th444 Privacy Policy

01 Scope & Application

This Privacy Policy applies to all personal data processed by th444 in connection with the operation of the th444 online casino and sports betting platform accessible at th444.org and any associated subdomains or mobile-optimised versions thereof. It applies to all individuals who access, browse, register on, or otherwise interact with the th444 Platform, including registered players, prospective players who visit the Platform without registering, and individuals who contact th444 Support.

This Privacy Policy should be read together with the th444 Terms and Conditions, which set out the contractual framework governing your use of the Platform. By using the Platform, you confirm that you have read and understood this Privacy Policy and agree to the processing of your personal data as described herein.

02 Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection legislation, th444 acts as the Personal Information Controller (PIC) with respect to all personal data collected and processed through the Platform. As the PIC, th444 determines the purposes and means of the processing of players' personal data.

Where th444 engages third-party service providers — including KYC verification partners, payment processors, and game software providers — to process personal data on its behalf, those entities act as Personal Information Processors (PIPs) and are bound by data processing agreements that restrict their use of personal data to the specific services they provide to th444. th444 retains responsibility for ensuring that its PIPs process personal data in accordance with this Privacy Policy and applicable law.

The th444 Data Protection Officer (DPO) may be contacted via the contact details set out in Section 14 of this Policy for any matter relating to personal data processing, data subject rights, or privacy concerns.

03 Personal Data We Collect

th444 collects the following categories of personal data from players and Platform users, to the extent necessary for the purposes described in Section 5:

th444 does not knowingly collect sensitive personal information beyond what is necessary for identity verification and regulatory compliance. Where sensitive personal information (as defined under the DPA) is collected — such as biometric data from KYC selfie images — it is processed solely for the purpose of age and identity verification and is not used for any other purpose.

04 How We Collect Personal Data

th444 collects personal data through the following methods:

• Direct Collection: Information you provide when you register an Account, complete KYC verification, make a deposit or withdrawal, contact Customer Support, respond to a survey, or update your Account settings.
• Automated Technical Collection: Technical data collected automatically when you access or use the Platform, including through cookies, session trackers, device identification scripts, and server log files. See Section 8 for details on cookies and tracking technology.
• Third-Party Verification Partners: Identity and age verification data returned by th444's certified KYC partners after you submit identification documents. th444 receives verification status and confidence scores; raw biometric processing is performed by the KYC partner under strict data processing agreements.
• Payment Service Providers: Transaction confirmation data from GCash, Maya, BDO, BPI, UnionBank, Coins.ph, and other approved payment processors, used to reconcile deposits and withdrawals against your Golden Bank Wallet balance.
• Regulatory and Law Enforcement Bodies: In limited circumstances, th444 may be required to receive or share data with government agencies, the Anti-Money Laundering Council (AMLC), or law enforcement authorities pursuant to a valid legal order or regulatory obligation.

05 Purpose of Processing & Legal Basis

th444 processes personal data for the following purposes, each supported by a lawful basis under the Data Privacy Act of 2012:

1. Account Registration and Platform Access — To create and manage your th444 Account, verify your identity, enable login, and provide access to all Platform features. Legal basis: performance of a contract.
2. Age and Identity Verification (KYC) — To verify that you are at least 21 years of age and that your identity is consistent with your Account registration information, in compliance with applicable online gaming and anti-money laundering regulations. Legal basis: compliance with a legal obligation; legitimate interests.
3. Payment Processing — To process deposits and withdrawals through approved payment channels and to maintain accurate transaction records in your Golden Bank Wallet. Legal basis: performance of a contract; compliance with a legal obligation.
4. Fraud Prevention and Security — To detect and prevent fraud, unauthorized account access, money laundering, and other prohibited activity, including through automated monitoring systems and manual review. Legal basis: legitimate interests; compliance with a legal obligation.
5. Responsible Gaming Compliance — To monitor gaming activity for signs of problem gambling, apply player-set limits, facilitate self-exclusion requests, and fulfil responsible gaming obligations. Legal basis: legitimate interests; compliance with regulatory requirements.
6. Customer Support — To respond to player enquiries, resolve complaints, and maintain records of support interactions for quality assurance and dispute resolution. Legal basis: performance of a contract; legitimate interests.
7. Marketing and Promotions — To send promotional communications, bonus notifications, and Platform updates to players who have opted in to receive them. Legal basis: consent. Players may withdraw consent at any time without penalty.
8. Platform Improvement and Analytics — To analyse Platform usage patterns, improve user experience, test new features, and measure the effectiveness of promotions, using aggregated or pseudonymised data where possible. Legal basis: legitimate interests.

