Privacy Policy

th16 ("we," "us," "our," or "the Platform") operates an online gaming platform accessible at th16.cam. This Privacy Policy describes our practices concerning the collection, use, storage, disclosure, and protection of personal information provided by users ("you," "your," or "the User") in connection with your use of the th16 platform and services.

This Privacy Policy applies to all personal data collected through the th16 website, mobile-optimized interface, and any other digital touchpoints operated by th16. By accessing or using the th16 platform, creating an account, or providing your personal information to us in any manner, you acknowledge that you have read, understood, and agree to this Privacy Policy in its entirety.

th16 is committed to full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations (IRR), and all issuances of the National Privacy Commission (NPC) of the Philippines. Where our practices exceed the minimum legal requirements, we do so to provide additional protection for your personal data.

For the purposes of the Data Privacy Act of 2012, th16 is the data controller responsible for your personal information. As the data controller, th16 determines the purposes and means of processing your personal data and is accountable for ensuring that such processing complies with applicable Philippine data protection laws.

th16's Data Protection Officer (DPO) is responsible for overseeing data protection strategy and implementation to ensure compliance with the Data Privacy Act. You may contact the DPO directly with any questions, concerns, or requests related to your personal data or this Privacy Policy using the contact details provided in Section 14 of this document.

th16 collects several categories of personal information to provide, maintain, and improve our services. The specific data we collect depends on how you interact with the platform. The categories of personal data collected by th16 include:

3.1 Account Registration Data

When you create a th16 account, you provide the following mandatory information:

• Full legal name (as it appears on government-issued identification)
• Date of birth (to verify you are 21 years of age or older)
• Email address (for account communications and password recovery)
• Mobile telephone number (for SMS OTP authentication and account security)
• Residential address (street, barangay, city/municipality, province, postal code)
• Username and encrypted password (for secure login authentication)
• Preferred currency (automatically set to Philippine Peso for all Filipino accounts)

3.2 Identity Verification (KYC) Data

To comply with regulatory requirements and prevent fraud, th16 collects the following verification documents:

• Government-issued identification document (Philippine National ID / PhilSys, UMID, Passport, Driver's License)
• Clear photograph or scan of identification document showing your full name, date of birth, photograph, and document issue/expiry dates
• Selfie photograph holding your identification document ("liveness verification")
• Proof of address document where required (utility bill, bank statement, government correspondence dated within the last 90 days)

3.3 Payment & Transaction Data

• Payment method details (GCash mobile number, Maya account identifier, bank account details for deposits and withdrawals)
• Transaction history (deposit amounts, withdrawal requests, payment timestamps, payment method used, transaction reference numbers)
• Account balance and wallet activity logs
• Bonus and promotional claim records

3.4 Gaming Activity Data

• Game play history (games played, bet amounts, outcomes, session duration)
• Sports betting activity (events wagered on, bet types, stake amounts, settlement results)
• Win/loss statistics and account profit/loss calculations
• Bonus wagering progress and fulfillment status
• Responsible gaming tool usage (deposit limits set, session time alerts configured, self-exclusion requests)

3.5 Technical & Device Data

• IP address and approximate geolocation (city/region level only, derived from IP)
• Device information (device type, operating system, browser type and version, screen resolution)
• Session logs (login timestamps, logout events, session duration)
• Website interaction data (pages viewed, buttons clicked, navigation paths, time spent on pages)
• Cookies and similar tracking technologies (see Section 6 for details)

3.6 Communications Data

• Customer support correspondence (live chat transcripts, email exchanges, subm itted support tickets, complaint records)
• Marketing communication preferences (email subscription status, promotional opt-in/opt-out records)
• Survey and feedback responses where voluntarily submitted

th16 uses your personal information only for the purposes described in this Privacy Policy. We do not process your data in any manner that is incompatible with these purposes. The specific purposes for which we use your data include:

4.1 Account Management & Service Delivery

• Creating and maintaining your th16 account
• Authenticating your identity at login
• Processing deposits, withdrawals, and account balance updates
• Enabling access to games and platform features
• Delivering customer support and resolving disputes

