twtplay Privacy Policy

twtplay ("twtplay", "we", "us", "our") operates the online gaming platform accessible at https://twtplay.net, including all associated sub-domains, mobile interfaces, and applications (collectively, the "Platform"). twtplay is committed to protecting and respecting the privacy of every Filipino member who registers, browses, or interacts with our Platform.

This Privacy Policy describes how twtplay collects, uses, stores, discloses, and otherwise processes personal information about you — as a registered member, a prospective member, or a visitor to our Platform. It also explains the rights you have under Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), and how you can exercise those rights.

This Privacy Policy applies to all personal data collected through the twtplay Platform, our customer support channels (live chat and email), promotional communications, and any other interaction you have with twtplay. It applies to registered members, unregistered visitors, and individuals who contact our support team without holding an account.

This Policy should be read alongside the twtplay Terms and Conditions and Responsible Gaming Policy, all of which are published on the Platform and incorporated by reference. Where any specific promotion, product feature, or service involves additional data processing, twtplay will notify you of that processing at the point of collection.

twtplay acts as the Personal Information Controller (PIC) in respect of all personal data collected through the Platform, as defined under the Data Privacy Act of 2012. Our designated Data Protection Officer (DPO) can be contacted using the details provided in Section 14 of this Policy.

twtplay collects personal data about you in the following ways: directly from you when you register or use the Platform; automatically through cookies and similar technologies when you browse the Platform; and from third parties such as payment processors and identity verification providers. The categories of personal data we collect include:

twtplay does not intentionally collect sensitive personal information as defined under the DPA (i.e., data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data, or sexual orientation). If any such information is inadvertently shared with us through support communications, it will be deleted promptly and not processed further.

twtplay uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your twtplay account, verify your identity and age (21+), process deposits and withdrawals in Philippine Peso (PHP), and provide you with access to games and services.
• Legal Compliance: To fulfil our obligations under the Data Privacy Act of 2012, anti-money-laundering regulations, and applicable Philippine gaming regulatory requirements — including KYC verification and suspicious transaction reporting.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent transactions, unauthorised account access, multi-accounting, bonus abuse, and other prohibited conduct described in our Terms and Conditions.
• Customer Support: To respond to your enquiries, resolve disputes, process complaints, and provide technical assistance through live chat and email.
• Responsible Gaming: To monitor play patterns and identify signs of problem gambling, enforce deposit limits and self-exclusion requests, and comply with responsible gaming obligations.
• Service Improvement: To analyse aggregated usage data, identify technical issues, improve the Platform's performance, and develop new features tailored to Filipino players.
• Marketing Communications: To send you promotional offers, bonus notifications, and VIP programme updates via email or in-platform notifications — only where you have provided your consent or where permitted by applicable law. You may opt out of marketing communications at any time via your account settings or by contacting support.

twtplay will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing a separate legal basis for the new processing activity.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, twtplay processes your personal data on one or more of the following legal bases:

• Contractual Necessity: Processing is necessary to perform the contract between you and twtplay (i.e., the Terms and Conditions you accepted upon registration), including account creation, payment processing, and game access.
• Legal Obligation: Processing is required to comply with a legal obligation to which twtplay is subject, including KYC verification, AML reporting, and age-restriction enforcement.
• Legitimate Interests: Processing is necessary for twtplay's legitimate interests — such as fraud prevention, platform security, and responsible gaming monitoring — provided those interests are not overridden by your fundamental rights.
• Consent: For certain processing activities — in particular, direct marketing communications and the use of non-essential cookies — twtplay relies on your freely given, specific, informed, and unambiguous consent. You may withdraw this consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

twtplay does not sell, rent, or trade your personal data to third parties for their own commercial purposes. We may share your personal data with the following categories of recipients, strictly to the extent necessary for the purposes described in this Policy:

• Payment Processors: GCash, Maya, InstaPay, PesoNet, BPI, BDO, Metrobank, 7-Eleven CLiQQ, and other payment service providers require transaction data to process deposits and withdrawals on your behalf.
• Identity Verification Providers: Third-party KYC service providers assist twtplay in verifying the identity and age of members. These providers process your ID documents and verification data under strict data processing agreements.
• Game Content Providers: Third-party game studios whose games are available on the twtplay Platform may receive anonymised or pseudonymised session data to enable game functionality, audit RNG outcomes, and investigate disputed game results.
• Fraud Prevention Services: Specialist fraud detection and risk management providers assist twtplay in identifying suspicious activity, verifying device fingerprints, and detecting multi-accounting behaviour.
• Regulatory Authorities: twtplay may be required by law or regulatory direction to disclose personal data to Philippine government authorities, law enforcement agencies, or judicial bodies. Such disclosures will be made only to the extent legally required.
• Professional Advisers: Lawyers, auditors, accountants, and other professional advisers engaged by twtplay may access personal data on a need-to-know basis and are bound by professional confidentiality obligations.

twtplay uses cookies and similar tracking technologies (including web beacons and pixel tags) to operate, maintain, and improve the Platform. Cookies are small text files placed on your device when you access a website. They help us recognise your browser, remember your session, and analyse how you interact with the Platform.

twtplay uses the following categories of cookies:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable session authentication, fraud prevention, and security features. You cannot opt out of these cookies as they are required for the Platform to operate.
• Performance & Analytics Cookies: These cookies collect anonymised data about how visitors use the Platform — which pages are visited most, how long sessions last, and where errors occur. This information helps twtplay improve the Platform experience for Filipino players.
• Functional Cookies: These cookies remember your preferences — such as your preferred language, lobby layout, and responsible gaming settings — so you do not need to reconfigure them on each visit.
• Marketing Cookies: With your consent, twtplay may use cookies to deliver personalised promotional content within the Platform. We do not use marketing cookies to deliver advertising on third-party websites.