06 Sharing of Personal Data

th444 does not sell, rent, or trade personal data to any third party for commercial or marketing purposes. Personal data is shared with third parties only to the extent necessary and only in the following circumstances:

• Payment Service Providers: GCash (G-Xchange, Inc.), Maya (Voyager Innovations, Inc.), BDO Unibank, Inc., Bank of the Philippine Islands, UnionBank of the Philippines, 7-Eleven Cliqq, and other approved payment processors receive transaction data strictly necessary to execute deposits and withdrawals.
• KYC Verification Partners: Certified identity verification service providers receive submitted identity documents and selfie images for the sole purpose of age and identity verification. These providers are contractually prohibited from using this data for any other purpose.
• Game Software Providers: Certified game studios may receive pseudonymised player identifiers and bet/win data necessary for the real-time operation of their games and to maintain game integrity certifications. Personal identity data is not shared with game providers.
• Regulatory and Law Enforcement Authorities: th444 will disclose personal data to the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), law enforcement agencies, or any other competent Philippine government authority where required to do so by law, regulation, or valid legal process.
• Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by th444 may access personal data on a strictly need-to-know basis and are bound by confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or corporate restructuring involving th444, personal data held by th444 may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. Players will be notified of any such transfer in advance.

All third parties with whom th444 shares personal data are required to maintain appropriate technical and organisational security measures and to process personal data only for the purposes specified by th444.

07 Data Retention

th444 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law, whichever is the longer period. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of the Account and for a minimum of five (5) years after Account closure, in compliance with applicable AML and online gaming regulatory record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, consistent with AMLA obligations and standard financial record-keeping requirements in the Philippines.
• KYC Documents: Identity documents and verification records are retained for five (5) years after the last active use of the Account, or as required by applicable regulations.
• Gaming Activity Data: Session logs and game history are retained for three (3) years after the date of the relevant session, used for dispute resolution, fraud investigation, and responsible gaming monitoring.
• Support Communications: Live chat transcripts and email correspondence are retained for two (2) years from the date of the interaction for quality assurance and dispute resolution purposes.
• Marketing Consent Records: Records of marketing consent and opt-out events are retained for three (3) years from the date of the consent action or until the Account is permanently closed.
• Technical and Log Data: Server log files and technical session data are retained for ninety (90) days, after which they are automatically deleted unless required for an active security investigation.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be linked to an identified or identifiable individual. Anonymised and aggregated analytical data derived from player activity may be retained indefinitely as it no longer constitutes personal data.

08 Cookies & Tracking Technologies

th444 uses cookies and similar tracking technologies to operate the Platform, maintain your session, and improve your experience. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the Platform to function. These cookies enable session management, authentication state, and security features including CSRF protection. They cannot be disabled without preventing access to the Platform. No consent is required for these cookies.
• Functional Cookies: Store your preferences such as language settings, game lobby view preferences, and notification settings. These improve your experience but are not essential to Platform operation.
• Analytical Cookies: Used to collect aggregated information about how players interact with the Platform — which pages are visited most, session duration, and navigation paths. This data is used to improve Platform performance and user experience. Analytical data is processed in aggregated, non-identifying form where possible.
• Security Cookies: Used to detect and prevent fraudulent activity, including login anomalies and suspected automated access attempts. These work in conjunction with device fingerprinting and IP monitoring systems.

th444 does not use third-party advertising cookies or permit third-party ad networks to set cookies through the Platform. Players may manage cookie preferences through their browser settings. Note that disabling strictly necessary cookies will prevent Platform access. All other cookie categories may be disabled without loss of core Platform functionality, though some features may not operate as intended.