4.2 Legal & Regulatory Compliance

• Verifying your identity and age (minimum 21 years) in compliance with PAGCOR requirements
• Meeting Anti-Money Laundering obligations under Republic Act No. 9160 (AMLA) and its amendments
• Responding to lawful requests from Philippine regulatory authorities and law enforcement agencies
• Maintaining transaction records for the periods required by law
• Detecting, investigating, and preventing fraud, money laundering, and other unlawful activity

4.3 Platform Security & Integrity

• Detecting and preventing unauthorized access to your account
• Identifying and preventing cheating, collusion, or bonus abuse
• Monitoring for technical errors and platform security vulnerabilities
• Enforcing our Terms & Conditions and acceptable use policies

4.4 Responsible Gaming

• Monitoring gaming activity patterns to identify signs of problem gambling
• Administering self-exclusion requests and deposit/loss limits
• Sending responsible gaming reminders and session time notifications where you have opted in

4.5 Marketing Communications (Consent-Based Only)

With your express consent, th16 may use your contact details to send you promotional offers, bonus notifications, and news about new games or platform features. You may withdraw your marketing consent at any time by updating your account communication preferences or by contacting th16 support. Withdrawal of marketing consent does not affect service-related communications, which remain necessary for account operation.

Under the Data Privacy Act of 2012, th16 processes your personal data on the following lawful bases:

• Contractual Necessity: Processing required to perform our obligations under the Terms & Conditions you accepted when creating your account — including account management, payment processing, and game access;
• Legal Obligation: Processing required to comply with applicable Philippine laws and regulations, including AMLA, PAGCOR licensing requirements, and the Data Privacy Act itself;
• Legitimate Interests: Processing necessary for th16's legitimate business interests, including fraud prevention, platform security, and responsible gaming monitoring, where such interests do not override your fundamental rights;
• Consent: Processing for optional purposes — specifically marketing communications — where you have freely given your explicit consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

th16 uses cookies and similar tracking technologies to operate the platform efficiently, maintain your session, and understand how users interact with the website. A cookie is a small text file placed on your device by a website you visit. Cookies help the website remember your preferences and login state between sessions.

The types of cookies used by th16 include:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies, security tokens, and load-balancing cookies. These cannot be disabled without preventing platform use;
• Functional Cookies: Store your preferences such as language settings, display options, and last-visited game category. These improve your experience but are not essential;
• Analytics Cookies: Collect anonymized or aggregated data about how visitors use the platform — pages visited, time spent, navigation paths — to help th16 improve platform performance and user experience;
• Security Cookies: Help detect and prevent fraudulent sessions, bot activity, and unauthorized access attempts.

th16 does not sell, rent, or trade your personal information to any third party. Your data is shared only in the limited circumstances described below, and only to the extent necessary for the stated purpose:

• Payment Processors: Your payment details are shared with GCash, Maya, GrabPay, BPI, BDO, Metrobank, and other payment providers solely to execute your deposit and withdrawal transactions. These providers are contractually bound to handle your data securely and only for payment processing purposes;
• Identity Verification Providers: Your KYC documents may be processed by trusted third-party identity verification services to confirm the authenticity of your identification documents. These providers operate under strict data processing agreements with th16;
• Game Software Providers: Game providers such as JILI, PG Soft, Pragmatic Play, and others may receive anonymized session data necessary to operate their games on the th16 platform. No personally identifiable information is shared with game providers beyond what is technically required;
• Regulatory Authorities: th16 may be required to disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other Philippine government agencies where legally required or in response to lawful regulatory orders;
• Law Enforcement: Where required by a valid court order, subpoena, or lawful request from Philippine law enforcement authorities, th16 will disclose the minimum necessary personal data. th16 will notify you of such a request where legally permitted to do so;
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of th16's business, personal data held by th16 may be transferred to the acquiring entity as part of that transaction, subject to equivalent privacy protections.

th16 retains your personal data only for as long as necessary to fulfil the purposes described in this Privacy Policy, or as required by Philippine law. The following retention periods apply to different categories of your data:

• Account Registration Data: Retained for the duration of your active account, plus five (5) years from account closure — as required by applicable financial record-keeping and AML regulations;
• KYC Identity Documents: Retained for a minimum of five (5) years from the date of last account activity, in compliance with AMLA requirements;
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine financial record-keeping laws;
• Gaming Activity Logs: Retained for two (2) years from the date of activity, or for the duration required by PAGCOR for audit and dispute resolution purposes;
• Customer Support Records: Retained for two (2) years from the date of the last support interaction;
• Marketing Preferences: Retained until you withdraw consent or close your account, whichever occurs first.