You can manage your cookie preferences through your browser settings or through the twtplay cookie preference centre accessible from the Platform footer. Please note that disabling certain cookies may affect the functionality of the Platform.

twtplay retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, and reporting requirements. The key retention periods applied by twtplay are as follows:

• Active Account Data: Retained for the duration of your account relationship with twtplay and for five (5) years following account closure, in accordance with Philippine AML regulations.
• KYC Verification Documents: Retained for five (5) years following the end of the business relationship, as required under Republic Act No. 9160 (Anti-Money Laundering Act) and its amendments.
• Transaction Records: Retained for five (5) years from the date of each transaction, in line with financial recordkeeping obligations applicable in the Philippines.
• Support Communications: Retained for three (3) years from the date of the last communication, to enable dispute resolution and regulatory audit.
• Marketing Consent Records: Retained for the duration of the consent and for two (2) years following withdrawal, as evidence of the consent obtained.
• Technical & Usage Logs: Retained for thirteen (13) months from collection, then aggregated or deleted.

At the end of the applicable retention period, twtplay will securely delete or anonymise your personal data in accordance with our internal data destruction procedures.

twtplay implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security framework includes:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the twtplay Platform.
• Encryption at rest for all databases storing personal and financial data.
• Two-factor authentication (2FA) available for all member accounts and mandatory for all administrative accounts.
• Continuous real-time monitoring of Platform infrastructure for security anomalies, intrusion attempts, and suspicious access patterns.
• Strict role-based access controls ensuring that twtplay employees access personal data only to the extent required for their specific job function.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Documented incident response procedures, including mandatory notification of the National Privacy Commission (NPC) and affected data subjects in the event of a personal data breach that is likely to result in harm, within the timeframes prescribed by the DPA.

Under the Data Privacy Act of 2012 and its Implementing Rules, as a Filipino data subject you have the following rights in relation to your personal data held by twtplay:

To exercise any of the rights listed above, please contact our Data Protection Officer using the details in Section 14. twtplay will respond to verified requests within fifteen (15) business days. In some cases, we may need to verify your identity before processing a rights request. If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

The twtplay Platform is strictly for adults aged 21 years and above, in accordance with the applicable Philippine regulatory framework governing online casino gaming. twtplay does not knowingly collect personal data from any person under the age of 21.

If twtplay discovers or reasonably suspects that an account has been created by, or on behalf of, a person under 21 years of age, we will immediately suspend the account, conduct an investigation, void all wagers and transactions associated with the account, return any net real-money deposits to the relevant payment method where verifiable, and permanently close the account.

Any personal data inadvertently collected from a minor will be securely deleted without delay upon confirmation of the individual's age. If you believe a minor has registered an account on the twtplay Platform, please contact our support team immediately so we can take prompt action.

Some of twtplay's third-party service providers — including game content suppliers, KYC verification platforms, and fraud prevention services — may process your personal data on servers located outside the Philippines. Where such international transfers occur, twtplay ensures that adequate safeguards are in place to protect your personal data, in accordance with the Data Privacy Act of 2012 and the guidelines issued by the National Privacy Commission.

Safeguards used by twtplay for international transfers include: entering into data transfer agreements with recipient organisations that incorporate the NPC's standard contractual clauses; transferring data only to jurisdictions that the NPC has recognised as providing an adequate level of data protection; and obtaining your explicit consent where required by applicable law.

You may request information about the specific safeguards applied to any international transfer of your personal data by contacting our Data Protection Officer at the address provided in Section 14.

twtplay reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, regulatory requirements, or Platform features. When we make material changes to this Policy, we will notify you by sending an email to your registered email address and/or by posting a prominent notice on the Platform prior to the change taking effect.

The revised Privacy Policy will always display the "Last Updated" date at the top of the page. We encourage you to review this Policy periodically. Your continued use of the twtplay Platform after the effective date of any amendment constitutes your acceptance of the updated Privacy Policy.

If you do not agree with any changes to this Privacy Policy, you must discontinue use of the Platform and contact our support team to request account closure. We will process your closure request and handle any remaining personal data in accordance with our data retention obligations described in Section 8.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way twtplay handles your personal data, please contact our Data Protection Officer using the details below. Our DPO is responsible for overseeing twtplay's compliance with the Data Privacy Act of 2012 and ensuring that your rights as a data subject are upheld.

• Data Controller: twtplay
• Platform: https://twtplay.net
• Email (Data Privacy Enquiries): [email protected]
• Support Availability: 24 hours a day, 7 days a week, including Philippine public holidays
• Response Time: Within 15 business days of receipt of a verified data subject request

If you are not satisfied with twtplay's response to your privacy enquiry or data subject request, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) at www.privacy.gov.ph. The NPC is the independent regulatory authority responsible for the administration and enforcement of the Data Privacy Act of 2012 in the Philippines.