data security.
• KYC and Identity Verification Providers: Third-party eKYC service providers engaged to verify your identity and age against government databases and document authenticity systems. These providers process your identity documents solely for verification purposes under strict confidentiality obligations.
• Game Studio Partners: PG Soft, Jili, JDB, Pragmatic Play, and other integrated game studios receive minimal technical session data (e.g., player token, bet value) necessary to run their games. No detailed personal information is shared with game studios.
• Regulatory Authorities: PAGCOR (Philippine Amusement and Gaming Corporation), the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and any other competent Philippine government authority, where disclosure is required by law or regulatory directive.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required pursuant to a valid legal order, subpoena, warrant, or court order.
• Fraud Prevention Agencies: To verify transactions and detect suspicious activity, we may share data with Philippine fraud prevention networks and financial intelligence units.
• Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by 88tmt, under strict professional confidentiality obligations.

8 Cross-Border Data Transfers

Some of the third-party service providers engaged by 88tmt — particularly international game studios and certain technical infrastructure providers — may be located outside the Republic of the Philippines. Where personal data is transferred to a recipient in another country, 88tmt will take steps to ensure that adequate safeguards are in place as required under Section 21 of the DPA, including:

• Entering into data transfer agreements that incorporate standard contractual clauses approved by the NPC or equivalent data protection authority;
• Ensuring the recipient country provides an adequate level of protection for personal data under its national laws;
• Limiting transferred data to the minimum necessary for the specific service being provided.

Where technically feasible, 88tmt prefers Philippine-hosted data infrastructure for the storage of personal data. Any cross-border transfers are documented and subject to periodic review by our Data Protection Officer.

9 Data Retention

88tmt retains personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to longer retention periods required by applicable law. The following retention periods apply:

• Account and identity data: Retained for a minimum of five (5) years following permanent account closure, as required by PAGCOR's record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years following the date of each transaction, as required under the AMLA and PAGCOR regulations.
• Gaming activity records: Retained for a minimum of five (5) years following the relevant gaming session, for audit and dispute resolution purposes.
• KYC documentation: Retained for a minimum of five (5) years following account closure, or longer if required by a regulatory investigation or legal proceeding.
• Customer support records: Retained for a period of three (3) years following the relevant interaction, for quality assurance and dispute resolution purposes.
• Marketing preference data: Retained until you withdraw your consent or request deletion, subject to our legal retention obligations.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with NPC guidelines. Where data is anonymised rather than deleted, the resulting anonymous data may be retained for statistical and analytical purposes without restriction.

10 Security Measures

88tmt implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and the 88tmt Platform is encrypted using 256-bit SSL/TLS encryption — the same standard used by Philippine banks for online banking.
• Data Encryption at Rest: Personal data stored on 88tmt's servers, particularly sensitive data categories such as government ID numbers and financial data, is encrypted at rest using AES-256 or equivalent.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. 88tmt staff are granted only the minimum access privileges necessary for their role. All access to personal data systems is logged and auditable.
• Two-Factor Authentication (2FA): All 88tmt administrative system access requires multi-factor authentication. Players are encouraged (and can require) SMS OTP 2FA on their accounts.
• Password Security: Player passwords are stored as salted cryptographic hashes — never in plain text. Staff cannot read player passwords.
• Security Audits: 88tmt conducts periodic vulnerability assessments and penetration testing of Platform infrastructure.
• Data Breach Response: 88tmt maintains a Data Breach Response Plan in accordance with NPC Circular 16-03. In the event of a personal data breach that is likely to result in harm to data subjects, 88tmt will notify the NPC within 72 hours and notify affected players without undue delay.

11 Cookies and Tracking Technologies

The 88tmt Platform uses cookies and similar technologies to operate correctly, improve your experience, and ensure Platform security. A cookie is a small text file stored on your device by your browser when you visit a website.

