tgcloud Privacy Policy

Introduction

tgcloud ("tgcloud", "we", "us", "our") operates the online gaming platform at tgcloud.asia ("Platform"). We understand that the privacy of our players matters deeply — particularly for Filipino users who entrust us with their personal information when registering an account, completing identity verification, or making financial transactions.

This Privacy Policy explains in plain terms what personal data tgcloud collects, why we collect it, how we use and protect it, who we share it with, how long we keep it, and what rights you have as a data subject under Philippine law. This Policy applies to all users of the tgcloud Platform, including visitors who browse without registering and registered players across Luzon, Visayas, and Mindanao.

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations, which protect the privacy and personal data of Filipino citizens.

Scope and Application

This Privacy Policy applies to all personal data processed by tgcloud in connection with:

• Registration and maintenance of a tgcloud Player Account
• Identity verification and KYC processes
• Deposits, withdrawals, and all financial transactions on the Platform
• Gaming activity, including bets placed, games played, and results recorded
• Customer support interactions via live chat, email, or any other channel
• Promotional activities, bonus claims, and loyalty programme participation
• Browsing and use of the tgcloud.asia website, including by unregistered visitors
• Responsible gaming tool usage and self-exclusion requests

This Policy does not apply to third-party websites, payment processors, or game software providers accessible through or linked from the tgcloud Platform. Those third parties operate under their own privacy practices, which tgcloud does not control.

Personal Data We Collect

tgcloud collects the following categories of personal data, depending on your level of engagement with the Platform:

How We Collect Personal Data

tgcloud collects personal data through the following means:

• Direct input: Information you provide when registering an Account, completing KYC, making deposits or withdrawals, or contacting support
• Automated collection: Technical and usage data collected automatically when you access the Platform, through server logs, cookies, and similar tracking technologies
• Third-party sources: Identity verification data confirmed through KYC service providers; payment confirmation data received from GCash, Maya, BPI, BDO, UnionBank, Coins.ph, and other payment processors
• Game providers: Gaming session data transmitted from third-party game software providers integrated into the tgcloud Platform
• Fraud detection services: Risk signals and device fingerprinting data from security service providers used to protect the integrity of the Platform

Purposes of Processing Your Data

tgcloud processes your personal data for the following specific purposes:

1. Account creation and management: To register, maintain, and administer your tgcloud Player Account, including authentication and session management.
2. Identity verification (KYC): To verify your identity and age (21+ requirement) in compliance with applicable regulations and anti-money laundering obligations.
3. Transaction processing: To process deposits from and withdrawals to your nominated Philippine payment methods (GCash, Maya, BDO, BPI, UnionBank, Coins.ph, and others).
4. Gaming service delivery: To provide access to and record the outcomes of all gaming activity on the Platform, including sports betting, casino games, slots, bingo, sabong, and Fortune Rabbit.
5. Customer support: To respond to your queries, investigate disputes, and resolve issues raised through live chat, email, or other support channels.
6. Security and fraud prevention: To detect, investigate, and prevent fraudulent activity, Account manipulation, multi-accounting, money laundering, and other prohibited conduct.
7. Regulatory compliance: To comply with obligations under Philippine law, PAGCOR regulations, anti-money laundering requirements, and any other applicable legal or regulatory frameworks.
8. Responsible gaming: To monitor gaming patterns for signs of problematic behaviour, administer self-exclusion and deposit limit tools, and facilitate access to responsible gaming support where needed.
9. Marketing and promotions: To send you relevant promotional offers and bonus information, but only where you have provided express consent to receive such communications. You may withdraw consent at any time.
10. Platform improvement: To analyse usage patterns, diagnose technical issues, test new features, and improve the overall tgcloud player experience.

Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012 and its Implementing Rules and Regulations, tgcloud processes your personal data on the following legal grounds:

• Contractual necessity: Processing required to fulfil tgcloud's obligations under the Terms and Conditions you accepted at registration — including Account management, transaction processing, and gaming service delivery
• Legal obligation: Processing required to comply with applicable Philippine law, regulatory requirements from PAGCOR, anti-money laundering regulations, and lawful orders from competent authorities
• Consent: Processing for marketing communications and certain optional features, where you have given explicit consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing
• Legitimate interests: Processing for fraud detection, Platform security, abuse prevention, and internal analytics, where such processing does not override your fundamental rights and interests
• Vital interests: In exceptional circumstances, processing to protect a player's life or safety, particularly in connection with responsible gaming interventions

Data Sharing and Disclosure

tgcloud does not sell, rent, or trade your personal data to any third party. We share personal data only in the following circumstances and only to the extent necessary for the stated purpose:

• Payment processors: GCash, Maya, BDO, BPI, UnionBank, Coins.ph, and other payment channel operators receive transaction data necessary to process your deposits and withdrawals. These parties are independent controllers of data relevant to their own services.
• KYC and identity verification providers: Third-party identity verification services receive your ID documents and selfie data for the sole purpose of verifying your identity and age for compliance purposes.
• Game software providers: Gaming session data is shared with integrated game providers (such as PG Soft, Pragmatic Play, Evolution Gaming, Jili, and others) to the extent necessary to deliver the game and record outcomes.
• Fraud detection and security services: Technical data and risk signals may be shared with security service providers for the purpose of detecting fraud, multi-accounting, and other prohibited conduct.
• Regulatory authorities: tgcloud will disclose personal data to PAGCOR, the National Privacy Commission, law enforcement agencies, or other competent Philippine authorities when required by law, regulatory order, or lawful request.
• Professional advisors: Legal counsel, auditors, and compliance consultants may access limited personal data under confidentiality obligations where necessary to provide professional services to tgcloud.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of tgcloud's assets, player data may be transferred to the acquiring entity, subject to this Privacy Policy continuing to apply or equivalent protections being put in place.

International Data Transfers

Some of tgcloud's service providers — including game software providers, cloud infrastructure partners, and KYC technology vendors — may process personal data in jurisdictions outside the Philippines. Where such cross-border data transfers occur, tgcloud takes the following steps to ensure your data remains protected:

• Transfer only to jurisdictions assessed as providing adequate data protection, or to providers certified under equivalent internationally recognised frameworks
• Implementation of contractual data processing agreements with receiving parties that impose data protection obligations consistent with the Philippine Data Privacy Act
• Application of technical safeguards including encryption in transit and at rest for all transferred data
• Regular review of cross-border transfer arrangements to ensure continuing adequacy of protections

By using the tgcloud Platform, you acknowledge that your personal data may be transferred, stored, and processed in countries outside the Philippines as described above, subject to the protections outlined in this section.

Data Retention Periods

tgcloud retains personal data for no longer than is necessary for the purposes for which it was collected, taking into account applicable legal and regulatory retention obligations. The following general retention guidelines apply:

• Account data and KYC records: Retained for the duration of your active Account plus a minimum of 5 years following Account closure, in compliance with anti-money laundering record-keeping requirements
• Transaction records: Retained for a minimum of 5 years following the transaction date, consistent with Philippine financial record-keeping regulations
• Gaming activity records: Retained for 5 years following the relevant gaming session, for dispute resolution and regulatory compliance purposes
• Customer support communications: Retained for 3 years following the resolution of the relevant query or dispute
• Marketing consent and communication records: Retained for the duration of the consent period plus 1 year following withdrawal of consent or Account closure
• Technical and usage logs: Retained for up to 12 months, unless required for longer periods by an ongoing security investigation

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data. Anonymised and aggregated analytics data may be retained indefinitely as it no longer constitutes personal data.

Data Security Measures

tgcloud implements technical, organisational, and physical security measures designed to protect your personal data against unauthorised access, loss, alteration, or disclosure. Key security measures include:

• 256-bit SSL/TLS encryption: All data transmitted between your device and tgcloud servers is encrypted using the same standard used by Philippine banks for online banking
• Encryption at rest: Sensitive personal data including KYC documents, ID numbers, and financial account details are encrypted at rest in tgcloud's data stores
• Two-factor authentication (2FA): Available to all players and required for certain internal administrative functions, adding a layer of protection against credential compromise
• Access controls: Personal data access within tgcloud is restricted on a strict need-to-know basis, with role-based access controls and audit logging of all access to sensitive data
• Regular security assessments: tgcloud conducts periodic security reviews and vulnerability assessments of Platform infrastructure and data handling processes
• Breach response procedures: tgcloud maintains documented data breach response procedures, including notification protocols consistent with obligations under the National Privacy Commission's breach notification requirements