09 Security Measures

th444 implements the following technical and organisational security measures to protect personal data against unauthorised access, loss, destruction, alteration, or disclosure:

• Transport Layer Security (TLS 1.3) with 256-bit encryption on all data transmissions between client devices and th444 servers.
• At-rest encryption of databases containing personal data, financial records, and KYC documents using AES-256 encryption.
• Access controls limiting personal data access to th444 personnel and authorised system components that require it for their designated functions, enforced through role-based access management.
• Two-factor authentication (2FA) available to all players for Account access, and required for all administrative system access by th444 personnel.
• Regular penetration testing and vulnerability assessments conducted by independent security specialists.
• Automated monitoring systems that detect and alert on anomalous login activity, unusual data access patterns, and potential security incidents.
• Secure disposal procedures for data that has reached the end of its retention period, including cryptographic erasure of encrypted storage volumes.

10 Your Rights as a Data Subject

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by th444:

1. Right to be Informed — The right to be informed of how your personal data is collected, processed, and retained, which is fulfilled by this Privacy Policy.
2. Right of Access — The right to request a copy of the personal data th444 holds about you. Requests will be fulfilled within fifteen (15) business days of verification of your identity.
3. Right to Correction — The right to request correction of inaccurate, incomplete, or outdated personal data. Many personal details can be updated directly through your Account settings; for other corrections, contact th444 Support.
4. Right to Erasure / Right to be Forgotten — The right to request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you have withdrawn consent and there is no other lawful basis for continued processing. Note that th444 is legally required to retain certain data (financial records, KYC documents) for regulatory compliance periods regardless of erasure requests.
5. Right to Object — The right to object to the processing of your personal data for purposes based on legitimate interests or for direct marketing purposes. Upon receipt of a valid objection to marketing processing, th444 will cease marketing communications without delay.
6. Right to Data Portability — The right to receive a structured, commonly used, and machine-readable copy of the personal data you have provided to th444, where technically feasible.
7. Right to Lodge a Complaint — The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that th444 has processed your personal data in a manner that violates the Data Privacy Act of 2012.

To exercise any of the above rights, players should contact th444 Support via live chat or at [email protected]. th444 may request proof of identity before processing data subject rights requests to prevent unauthorised disclosure of personal data. All requests will be acknowledged within five (5) business days.

11 Children and Minors

th444 is strictly prohibited to persons under the age of 21. The Platform does not knowingly collect personal data from individuals under 21 years of age. Age verification is performed as part of the KYC process for all registered accounts, and accounts found to belong to persons under 21 will be closed immediately upon discovery.

If th444 becomes aware that personal data belonging to a person under 21 has been collected, that data will be deleted without undue delay and the associated Account will be permanently closed. Any deposits associated with a minor's Account will be returned to the originating payment method.

If you are a parent or guardian and believe that a person under 21 has registered an Account with th444, please contact th444 Support immediately via live chat or at [email protected] with relevant details. th444 will investigate and respond within 24 hours.

12 Third-Party Links

The th444 Platform does not contain links to external third-party websites other than as described in these policies. In the event that Platform content references or links to any third-party website or service, th444 is not responsible for the privacy practices or data handling of those third parties and provides no warranty or assurance regarding their data protection standards.

Players who access third-party services — including their e-wallet applications (GCash, Maya), banking platforms (BDO, BPI, UnionBank), or mobile operating system stores — in connection with their use of th444 should review the privacy policies of those respective services independently. th444's Privacy Policy applies solely to data processing conducted by th444 on the th444 Platform.

13 Amendments to This Policy

th444 reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, or th444's data processing practices. The effective date and last revised date displayed at the top of this page will be updated upon each revision.

Where amendments are material — including any changes to the categories of data collected, the purposes for which data is processed, or the rights available to data subjects — th444 will provide advance notice to registered players via in-platform notification or email to their registered contact address at least seven (7) days before the changes take effect.

Continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Privacy Policy. If you do not accept any material amendment, you should close your Account and discontinue use of the Platform before the amendment takes effect. Account closure instructions are available through th444 Support.

14 Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or th444's handling of your personal data, please contact th444 through the following channels:

• Live Chat: Available 24/7 within the th444 Platform after login. For privacy-related enquiries, identify your request as a "Data Privacy Matter" at the start of the chat for routing to the appropriate team.
• Email: [email protected] — For formal data subject rights requests, privacy complaints, and DPO correspondence. Subject your email "Privacy Policy Enquiry" or "Data Subject Request" as appropriate.

th444 will acknowledge all privacy-related enquiries within 24 hours and will provide a substantive response within fifteen (15) business days. Complex requests — including large-volume access requests or erasure requests requiring regulatory review — may take up to thirty (30) business days. Players will be kept informed of progress.