tbhili Privacy Policy - Your Data Protection Rights

1. Introduction and Scope

This Privacy Policy ("Policy") describes how tbhili ("we", "us", "our", or "Company"), operating under PAGCOR licensing as an online casino and sports betting platform serving Filipino users, collects, uses, discloses, stores, and protects personal information obtained from users ("you", "your", or "Player") of our website located at tbhili.cam and associated mobile applications (collectively, the "Platform").

By accessing our Platform, creating an account, or using any of our services, you acknowledge that you have read, understood, and consent to the collection and processing of your personal information as described in this Policy. If you do not agree with this Policy, you must not use our Platform or services.

This Policy applies to all tbhili users, including registered account holders, visitors to our website, mobile app users, and anyone who interacts with our Platform or services. We are committed to complying with the Data Privacy Act of 2012 and implementing appropriate technical and organizational measures to protect your personal data.

2. Information We Collect

2.1 Personal Information Provided by You

When you register an account with tbhili, we collect the following personal information that you directly provide:

• Identification Information: Full legal name, date of birth, nationality, gender, and government-issued identification numbers as required for age verification and compliance with Know Your Customer (KYC) regulations.
• Contact Information: Email address, mobile phone number, residential address, postal code, and city/municipality of residence within the Philippines.
• Account Credentials: Username, password (stored in encrypted format), and security questions/answers used to secure your account.
• Financial Information: Payment method details including GCash account information, PayMaya account details, bank account numbers, credit/debit card information (stored by our PCI-DSS compliant payment processors), and transaction history.
• Verification Documents: Copies of government-issued IDs (passport, driver's license, PhilID, etc.), proof of address documents (utility bills, bank statements), and selfie photos for identity verification purposes.
• Communication Data: Records of your communications with our customer support team via live chat, email, phone calls, and social media messages.

2.2 Information Automatically Collected

When you access the tbhili Platform, we automatically collect certain technical and usage information:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers, and mobile network information.
• Usage Data: Pages visited, games played, betting patterns, time spent on platform, clickstream data, search queries, and interaction with features and content.
• Location Information: IP address, approximate geographic location derived from IP address to verify you are accessing our Platform from within the Philippines as required by our PAGCOR license.
• Cookies and Tracking Technologies: We use cookies, web beacons, pixel tags, and similar technologies to collect information about your browsing behavior and preferences. See Section 8 for detailed information about our cookie practices.
• Transaction Records: Complete history of deposits, withdrawals, bets placed, game outcomes, bonuses claimed, and account balance changes.

2.3 Information from Third Parties

We may receive personal information about you from third-party sources including:

• Payment processors (GCash, PayMaya, banks) who provide transaction verification and fraud prevention services.
• Identity verification services that confirm your identity and age using public and proprietary databases.
• Gaming platform providers who supply game content and may collect gameplay data.
• Marketing partners (with your consent) who may share information about your interaction with promotional campaigns.
• Social media platforms if you choose to link your social accounts or use social login features.

3. How We Use Your Information

tbhili processes your personal information for the following legitimate business purposes:

3.1 Account Management and Service Provision

• Create, maintain, and manage your user account.
• Process deposits, withdrawals, and other financial transactions.
• Provide access to casino games, live dealer tables, and sports betting services.
• Manage bonuses, promotions, loyalty rewards, and VIP programs.
• Process and respond to customer support inquiries and complaints.
• Send transactional communications including account notifications, password resets, and payment confirmations.

3.2 Legal and Regulatory Compliance

• Verify your identity and age to comply with Philippine gaming laws requiring players to be 21+ years old.
• Comply with PAGCOR licensing requirements, regulations, and audit procedures.
• Implement Know Your Customer (KYC) and Anti-Money Laundering (AML) procedures as required by law.
• Detect, prevent, and investigate fraud, money laundering, bonus abuse, and other prohibited activities.
• Maintain records as required by law and respond to legal processes including court orders and government requests.
• Enforce our Terms & Conditions and other policies governing use of the Platform.

3.3 Platform Security and Improvement

• Monitor and analyze usage patterns to improve Platform functionality, user experience, and performance.
• Detect and prevent security threats, unauthorized access, and technical issues.
• Develop and test new features, games, and services.
• Conduct data analytics to understand user preferences and optimize content offerings.
• Ensure responsible gaming by monitoring gambling behavior and implementing player protection measures.

