ttjj Casino Privacy Policy

This Privacy Policy ("Policy") describes how ttjj ("we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "the Data Subject") who access or use the ttjj Casino platform at ttjj.win ("the Platform").

This Policy is issued in accordance with Republic Act No. 10173, known as the Data Privacy Act of 2012 of the Republic of the Philippines ("DPA"), its Implementing Rules and Regulations ("IRR"), and the relevant issuances of the National Privacy Commission ("NPC"). It also reflects our obligations as a PAGCOR-regulated gaming operator.

By registering for or using the ttjj platform, you acknowledge that you have read, understood, and consent to the data processing activities described in this Policy. If you do not agree with this Policy, you must not register for or use the ttjj platform.

This Policy should be read alongside the ttjj Terms and Conditions and Responsible Gaming Policy, which together constitute the full agreement governing your use of the Platform.

ttjj collects the minimum personal data necessary to provide you with a safe, compliant, and personalised gaming experience. The categories of personal data we process include:

• Full legal name
• Date of birth (for age verification — players must be 21+)
• Philippine mobile number
• Email address
• Username and encrypted password
• Nationality and country of residence

• Government-issued identification (e.g., Philippine Passport, SSS ID, UMID, Driver's Licence, PhilSys National ID)
• Proof of address (e.g., utility bill, bank statement issued within 90 days)
• Selfie or liveness check photograph for identity verification
• Source of funds documentation (for high-value accounts, as required by PAGCOR anti-money laundering rules)

• Payment method details (GCash number, PayMaya account, bank account details — stored in tokenised form only; full card/account numbers are never stored by ttjj)
• Deposit history, withdrawal history, and transaction timestamps
• Bonus and promotional history

• Game session logs — games played, bets placed, outcomes, session duration
• Sports betting selections and wagering history
• Bingo and sabong activity records

• IP address and approximate geolocation (city/region level)
• Device type, operating system, and browser information
• Session logs — login timestamps, session duration, pages visited
• Cookies and similar tracking technologies (see Section 7)

• Live chat transcripts and support ticket records
• Email correspondence with ttjj
• Survey responses and player feedback submissions

ttjj collects personal data through the following channels:

1. Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, respond to a survey, or use any other interactive feature of the Platform.
2. Automatically: When you browse or interact with the Platform, technical data including your IP address, device identifiers, and browsing behaviour is collected automatically through server logs, cookies, and similar technologies.
3. From third-party payment providers: When you make a deposit or withdrawal via GCash, PayMaya, BPI, BDO, or Metrobank, we receive transaction confirmation and relevant payment reference data from those providers. We do not receive or store your full banking credentials.
4. From identity verification providers: During KYC verification, we may use third-party identity verification services that process your identification documents and return a verification result to ttjj.
5. From regulatory and law enforcement authorities: In certain circumstances required by PAGCOR regulations or Philippine law, we may receive or be required to exchange information with regulatory, judicial, or law enforcement bodies.

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

1. Account creation and management: To register, authenticate, and manage your ttjj player account, including processing your login credentials and account settings.
2. Age and identity verification: To verify that you are at least 21 years of age and to confirm your identity as required by PAGCOR regulations and anti-money laundering obligations.
3. Processing deposits and withdrawals: To facilitate your financial transactions on the Platform, including communicating with payment providers and maintaining accurate transaction records.
4. Providing gaming services: To enable your access to and use of games, sports betting, bingo, sabong, and all other Platform features.
5. Customer support: To respond to your queries, complaints, and support requests through live chat, email, and other available channels.
6. Responsible gaming: To monitor your gaming behaviour for signs of problem gambling, enforce deposit limits and self-exclusion orders, and provide responsible gaming interventions where appropriate.
7. Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorised account access, and other security threats.
8. Legal and regulatory compliance: To fulfil our obligations under PAGCOR's licensing conditions, the Anti-Money Laundering Act (AMLA), the Data Privacy Act, and other applicable Philippine laws.
9. Personalisation: To customise your Platform experience, including game recommendations, promotional offers, and interface preferences, based on your usage patterns.
10. Platform improvement: To analyse aggregated, anonymised usage data for the purpose of improving Platform performance, game selection, and user experience.
11. Marketing communications: To send you promotional offers, bonus notifications, and gaming updates where you have consented to receive such communications. You may withdraw this consent at any time.

Under the Philippine Data Privacy Act, ttjj processes your personal data on the following legal bases:

1. Contractual necessity: Processing required to perform our contractual obligations to you under the ttjj Terms and Conditions — including account management, game provision, and payment processing.
2. Legal obligation: Processing necessary to comply with PAGCOR licensing conditions, AMLA requirements, and other applicable Philippine laws to which ttjj is subject.
3. Legitimate interests: Processing necessary for ttjj's legitimate interests in fraud prevention, platform security, responsible gaming compliance, and improving platform quality — provided these interests are not overridden by your fundamental rights and freedoms.
4. Consent: Processing for marketing communications and certain optional personalisation features, where you have freely given, specific, and informed consent. Consent may be withdrawn at any time without affecting the lawfulness of processing prior to withdrawal.

ttjj does not sell, rent, or trade your personal data. We share your data only in the following limited circumstances, and only to the minimum extent necessary for the stated purpose:

ttjj engages trusted third-party service providers who process data on our behalf under binding data processing agreements. These include payment processing partners (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, cloud infrastructure providers, fraud detection services, and customer support platform providers. All processors are required to implement appropriate technical and organisational security measures and are prohibited from using your data for any purpose beyond the specific service they provide.

