ttjj Privacy Policy

1. Introduction

ttjj ("we," "us," or "the Company") is committed to protecting the privacy and personal data of all users ("you," "Player," or "Data Subject") of the ttjj platform accessible at https://ttjj.app (the "Platform"). This Privacy Policy describes how ttjj collects, processes, stores, shares, and protects your personal information in connection with your use of the Platform.

This Privacy Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC). By registering on or using the ttjj Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.

If you do not agree with any part of this Privacy Policy, please discontinue use of the Platform immediately and contact us to request deletion of any data we may hold about you.

2. Personal Data We Collect

ttjj collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:

• Identity Data: Full legal name, date of birth, nationality, and government-issued ID details (e.g., Philippine National ID, passport, driver's license, SSS/GSIS ID).
• Contact Data: Email address, Philippine mobile number, and residential address.
• Financial Data: Payment method details (e.g., GCash account number, PayMaya account, BPI/BDO/Metrobank account details), deposit and withdrawal history, and transaction records.
• Account Data: Username, encrypted password, account preferences, gaming history, bonus usage, and session logs.
• Technical Data: IP address, device type, browser type and version, operating system, and access timestamps.
• Usage Data: Pages visited, games played, session duration, click patterns, and feature interactions on the Platform.
• Communications Data: Records of your correspondence with ttjj customer support, including live chat transcripts and email exchanges.

We do not collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for identity verification or regulatory compliance, and only with your explicit consent.

3. How We Use Your Personal Data

ttjj processes your personal data for the following purposes:

• To create, verify, and manage your ttjj account.
• To process deposits, withdrawals, and other financial transactions via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment channels.
• To verify your identity and age (21+) in compliance with Philippine gaming regulations and anti-money laundering (AML) requirements.
• To provide customer support and respond to your inquiries.
• To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct.
• To send you transactional communications (e.g., deposit confirmations, withdrawal notifications, security alerts). Marketing communications are sent only with your consent and you may opt out at any time.
• To improve the Platform's features, performance, and user experience through aggregated analytics.
• To comply with applicable Philippine laws, regulations, and lawful requests from government authorities.
• To enforce our Terms & Conditions and other platform policies.

4. Legal Basis for Processing

ttjj processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform the contract between you and ttjj (i.e., to operate your account and provide gaming services).
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including AML regulations, gaming regulations, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for ttjj's legitimate interests in fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights.
• Consent: For marketing communications and non-essential cookies, processing is based on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

ttjj does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only to the extent necessary:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your financial transactions.
• Identity Verification Providers: Third-party KYC (Know Your Customer) service providers engaged to verify your identity and age.
• Technology Service Providers: Cloud hosting, data storage, and platform infrastructure providers operating under strict data processing agreements.
• Game Content Providers: Third-party game studios whose games are available on the ttjj Platform, limited to session and wagering data required to operate the games.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies, where required by law or lawful order.
• Professional Advisors: Legal counsel, auditors, and compliance consultants, subject to professional confidentiality obligations.

All third-party service providers engaged by ttjj are contractually required to process your data only for the specified purpose and to maintain appropriate security measures.

6. Cookies & Tracking Technologies

ttjj uses cookies and similar technologies to operate and improve the Platform. The types of cookies we use are:

• Strictly Necessary Cookies: Required for the Platform to function, including session management and security. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings and login state to provide a more personalized experience.
• Analytics Cookies: Collect aggregated, anonymized data about how players use the Platform to help us improve performance and features. No personally identifiable information is shared with analytics providers.

ttjj does not use third-party advertising cookies or cross-site behavioral tracking. You may manage cookie preferences through your browser settings; however, disabling strictly necessary cookies may impair Platform functionality.

7. Data Retention

ttjj retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law. Specific retention periods include:

• Account Data: Retained for the duration of your account and for five (5) years following account closure, in compliance with AML record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years as required by the Anti-Money Laundering Act and related regulations.
• Customer Support Records: Retained for two (2) years from the date of the last interaction.
• Technical and Usage Logs: Retained for up to twelve (12) months for security and fraud investigation purposes.

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

8. Data Security

ttjj implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and ttjj servers.
• Encryption of sensitive data at rest using industry-standard algorithms.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, vulnerability scanning, and penetration testing of Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems holding personal data.

While ttjj takes all reasonable steps to protect your data, no system is completely immune to security risks. In the event of a personal data breach that is likely to result in harm to affected players, ttjj will notify the National Privacy Commission and affected Data Subjects within seventy-two (72) hours of becoming aware of the breach, as required by NPC regulations.

9. Your Rights as a Data Subject

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

• Right to be Informed: The right to know how your personal data is being collected and processed — which this Privacy Policy fulfills.
• Right of Access: The right to request a copy of the personal data ttjj holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to ttjj's legal retention obligations.
• Right to Object: The right to object to the processing of your personal data for direct marketing or where processing is based on legitimate interests.
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format where technically feasible.
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 12. We will respond to all verified requests within thirty (30) days.

10. Children's Privacy

The ttjj Platform is strictly intended for individuals aged 21 years and above. ttjj does not knowingly collect personal data from persons under 21 years of age. If we become aware that personal data has been collected from a minor, we will immediately suspend the associated account and delete the data. If you believe a minor has registered on the Platform, please contact us immediately at the details provided in Section 12.

11. Updates to This Privacy Policy

ttjj reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or Platform features. When material changes are made, we will post the updated Privacy Policy on this page with a revised "Last Updated" date. Where required by law, we will notify you directly of significant changes via email or in-Platform notification.

Your continued use of the ttjj Platform following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically.

12. Contact & Data Protection Officer

ttjj has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests regarding your personal data or this Privacy Policy, please contact our DPO:

• Platform: ttjj — https://ttjj.app
• Email: [email protected]
• Response Time: Within 30 days of receipt of a verified request.

You also have the right to lodge a complaint directly with the National Privacy Commission of the Philippines if you are not satisfied with our response.