tttjl Privacy Policy

Introduction

tttjl ("we", "us", "our") operates the online casino and sports betting platform accessible at tttjl.bet (the "Platform"). We are committed to protecting the privacy and personal data of every player who registers and uses the tttjl Platform, in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and all relevant issuances of the National Privacy Commission (NPC).

This Privacy Policy describes what personal data tttjl collects from you, why we collect it, how it is used, who it may be shared with, how long it is retained, and what rights you have in relation to your data. It applies to all users of the tttjl Platform, including registered players, visitors who browse the Platform without registering, and individuals who contact tttjl's support team.

By accessing or using the tttjl Platform, you confirm that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein. This Policy should be read alongside the tttjl Terms & Conditions and Responsible Gaming Policy.

Data Controller

For the purposes of the Philippine Data Privacy Act of 2012, tttjl is the Personal Information Controller (PIC) in respect of the personal data collected from users of the tttjl Platform. As PIC, tttjl determines the purposes and means by which your personal data is processed.

Where tttjl engages third-party service providers to process personal data on its behalf — such as KYC verification providers, payment processors, and fraud detection services — those third parties act as Personal Information Processors (PIPs) and are contractually bound to process data only in accordance with tttjl's documented instructions and applicable Philippine data privacy law.

tttjl has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with data privacy obligations and serving as the point of contact for data subjects. Contact details for the DPO are provided in Section 16 of this Policy.

Personal Data We Collect

tttjl collects personal data in the following categories, depending on how you interact with the Platform:

3.1 Registration & Account Data

When you create a tttjl Account, we collect: full legal name; date of birth; Philippine mobile number; email address; username; and account password (stored in hashed, non-reversible form).

3.2 Identity Verification (KYC) Data

To comply with PAGCOR requirements and Philippine AML law, we collect: government-issued ID document type and number (UMID, PhilSys National ID, passport, or driver's licence); a photograph or scan of that document; a live selfie or photo for biometric comparison; and, where required, proof of address and source-of-funds documentation.

3.3 Financial & Transaction Data

We collect: GCash mobile number; PayMaya account reference; bank account details (BPI, BDO, Metrobank) where provided for withdrawal; deposit and withdrawal transaction history; account balance history; and payment method verification data.

3.4 Gaming Activity Data

We record: games played and bet history; wagering amounts and outcomes; session durations; responsible gaming tool settings (deposit limits, cooling-off periods, self-exclusion status); and promotional bonus activity.

3.5 Technical & Device Data

We automatically collect when you access the Platform: IP address; device type, operating system, and browser version; session tokens; approximate geographic location derived from IP; and platform access timestamps.

3.6 Communications Data

We retain records of: live chat and email support interactions; notifications sent to your registered mobile number and email address; and any correspondence you initiate with tttjl regarding account queries, disputes, or complaints.

How We Use Your Personal Data

tttjl processes your personal data for the following purposes:

Legal Basis for Processing

tttjl processes personal data under one or more of the following legal bases as recognised under the Philippine Data Privacy Act of 2012:

• Consent (Section 12(a) RA 10173): Processing where you have given clear, specific, informed, and freely given consent — primarily for marketing communications. You may withdraw consent at any time without affecting the legality of prior processing.
• Contractual Necessity (Section 12(b)): Processing required to enter into or perform the contract between you and tttjl — including account operations, payment processing, and game delivery.
• Legal Obligation (Section 12(c)): Processing required by applicable Philippine law — including KYC under PAGCOR regulations, AML reporting under RA 9160 as amended, and data breach notification obligations under RA 10173.
• Legitimate Interest (Section 12(f)): Processing necessary for tttjl's legitimate interests — including fraud detection, platform security, abuse prevention, and aggregated analytics — provided those interests are not overridden by your privacy rights.

Where processing is based on consent, you have the right to withdraw that consent at any time by updating your communication preferences in Account Settings or by contacting the tttjl Data Protection Officer.

Data Sharing & Third Parties

tttjl does not sell, rent, or trade your personal data. We share personal data only in the following circumstances and only to the extent necessary:

6.1 Service Providers (Personal Information Processors)

We engage third-party processors to assist with platform operations. Each processor is bound by a written data processing agreement requiring them to process data only on tttjl's documented instructions and to implement appropriate security measures. Categories of processors include:

• KYC and identity verification providers
• Payment gateway operators (GCash, PayMaya integrations) and Philippine banking partners
• Fraud detection and anti-money laundering screening services
• Cloud hosting and data centre providers (servers in the Philippines and nearby regions)
• Customer support platform operators
• Game software providers (game-level session data only, no financial or KYC data)

6.2 Legal & Regulatory Disclosure

tttjl may disclose personal data to Philippine regulatory authorities, law enforcement agencies, courts, or government bodies where: (a) required to do so by applicable law or a valid legal order; (b) necessary to comply with PAGCOR or NPC directives; or (c) necessary to prevent, detect, or prosecute illegal activity including money laundering or fraud.

6.3 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of tttjl's business, personal data held by tttjl may be transferred to the relevant successor entity. You will be notified of any such transfer and of any material change to the privacy arrangements applicable to your data before the transfer takes effect.

Cross-Border Data Transfers

tttjl primarily stores and processes personal data within the Philippines and nearby Southeast Asian regions. Where personal data is transferred to a country outside the Philippines, tttjl ensures that appropriate safeguards are in place to protect your data, including:

• Transfers to countries recognised by the NPC as providing an adequate level of data protection
• Standard Contractual Clauses (SCCs) approved by the NPC or an equivalent regulatory body in the recipient jurisdiction
• Binding corporate rules where the recipient is an affiliate of tttjl's corporate group

You may request information about the specific safeguards applicable to any cross-border transfer of your data by contacting the tttjl Data Protection Officer at the details provided in Section 16.