Certain game providers (e.g., JILI Games, Pragmatic Play, PG Soft) may receive aggregated, pseudonymised session data for the purpose of game performance analytics and jackpot calculation. No personally identifiable information beyond an anonymised player identifier is shared with game providers.

ttjj may be required to disclose your personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), Philippine law enforcement agencies, or courts of competent jurisdiction, where such disclosure is required by law, court order, or regulatory directive.

In the event of a merger, acquisition, or sale of all or part of ttjj's assets, your personal data may be transferred to the acquiring entity, subject to the same level of data protection as described in this Policy. You will be notified of any such transfer in advance.

ttjj uses cookies and similar technologies to operate the Platform, remember your preferences, and analyse usage patterns. The following types of cookies may be used:

1. Essential cookies: Required for the Platform to function — including session authentication tokens, security cookies, and load-balancing identifiers. These cannot be disabled without impairing Platform functionality.
2. Functional cookies: Remember your preferences such as language settings, game display options, and notification preferences to personalise your experience.
3. Analytics cookies: Collect anonymised data about how players navigate the Platform, which games are most popular, and where technical errors occur. Used exclusively for Platform improvement.
4. Marketing cookies: Used, with your consent, to track which promotions you have engaged with and to tailor future promotional communications to your interests.

You may manage your cookie preferences through your browser settings. Please note that disabling essential cookies will prevent you from accessing Platform features that require authentication.

ttjj implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers
• AES-256 encryption for sensitive data at rest, including identity documents and financial records
• Password hashing using industry-standard cryptographic algorithms (bcrypt) — passwords are never stored in plain text
• Two-factor authentication (2FA) via SMS OTP for account access on new devices
• Role-based access controls limiting staff access to personal data to only those with a legitimate operational need
• Regular penetration testing and vulnerability assessments by independent security specialists
• Intrusion detection systems and real-time security monitoring
• Data breach response procedures complying with NPC notification requirements

In the event of a personal data breach that poses a real risk to your rights and freedoms, ttjj will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with the DPA and NPC Circular 16-03.

ttjj retains your personal data for only as long as necessary to fulfil the purposes outlined in this Policy, or as required by applicable law. The following general retention periods apply:

1. Account and KYC data: Retained for the duration of your active account plus five (5) years after account closure, as required by PAGCOR licensing conditions and the Anti-Money Laundering Act.
2. Transaction and financial records: Retained for five (5) years from the date of the transaction, in accordance with AMLC regulations and PAGCOR requirements.
3. Gaming session logs: Retained for three (3) years for dispute resolution and regulatory audit purposes.
4. Customer support communications: Retained for two (2) years from the date of the communication, or until any related dispute is finally resolved.
5. Marketing consent records: Retained for the duration of your account plus two (2) years, as evidence of your consent and to process any withdrawal of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with ttjj's data destruction procedures.

As a data subject under the Philippine Data Privacy Act, you have the following rights with respect to your personal data held by ttjj:

1. Right to be informed: The right to be notified that your personal data is being or will be processed, and the details of such processing as described in this Policy.
2. Right of access: The right to obtain a copy of the personal data we hold about you, including information about how it is being processed.
3. Right to rectification: The right to have inaccurate or incomplete personal data corrected without undue delay.
4. Right to erasure / right to be forgotten: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations.
5. Right to restriction of processing: The right to request that we limit the processing of your personal data in certain circumstances.
6. Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format and to transmit it to another controller.
7. Right to object: The right to object to processing of your personal data for direct marketing purposes at any time, and on legitimate grounds, to processing based on ttjj's legitimate interests.
8. Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe ttjj has violated your data privacy rights.

To exercise any of the above rights, please contact our Data Protection Officer (see Section 14). We will respond to all valid requests within fifteen (15) business days of receipt. We may require identity verification before processing your request.

The ttjj platform is strictly restricted to individuals who are 21 years of age or older, in accordance with Philippine law and PAGCOR regulations. ttjj does not knowingly collect, process, or retain personal data from individuals under 21 years of age.

If we become aware that an account has been created by or for a person under the age of 21, we will immediately suspend the account, delete the associated personal data to the extent permitted by our legal obligations, and report the matter to PAGCOR as required. If you believe that a minor has registered on the ttjj platform, please notify us immediately via our support channels.

Certain of ttjj's service providers and game content partners may be located outside of the Philippines. Where personal data is transferred to, or processed in, a country outside the Philippines, ttjj ensures that appropriate safeguards are in place to provide an equivalent level of data protection to that required under the Philippine Data Privacy Act.

Such safeguards may include data transfer agreements containing standard contractual clauses approved by the NPC, transfer to countries with an adequate level of data protection as recognised by the NPC, or reliance on other lawful transfer mechanisms available under the DPA and its IRR.

You may request information about the specific safeguards applicable to any international transfer of your personal data by contacting our Data Protection Officer.

ttjj reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or PAGCOR regulatory requirements. The effective date of the current version is displayed at the top of this page.

Material changes to this Policy — being changes that meaningfully affect your rights or the way we process your personal data — will be communicated to you via email to your registered address and via a prominent notice on the Platform at least fourteen (14) days before the changes take effect. Your continued use of the Platform after the effective date of any change constitutes your acceptance of the updated Policy.

We recommend reviewing this Policy periodically to stay informed about how ttjj protects your personal information.

ttjj has designated a Data Protection Officer (DPO) as required under the Philippine Data Privacy Act. If you have any questions, concerns, or requests relating to this Privacy Policy or ttjj's processing of your personal data, please contact: