tttjl Privacy Policy

1.1   This Policy applies to all personal data collected by tttjl in connection with the operation of the tttjl platform, including data collected through account registration, gameplay, financial transactions, customer support interactions, marketing communications, and your use of any tttjl digital properties.

1.2   This Policy should be read together with the tttjl Terms and Conditions and the tttjl Responsible Gaming Policy, both of which are incorporated by reference. By creating an Account on tttjl or by continuing to use the Platform after this Policy has been made available to you, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

1.3   tttjl operates exclusively in the Philippines under PAGCOR authorization. This Policy reflects the requirements of Philippine data protection law as the primary applicable legal framework. Where tttjl processes data of residents of other jurisdictions, additional jurisdiction-specific terms may apply as communicated at the point of data collection.

For the purposes of this Policy, the following definitions apply:

• "Personal Data" means any information from which the identity of an individual is apparent or can reasonably be ascertained, including but not limited to name, mobile number, email address, date of birth, government ID numbers, and financial account details.
• "Sensitive Personal Information" has the meaning given in Section 3(l) of RA 10173, and includes information about race, ethnic origin, religious beliefs, health, education, genetic and sexual life, and government-issued identification numbers.
• "Processing" means any operation or set of operations performed upon personal data, including collection, recording, organization, storage, updating, retrieval, use, consolidation, blocking, erasure, or destruction.
• "Data Controller" means tttjl, which determines the purposes and means of processing personal data collected through the Platform.
• "Data Processor" means any third party that processes personal data on behalf of tttjl under a contractual data processing agreement.
• "DPO" means tttjl's designated Data Protection Officer, registered with the National Privacy Commission in accordance with NPC Registration Circular No. 17-01.

3.1   tttjl is the Data Controller for all personal data processed through the tttjl platform. tttjl has appointed a Data Protection Officer ("DPO") who is responsible for overseeing compliance with this Policy and with applicable Philippine data protection law.

3.2   tttjl's DPO can be contacted through the support channels specified in Section 15 of this Policy. All data rights requests, privacy inquiries, and complaints relating to tttjl's processing of personal data should be directed to the DPO in the first instance.

4.1   tttjl collects personal data through several channels. The categories of data collected and the primary source of each are set out in the table below:

4.2   tttjl does not knowingly collect Sensitive Personal Information beyond what is required for KYC compliance under PAGCOR regulatory requirements and applicable Philippine anti-money laundering law. Where such collection is unavoidable, additional protective measures are applied as described in Section 10.

5.1   tttjl processes your personal data for the following specific, legitimate purposes:

• Account Management: Creating, verifying, maintaining, and securing your tttjl Account, including processing login authentication and two-factor verification.
• Identity Verification (KYC): Verifying your identity and age (minimum 21 years) in compliance with PAGCOR requirements and Philippine Anti-Money Laundering Act (AMLA) obligations.
• Transaction Processing: Processing deposits, withdrawals, and internal fund transfers through GCash, PayMaya, and Philippine banking channels.
• Regulatory Compliance: Fulfilling tttjl's obligations under PAGCOR licensing conditions, RA 9160 (Anti-Money Laundering Act), RA 10927 (AMLA extension to casinos), and other applicable Philippine laws.
• Customer Support: Responding to your inquiries, resolving disputes, processing complaints, and administering account recovery.
• Responsible Gaming: Monitoring gaming activity to identify and intervene on potential problem gambling behavior, implementing self-exclusion and account restriction tools.
• Fraud Prevention and Security: Detecting and preventing unauthorized account access, fraudulent transactions, money laundering, and other prohibited conduct.
• Platform Improvement: Analyzing aggregated, anonymized usage data to improve the tttjl platform's features, performance, and user experience.
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates to Players who have given their consent to receive such communications, with an opt-out mechanism provided in every communication.

5.2   tttjl will not process your personal data for any purpose that is incompatible with the purposes listed above without obtaining your separate, explicit consent prior to that processing, except where processing is required by applicable Philippine law.

6.1   tttjl processes personal data under one or more of the following legal bases as recognized under Section 12 and Section 13 of RA 10173:

7.1   tttjl does not sell, rent, or trade your personal data to any third party for commercial purposes. Personal data is shared with third parties only in the following circumstances:

• Payment Processors: GCash (GXI Corp.), PayMaya (Maya Philippines), BPI, BDO, Metrobank, UnionBank, and other approved payment service providers, for the sole purpose of processing your financial transactions. All payment processors are bound by contractual data processing agreements and applicable BSP regulations.
• KYC Verification Providers: Third-party identity verification service providers engaged by tttjl to perform document authentication and liveness checks in compliance with PAGCOR's KYC requirements. These providers process your identity data solely on tttjl's instructions.
• Game Studios and Content Providers: Licensed game studios whose products are offered on the tttjl platform may receive anonymized session data necessary for game performance reporting and RNG audit purposes. No identifiable personal data is shared with game studios beyond what is required for regulatory audit trails.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine government authorities, where disclosure is required by law, court order, or regulatory directive.
• Professional Advisors: Legal counsel, auditors, and compliance consultants engaged by tttjl under strict confidentiality obligations, where access to personal data is necessary for the provision of professional services.
• Business Transfers: In the event of a merger, acquisition, or sale of tttjl's business or assets, personal data may be transferred to the acquiring entity, subject to the same data protection obligations and with advance notification to affected Players.

7.2   All third-party Data Processors engaged by tttjl are required to implement data protection standards equivalent to those described in this Policy as a contractual condition of their engagement.