Upon expiry of the applicable retention period, your personal data will be securely deleted or anonymized so that it can no longer be associated with you. Where data is retained beyond the active service period solely for legal compliance purposes, access to such data is strictly limited within th16.

th16 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, alteration, disclosure, or destruction. Our security measures include, but are not limited to:

• Encryption in Transit: All data transmitted between your device and th16 servers is encrypted using TLS 1.2 or higher, ensuring your credentials and personal data cannot be intercepted;
• Encryption at Rest: Sensitive personal data stored on th16 servers, including identification documents and payment details, is encrypted at rest using AES-256 encryption;
• Access Controls: Access to personal data within th16 is strictly role-based and limited to personnel with a verified operational need. All access is logged and regularly audited;
• Two-Factor Authentication: All th16 staff accounts with access to personal data systems are protected by mandatory two-factor authentication;
• Penetration Testing: th16 conducts regular security assessments and penetration tests of its platform and infrastructure to identify and remediate vulnerabilities;
• Incident Response: th16 maintains a documented data breach response plan, including notification procedures compliant with the NPC's 72-hour breach notification requirement.

Under the Data Privacy Act of 2012, you have specific rights with respect to your personal data held by th16. th16 is committed to facilitating the exercise of these rights without undue delay. Your rights include:

• Right to Be Informed: The right to know what personal data th16 collects about you and how it is processed — which is the primary purpose of this Privacy Policy;
• Right to Access: The right to request a copy of the personal data th16 holds about you, including information on its source, purpose, and any third parties to whom it has been disclosed;
• Right to Correction: The right to request correction of any personal data that is inaccurate, incomplete, or outdated. You may update most registration information directly through your account settings;
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to th16's legal retention obligations. Note that data retained for AML and regulatory compliance purposes cannot be deleted while the legal retention period is in force;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to request its transfer to another data controller where technically feasible;
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes, which th16 will honor immediately upon receipt of such objection;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe th16 has violated your data privacy rights.

To exercise any of the above rights, please contact th16's Data Protection Officer using the details provided in Section 14. th16 will respond to all verifiable data rights requests within thirty (30) calendar days of receipt.

The primary servers hosting th16 player data are located within or near the Philippines. In limited circumstances, personal data may be processed by service providers operating outside the Philippines — for example, where a game provider or technical infrastructure provider operates international data centers.

Where personal data is transferred outside the Philippines, th16 ensures that such transfers are protected by appropriate safeguards, including contractual data processing agreements that impose data protection obligations equivalent to those required under the Philippine Data Privacy Act. th16 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing such contractual safeguards.

If th16 becomes aware that personal data has been collected from an individual below the age of 21, th16 will immediately suspend the relevant account, delete all associated personal data, and report the matter to the appropriate authorities where required. If you believe a minor has registered on the platform, please contact th16 support immediately at [email protected].

th16 reviews and updates this Privacy Policy periodically to reflect changes in our data practices, legal obligations, and platform features. The "Last Updated" date at the top of this page will reflect the most recent revision.

When material changes are made to this Privacy Policy — particularly changes that affect how we use your personal data or your privacy rights — th16 will notify registered users via email or a prominent in-platform notification prior to the changes taking effect, where reasonably practicable.

Your continued use of the th16 platform following the effective date of any revised Privacy Policy constitutes your acknowledgment of and agreement to the updated terms. If you do not agree to the revised Privacy Policy, you should discontinue use of the platform and may request account closure in accordance with our Terms & Conditions.

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by th16, please contact our Data Protection Officer through any of the following channels:

If you are not satisfied with th16's response to your privacy concern, you have the right to lodge a formal complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.