3.4 Marketing and Communications (With Your Consent)

• Send promotional emails, SMS messages, and push notifications about bonuses, tournaments, new games, and special offers.
• Personalize marketing content based on your gaming preferences and activity history.
• Invite you to participate in surveys, feedback requests, and promotional campaigns.
• Display targeted advertisements on our Platform and partner websites (you can opt out of marketing communications at any time).

4. Information Sharing and Disclosure

tbhili does not sell your personal information to third parties. We only share your information in the following limited circumstances:

4.1 Service Providers and Business Partners

We share personal information with trusted third-party service providers who perform services on our behalf, including:

• Payment processors (GCash, PayMaya, banks, credit card networks) to facilitate deposits and withdrawals.
• Identity verification services to confirm your age and identity.
• Game content providers who supply casino games and sports betting platforms.
• Cloud hosting providers who store data on secure servers.
• Customer support platform providers who help us manage communications.
• Marketing and analytics partners who help us optimize campaigns and understand user behavior.
• IT security providers who protect our systems from cyber threats.

All service providers are contractually obligated to protect your information, use it only for specified purposes, and comply with applicable data protection laws.

4.2 Legal and Regulatory Authorities

We may disclose your personal information to government agencies, law enforcement, regulators, and courts when required by law or when we believe disclosure is necessary to:

• Comply with PAGCOR regulations, audit requirements, and licensing obligations.
• Respond to lawful requests, court orders, subpoenas, and legal processes.
• Report suspicious transactions to Philippine financial intelligence units under AML regulations.
• Cooperate with investigations into fraud, money laundering, or other criminal activities.
• Protect the rights, property, or safety of tbhili, our users, or the public.

4.3 Business Transfers

In the event of a merger, acquisition, reorganization, sale of assets, or bankruptcy involving tbhili, your personal information may be transferred to the acquiring entity or successor company. We will notify you of any such transfer and any choices you may have regarding your information.

5. Data Security Measures

tbhili implements comprehensive technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction:

5.1 Technical Security Controls

• Encryption: All data transmitted between your device and our servers is encrypted using industry-standard SSL/TLS protocols. Sensitive data stored in our databases is encrypted at rest.
• Access Controls: Access to personal information is restricted to authorized personnel only, based on role-based access controls and the principle of least privilege.
• Secure Authentication: Passwords are hashed using strong cryptographic algorithms. We support two-factor authentication for enhanced account security.
• Firewalls and Intrusion Detection: Network firewalls, intrusion detection systems, and security monitoring protect our infrastructure from cyber attacks.
• Regular Security Audits: Third-party security firms conduct penetration testing and vulnerability assessments to identify and remediate security weaknesses.
• Data Backup: Regular encrypted backups ensure data can be recovered in case of system failure or disaster.

5.2 Organizational Security Practices

• Employee training on data protection, privacy regulations, and security best practices.
• Confidentiality agreements binding all personnel who handle personal information.
• Incident response procedures to detect, respond to, and report data breaches.
• Vendor management processes ensuring third-party service providers maintain adequate security standards.

Despite these measures, no method of transmission over the internet or electronic storage is 100% secure. While we strive to protect your personal information, we cannot guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and must notify us immediately of any unauthorized access to your account.

6. Data Retention

tbhili retains your personal information only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements:

• Active Accounts: Personal information of active users is retained for the duration of the account relationship and as long as necessary to provide services.
• Closed Accounts: After account closure, we retain certain information for up to seven (7) years to comply with Philippine tax laws, AML regulations, PAGCOR record-keeping requirements, and to handle potential disputes or claims.
• Transaction Records: Financial transaction records are retained for at least five (5) years as required by anti-money laundering regulations.
• Marketing Data: If you opt out of marketing communications, we retain minimal information (email address or phone number) to honor your opt-out preference and prevent future contact.
• Security Logs: Technical logs and security incident records are retained for up to two (2) years for security monitoring and forensic investigation purposes.

After the retention period expires, personal information is securely deleted or anonymized so it can no longer identify you. Some aggregated, anonymized data may be retained indefinitely for statistical analysis and business intelligence purposes.

7. Your Privacy Rights

Under the Data Privacy Act of 2012 and applicable Philippine regulations, you have the following rights regarding your personal information:

7.1 Right to Access

You have the right to request access to the personal information we hold about you. You can view much of your account information by logging into your tbhili account. For additional information, contact our Data Protection Officer using the contact details provided in Section 12.

7.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete personal information. You can update most information directly through your account settings. For changes to verified information (name, date of birth), contact customer support with supporting documentation.

7.3 Right to Erasure

You have the right to request deletion of your personal information, subject to certain limitations. We may be required to retain some information to comply with legal obligations, resolve disputes, prevent fraud, or enforce our agreements. To request account deletion, contact customer support.

7.4 Right to Restrict Processing

You have the right to request restriction of processing your personal information in certain circumstances, such as when you contest the accuracy of data or object to processing. During restricted processing, we will store your information but not actively process it except with your consent or for legal claims.

7.5 Right to Data Portability

You have the right to receive your personal information in a structured, commonly used, and machine-readable format and to transmit that data to another service provider where technically feasible.

7.6 Right to Object

You have the right to object to processing of your personal information for direct marketing purposes. You can opt out of marketing communications at any time by clicking unsubscribe links in emails, adjusting notification settings in your account, or contacting customer support.

7.7 Right to Withdraw Consent

Where processing is based on consent, you have the right to withdraw consent at any time. Withdrawal does not affect the lawfulness of processing conducted before withdrawal.

7.8 Right to Lodge Complaint

If you believe we have violated your privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Contact details: National Privacy Commission, 5th Floor, Philippine International Convention Center, Vicente Sotto Street, Pasay City 1307, Philippines. Website: privacy.gov.ph

8. Cookies and Tracking Technologies

tbhili uses cookies, web beacons, pixel tags, and similar technologies to enhance your experience, analyze usage patterns, and deliver personalized content:

8.1 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Enable core Platform functionality, account authentication, and security features. These cookies are necessary for the Platform to operate and cannot be disabled.	Session or up to 1 year
Functional Cookies	Remember your preferences, language settings, and customization choices to enhance your experience.	Up to 2 years
Analytics Cookies	Collect information about how you use the Platform, which pages are visited most, and identify technical issues to help us improve services.	Up to 2 years
Marketing Cookies	Track your activity across websites to deliver targeted advertising and measure effectiveness of promotional campaigns.	Up to 1 year

8.2 Managing Cookies

Most web browsers automatically accept cookies, but you can modify your browser settings to decline cookies or alert you when cookies are being sent. Note that disabling cookies may affect Platform functionality and prevent access to certain features. You can manage cookie preferences through your browser settings or through our cookie consent banner displayed on your first visit.

9. Third-Party Links and Services

The tbhili Platform may contain links to third-party websites, applications, or services that are not owned or controlled by us. This Privacy Policy applies only to information collected by tbhili. We are not responsible for the privacy practices of third-party sites. We encourage you to review the privacy policies of any third-party sites you visit. When you use third-party payment services (GCash, PayMaya, banks), those providers' privacy policies govern how they handle your information.

10. Children's Privacy

tbhili services are intended exclusively for adults aged 21 years and older as required by Philippine gaming regulations. We do not knowingly collect personal information from individuals under 21 years of age. If we discover that we have inadvertently collected information from a minor, we will immediately delete that information from our systems. If you believe a minor has provided personal information to us, please contact our Data Protection Officer immediately.

11. International Data Transfers

Your personal information is primarily stored and processed on servers located within the Philippines. In some cases, information may be transferred to and processed by service providers located in other countries. When international transfers occur, tbhili ensures that appropriate safeguards are in place to protect your information in accordance with Philippine data protection laws, including:

• Contractual clauses requiring recipients to implement adequate data protection measures.
• Verification that recipient countries have adequate data protection frameworks recognized by the National Privacy Commission.
• Encryption and other security measures to protect data during transmission and storage abroad.

12. Changes to This Privacy Policy

tbhili reserves the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. When we make material changes, we will notify you by:

• Posting a prominent notice on the Platform homepage.
• Sending an email notification to the address associated with your account.
• Displaying an in-app notification when you next log in.
• Updating the "Last Updated" date at the top of this Policy.

Your continued use of the Platform following notification of changes constitutes acceptance of the updated Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your information. If you do not agree with changes, you should discontinue use of the Platform and close your account.

13. Contact Information and Data Protection Officer

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact our Data Protection Officer:

• Email: [email protected]
• Customer Support: [email protected]
• Live Chat: Available 24/7 through the tbhili Platform
• Subject Line: For privacy-related inquiries, use "Privacy Request" or "Data Protection Inquiry" in your subject line

We are committed to addressing your privacy concerns promptly and transparently. Our Data Protection Officer will respond to all legitimate requests within thirty (30) days or as required by applicable law. For urgent security matters or suspected data breaches, please contact us immediately through our 24/7 customer support channels.