Categories of cookies used on 88tmt:

• Strictly Necessary Cookies: Essential for Platform operation — session authentication, security tokens, language preferences, and login state. These cannot be disabled without breaking Platform functionality.
• Functional Cookies: Remember your preferences such as game display settings and responsible gaming tool configurations between sessions.
• Analytics Cookies: Collect anonymised or pseudonymised data on how players navigate the Platform — page visit frequency, navigation paths, and feature usage. Used to improve Platform design and performance.
• Security Cookies: Detect and prevent fraudulent activity, bot access, and multi-accounting by fingerprinting device characteristics.

Managing Cookies: You can control non-essential cookies through your browser settings. Most modern browsers (Chrome, Safari, Firefox) allow you to block, delete, or restrict cookies. Note that disabling strictly necessary cookies will impair or prevent access to the Platform. 88tmt does not use third-party advertising cookies or behavioural tracking cookies for external ad networks.

12 Your Rights Under the Philippine Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 88tmt. All requests should be submitted to our Data Protection Officer via 24/7 live chat or email to [email protected].

88tmt will respond to all data subject rights requests within fifteen (15) business days of receipt. Where a request requires additional time due to complexity, we will inform you within the initial 15-day period and provide a revised response timeline.

13 Minors and Age Restriction

The 88tmt Platform is strictly intended for adult Filipino players aged 21 years and above, in accordance with PAGCOR's regulations governing online casino gaming. 88tmt does not knowingly collect personal data from individuals under the age of 21.

All accounts are subject to mandatory KYC age verification before real-money play, deposits, or withdrawals are enabled. If 88tmt discovers that personal data has been collected from a person under the age of 21, the account will be immediately suspended, any funds will be handled in accordance with PAGCOR guidelines, and the data will be securely deleted except where retention is required for regulatory reporting purposes.

If you are a parent or guardian and believe that a minor under your care has registered an account with 88tmt, please contact our support team immediately via 24/7 live chat. We will investigate promptly and take appropriate action.

14 Marketing Communications

With your explicit consent, 88tmt may send you promotional communications about bonuses, new games, events, and platform updates via SMS to your registered Philippine mobile number or via email. Marketing communications are optional — your consent is sought separately during registration and in your account settings.

Opting Out: You may withdraw your consent to receive marketing communications at any time by:

• Updating your communication preferences in your 88tmt account settings (under "Notifications & Marketing");
• Replying STOP to any promotional SMS received from 88tmt;
• Contacting our support team via 24/7 live chat; or
• Emailing our DPO at [email protected].

Withdrawal of marketing consent will not affect the delivery of transactional and account communications (e.g., deposit confirmations, OTP messages, security alerts, responsible gaming notifications) — these are sent regardless of marketing preferences as they are necessary for account operation.

88tmt does not share your contact data with third-party advertisers for their own marketing campaigns. Promotional communications sent by 88tmt relate exclusively to 88tmt's own products and services.

15 Privacy Complaints and DPO Contact

If you have any concerns, questions, or complaints about how 88tmt processes your personal data, we encourage you to contact our Data Protection Officer in the first instance. Most privacy concerns can be addressed quickly at this stage:

• Live Chat: 24/7 via your logged-in 88tmt account dashboard
• DPO Email: [email protected]

If you are not satisfied with 88tmt's response to your privacy complaint, you have the right to escalate the matter to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act. The NPC's contact information and complaint filing procedures are available through official Philippine government channels.

16 Changes to This Privacy Policy

88tmt reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, new regulatory requirements, or improvements to Platform functionality. Updated versions of the Policy will be posted on this page with a revised effective date.

Where changes are material — meaning they significantly affect your rights or how we process your personal data — 88tmt will provide advance notice via your registered contact details (SMS or email) or through a prominent notice on the Platform, at least fourteen (14) days before the changes take effect.

Your continued use of the 88tmt Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you must cease using the Platform and may request account closure as described in our Terms and Conditions.