8.1   tttjl's primary operations are based in the Philippines and personal data is processed primarily within Philippine territory. Where tttjl engages service providers whose processing infrastructure is located outside the Philippines — such as certain cloud hosting providers or international game studios — any such cross-border transfer of personal data is subject to the requirements of Section 21 of RA 10173 and the NPC's applicable transfer rules.

8.2   Cross-border transfers by tttjl are conducted only to countries or organizations that provide an adequate level of data protection as determined by the NPC, or where appropriate contractual safeguards (such as the NPC's standard contractual clauses) are in place between tttjl and the recipient entity.

8.3   Where you would like information about the specific safeguards applied to any cross-border transfer of your personal data, you may request this from tttjl's DPO using the contact details in Section 15.

9.1   tttjl retains personal data for the minimum period necessary to fulfill the purpose for which it was collected and to meet applicable legal and regulatory retention obligations. The following retention periods apply as a general framework:

9.2   Upon expiry of the applicable retention period, personal data is securely deleted or, where deletion is not technically feasible, irreversibly anonymized so that it can no longer be associated with any identifiable individual.

10.1   tttjl implements a comprehensive set of technical, organizational, and physical security measures to protect personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include but are not limited to:

• AES-256 encryption for all personal data stored in tttjl's databases and storage systems;
• TLS 1.3 protocol for all data transmission between your device and tttjl's servers;
• Role-based access controls ensuring that only personnel with a documented operational need can access personal data;
• Multi-factor authentication requirements for all tttjl employees accessing systems that contain personal data;
• Regular penetration testing and vulnerability assessments of tttjl's infrastructure by qualified independent security firms;
• Dedicated intrusion detection and prevention systems monitoring tttjl's network perimeter;
• A formal Information Security Policy governing employee conduct with respect to personal data handling;
• A documented Incident Response Plan for managing and reporting personal data breaches in accordance with NPC Circular 16-03.

10.2   In the event of a personal data breach that is likely to pose a real risk to the rights and freedoms of affected individuals, tttjl will notify the NPC within 72 hours of becoming aware of the breach, and will notify affected Players without undue delay where required under RA 10173 and NPC issuances. The notification will include a description of the breach, the likely consequences, and the measures taken or proposed to address it.

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

• Strictly Necessary Cookies: Essential for the Platform to function correctly, including maintaining your authenticated session, remembering your preferences during a visit, and enabling core platform security features. These cannot be disabled without significantly affecting your use of the Platform.
• Performance and Analytics Cookies: Collect anonymized information about how Players use the Platform — such as which pages are visited most frequently and where errors occur — to help tttjl improve the platform experience. This data is aggregated and does not identify individual users.
• Functionality Cookies: Remember choices you make on the Platform (such as your preferred game category view or display settings) to provide a more personalized experience during your session.
• Session Security Tokens: Short-lived cryptographic tokens used to verify the integrity of your authenticated session and protect against cross-site request forgery attacks.

11.2   tttjl does not use third-party advertising cookies or cross-site tracking cookies for commercial advertising purposes. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies may impair the functionality of the Platform.

12.1   Under Republic Act No. 10173, you have the following rights with respect to your personal data processed by tttjl. You may exercise these rights at any time by contacting tttjl's DPO using the details in Section 15. tttjl will respond to verified rights requests within 30 calendar days of receipt.

12.2   Certain rights are subject to limitations where tttjl's retention and processing obligations are required by PAGCOR licensing conditions, the Anti-Money Laundering Act, or other applicable Philippine law. Where tttjl cannot fulfill a rights request in full due to such obligations, we will explain the applicable limitation and, where possible, fulfill the request to the extent permissible.

12.3   If you are not satisfied with tttjl's response to a data rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

13.1   tttjl enforces the minimum age requirement of 21 years through mandatory age declaration at registration and KYC identity verification procedures for all Accounts. Where tttjl becomes aware that personal data has been collected from a person under the age of 21 — whether through fraudulent misrepresentation or otherwise — tttjl will immediately close the Account, cease all processing of that individual's personal data for gaming purposes, delete the data to the extent not required for legal or regulatory retention obligations, and report the incident to PAGCOR where required by licensing conditions.

13.2   If you have reason to believe that a minor has registered an Account on tttjl, please contact tttjl's support team or DPO immediately using the contact details in Section 15 so that appropriate action can be taken without delay.

14.1   tttjl reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, our data processing practices, or the services offered on the Platform.

14.2   Where changes are material — meaning they significantly affect your rights or how tttjl handles your personal data — tttjl will provide advance notice of at least 14 calendar days via the email address or mobile number registered to your Account before the updated Policy takes effect. For non-material clarifications and corrections, the updated Policy will be posted on the Platform with an updated effective date, without separate individual notification.

14.3   Your continued use of the tttjl Platform after the effective date of any updated Privacy Policy constitutes your acknowledgment of the updated Policy. If you do not agree to the updated Policy, you must cease using the Platform and request Account closure prior to the effective date of the update.

14.4   The version number and effective date shown at the top of this Policy identify the current controlling version. Previous versions are available from tttjl's DPO upon request.

15.1   For all privacy-related matters — including data subject rights requests, questions about this Policy, concerns about tttjl's data handling practices, or reporting a potential data breach — please contact tttjl's Data Protection Officer through the following channels:

15.2   If you are not satisfied with tttjl's response to your privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines. Information on how to file an NPC complaint is available through official Philippine government channels.

This Privacy Policy was last updated on 1 January 2026 and supersedes all previous versions. tttjl is registered with the National Privacy Commission and operates under PAGCOR authorization. © 2026 tttjl. All rights reserved.