Retention Periods

tttjl retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. Key retention periods are as follows:

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised using industry-standard methods. Anonymised data that cannot be re-associated with an individual may be retained indefinitely for aggregated analytics purposes.

Security Measures

tttjl implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Encryption in transit: All data transmitted between your device and tttjl's servers is encrypted using TLS 1.2 or higher (256-bit SSL).
• Encryption at rest: Personal data stored in tttjl's databases is encrypted at rest using industry-standard algorithms.
• Access controls: Access to personal data is restricted on a need-to-know basis. Staff who handle personal data are subject to confidentiality obligations and undergo regular privacy and security training.
• Multi-factor authentication: Internal systems holding personal data require multi-factor authentication for administrative access.
• Intrusion detection: tttjl maintains active monitoring for unauthorised access attempts, unusual traffic patterns, and potential security incidents.
• Penetration testing: Periodic third-party security assessments are conducted to identify and remediate vulnerabilities in tttjl's infrastructure.
• Vendor security requirements: All third-party processors are required to demonstrate equivalent security standards before being engaged, and are subject to ongoing monitoring.

While tttjl takes all reasonable measures to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the security of your Account credentials and for notifying tttjl immediately if you suspect any unauthorised access to your Account.

Cookies & Tracking Technologies

tttjl uses cookies and similar tracking technologies on the Platform for the following purposes:

10.1 Strictly Necessary Cookies

These cookies are required for the Platform to function correctly. They manage your login session, maintain your authentication state, remember your language preference, and ensure security tokens are validated correctly. These cookies cannot be disabled without breaking the Platform's core functionality.

10.2 Functional Cookies

These cookies remember your preferences and customisation choices — such as your preferred game lobby view, responsible gaming settings, and notification preferences — so that you do not need to re-enter them on each visit.

10.3 Analytics Cookies

tttjl uses aggregated, anonymised analytics data to understand how players navigate the Platform, which features are used most frequently, and where user experience can be improved. Analytics data collected by tttjl does not identify you as an individual.

10.4 Managing Cookies

You can manage cookie preferences through your browser's settings. Note that disabling strictly necessary cookies will impair or prevent your ability to log in and use the tttjl Platform. Disabling functional or analytics cookies will not prevent you from accessing real-money games but may affect your personalisation experience.

Children & Minors — 21+ Only

The tttjl Platform is strictly intended for persons aged twenty-one (21) years and above, in compliance with PAGCOR regulations governing online gambling in the Philippines. tttjl does not knowingly collect, process, or retain personal data from individuals under the age of 21.

All account registrations require mandatory KYC age verification before real-money access is granted. Where tttjl discovers that a user under the age of 21 has provided personal data and accessed the Platform, the account will be immediately suspended, all data associated with the account will be deleted to the extent not required for legal or regulatory compliance, and any funds associated with the account will be handled in accordance with tttjl's underage access policy.

Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in respect of your personal data held by tttjl. To exercise any of these rights, contact the tttjl Data Protection Officer as described in Section 16.

Marketing Communications & Opt-Out

With your consent, tttjl may send you promotional communications about tttjl offers, new game launches, seasonal promotions, and loyalty programme updates via SMS, push notification, and email. All marketing communications are sent to Filipino players in English.

You may opt out of marketing communications at any time by: (a) updating your notification preferences in Account Settings; (b) clicking the unsubscribe link included in any marketing email; (c) replying STOP to any promotional SMS; or (d) contacting tttjl support via live chat.

Opting out of marketing communications will not affect your receipt of transactional communications — such as deposit confirmations, withdrawal notifications, security alerts, and account-related notifications — which are necessary for the operation of your Account and cannot be disabled while your Account is active.

Data Breach Response

In the event that tttjl discovers or reasonably suspects a personal data breach, we will follow the following incident response procedure:

1. Containment: Upon discovery, affected systems are isolated and the breach is contained to prevent further unauthorised access or data exposure.
2. Assessment: The scope, nature, and likely impact of the breach are assessed. A determination is made as to whether the breach poses a real risk to the rights and freedoms of affected data subjects.
3. Regulator Notification: Where the breach is confirmed to pose a real risk, tttjl will notify the National Privacy Commission (NPC) within seventy-two (72) hours of confirmed discovery, as required by NPC Circular No. 16-03.
4. Player Notification: Affected players will be notified without undue delay where the breach is likely to result in high risk to their personal data rights. Notification will include: the nature of the breach; the data categories affected; steps taken by tttjl to address the breach; and recommended protective actions for affected players.
5. Remediation: tttjl will implement corrective technical and organisational measures to prevent recurrence and document the incident in accordance with RA 10173 requirements.

Policy Amendments

tttjl reserves the right to amend this Privacy Policy at any time to reflect changes in applicable law, NPC guidance, platform operations, or industry best practice. Where changes are material, tttjl will notify registered players via their registered email address or mobile number at least seven (7) days before the updated Policy takes effect.

The current version of this Privacy Policy, together with its effective date, is always accessible at tttjl.bet/privacy-policy. Your continued use of the Platform after the effective date of a revised Policy constitutes your acceptance of the updated terms. If you do not accept the revised Policy, you must close your Account before the changes take effect.

Contact & Data Protection Officer

For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by tttjl, please contact the tttjl Data Protection Officer through the following channels:

• Live Chat: Available 24/7 via the tttjl Platform — request the Data Privacy team specifically
• Email: [email protected] — subject line: "Data Privacy Request"
• Support Language: English and Tagalog
• Response Time: Within 15 calendar days of a verified request

If you are not satisfied with tttjl's response to your data privacy concern, or if you believe tttjl has processed your personal data in violation of the Philippine Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.