Cookies and Tracking Technologies

tgcloud uses cookies and similar technologies to operate the Platform, maintain your session, and understand how the Platform is used. The types of cookies used are:

• Strictly necessary cookies: Required for the Platform to function. These include session cookies that keep you logged in between pages and security cookies that protect against cross-site request forgery. These cannot be disabled without breaking Platform functionality.
• Functional cookies: Remember your preferences — such as language settings, preferred view layouts, and recently played games — to provide a more personalised experience.
• Analytics cookies: Collect anonymous usage data to help tgcloud understand how players navigate the Platform, identify technical issues, and improve the overall experience. Data is processed in aggregated, anonymised form.
• Security cookies: Used by tgcloud's fraud detection systems to identify anomalous access patterns, detect bot activity, and protect against account takeover attempts.

Most web browsers allow you to control cookies through browser settings. Disabling all cookies may affect Platform functionality, including login and session persistence. tgcloud does not use third-party advertising or tracking cookies.

Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by tgcloud:

To exercise any of these rights, contact tgcloud via live chat or email (details in Section 16). tgcloud will acknowledge your request within 3 business days and aim to fulfil it within 30 days. Some rights may be limited where data processing is required for regulatory compliance or legal obligations that take precedence.

Minors and Age Restriction

tgcloud strictly prohibits access to and use of the Platform by any person under the age of 21. The tgcloud Platform is not directed at, and does not knowingly collect personal data from, individuals under 21 years of age.

If tgcloud discovers that an Account has been created by a person under 21, the Account will be immediately closed, all associated personal data will be deleted or anonymised (except where retention is required for regulatory compliance), and any deposits will be returned in accordance with applicable regulations.

Third-Party Services and External Links

The tgcloud Platform integrates third-party services for specific functions — including game software providers (PG Soft, Pragmatic Play, Evolution Gaming, Jili, JDB, Spadegaming, and others), payment processors (GCash, Maya, BDO, BPI, UnionBank, Coins.ph), and KYC verification providers. These third parties operate as independent data controllers or processors with their own privacy practices.

tgcloud selects third-party service providers carefully and requires them to maintain appropriate data security standards under contractual data processing agreements. However, tgcloud is not responsible for the privacy practices of third-party providers operating their own independent services.

When you interact with a third-party game within the Platform, session data including game actions, bets, and outcomes is transmitted to the game provider's servers. tgcloud receives and stores aggregated outcomes for Account balance purposes. The granular game event data processed by providers is subject to their own privacy policies.

Changes to This Privacy Policy

tgcloud reserves the right to update, modify, or replace this Privacy Policy at any time to reflect changes in our data practices, legal obligations, regulatory requirements, or Platform features. The effective date at the top of this document will be updated to reflect the date of the latest revision.

For material changes to this Policy — those that significantly affect how we use your personal data or your rights as a data subject — tgcloud will provide advance notice through one or more of the following channels: in-Platform notification displayed upon login, email to your registered address, or SMS to your registered mobile number.

Continued use of the tgcloud Platform after the stated effective date of a revised Privacy Policy constitutes acceptance of the revised terms. If you do not accept the revised Policy, you should cease using the Platform and may request Account closure.

The current version of this Privacy Policy is always available at tgcloud.asia/privacy-policy. Earlier versions may be requested from tgcloud support for reference.

Contact Us — Data Privacy Inquiries

For all privacy-related inquiries, data subject rights requests, or concerns about tgcloud's handling of your personal data, please use the following contact channels:

• Live Chat: Available 24/7 via the chat widget on tgcloud.asia. For urgent matters including suspected data breaches or unauthorised Account access. Average response under 2 minutes.
• Email: [email protected] — for formal written privacy inquiries and data subject rights requests. Please include "Privacy Inquiry" in your subject line. Response within 4 hours.

tgcloud will acknowledge receipt of all formal privacy inquiries within 3 business days. Complex data subject rights requests, including access and portability requests, will be fulfilled within 30 days of identity verification. If tgcloud requires additional time, you will be notified before the initial 30-day period expires.

If you believe tgcloud has not addressed your privacy concerns adequately, you have the right to lodge a complaint with the National Privacy Commission of the Philippines, which is the competent supervisory authority for data protection matters in the Philippines.