tbjl Privacy Policy

Introduction

tbjl ("tbjl," "we," "us," or "our") is committed to protecting the personal information of all users of the tbjl platform. This Privacy Policy describes how we collect, use, store, share, and protect personal data in connection with the operation of tbjl, an online casino and sports betting platform regulated by the Philippine Amusement and Gaming Corporation (PAGCOR).

This Privacy Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines ("DPA"), its Implementing Rules and Regulations, and the applicable issuances of the National Privacy Commission ("NPC"). All data processing activities conducted by tbjl are guided by the principles of transparency, legitimate purpose, and proportionality as established under the DPA.

By accessing the tbjl platform, creating an account, or using any tbjl service, you consent to the collection and processing of your personal information as described in this Privacy Policy. If you do not agree with any part of this policy, you should not use the tbjl platform.

Data Controller

tbjl acts as the personal information controller ("PIC") with respect to all personal data collected through the tbjl platform. As the PIC, tbjl determines the purposes and means of processing your personal data and bears responsibility for ensuring that all data processing is conducted lawfully, fairly, and in accordance with the DPA.

tbjl has designated a Data Privacy Officer ("DPO") responsible for overseeing compliance with the DPA and this Privacy Policy. The DPO may be contacted at the address provided in Section 15 of this document. The contact details of tbjl's DPO have been registered with the National Privacy Commission as required by the DPA.

Personal Data We Collect

tbjl collects personal data that is necessary for the provision of gaming services, regulatory compliance, fraud prevention, and customer support. The categories of personal data we collect include:

tbjl does not collect sensitive personal information as defined under the DPA (such as racial or ethnic origin, political opinions, health data, or sexual orientation) unless required by PAGCOR regulations for specific compliance purposes, in which case such collection will be clearly disclosed and separately consented to.

How We Collect Personal Data

tbjl collects personal data through the following means:

• Account Registration: Information provided by you when you create a tbjl account, including your name, mobile number, and date of birth.
• KYC Verification: Identity documents and photographs submitted by you to complete the verification process required prior to withdrawals.
• Payment Processing: Financial information provided when you make deposits or withdrawal requests through supported payment methods including GCash, Maya, and bank transfers.
• Platform Use: Technical data and gameplay data automatically collected through your use of the tbjl platform, including through cookies and similar technologies.
• Customer Support: Information provided by you in communications with tbjl's support team through live chat, email, or other channels.
• Third-Party Verification Services: Identity verification data from third-party KYC service providers engaged by tbjl for regulatory compliance purposes.

Purposes of Data Processing

tbjl processes your personal data for the following specific and legitimate purposes:

1. Account Management: Creating, maintaining, and managing your tbjl account, including authentication and access control.
2. Service Delivery: Providing access to casino games, sports betting, and all other tbjl platform features that you have requested.
3. Payment Processing: Processing deposits, withdrawals, and internal fund transfers securely and in accordance with applicable Philippine payment regulations.
4. Regulatory Compliance: Fulfilling tbjl's obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012, including mandatory reporting and record-keeping obligations.
5. Fraud Prevention and Security: Detecting and preventing fraudulent activity, unauthorized account access, money laundering, and other prohibited activities on the platform.
6. Responsible Gaming Compliance: Administering responsible gaming tools including deposit limits, self-exclusion requests, and cooling-off periods, and maintaining records required for PAGCOR responsible gaming compliance.
7. Customer Support: Responding to your inquiries, complaints, and support requests, and maintaining a record of communications for quality assurance and dispute resolution purposes.
8. Marketing Communications: Sending you promotional offers, bonus notifications, and platform updates where you have opted in to receive such communications. You may withdraw consent to marketing communications at any time.
9. Platform Improvement: Analyzing aggregated and anonymized usage data to improve platform performance, game selection, and user experience.

Legal Basis for Processing

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

• Contractual Necessity: Processing required to perform our obligations under the tbjl Terms & Conditions, including account management, payment processing, and service delivery.
• Legal Obligation: Processing required to comply with applicable Philippine laws, including PAGCOR regulatory requirements, the Anti-Money Laundering Act, and the Data Privacy Act.
• Legitimate Interests: Processing for fraud prevention, platform security, and platform improvement, where tbjl's legitimate interests do not override your fundamental rights and freedoms.
• Consent: Processing for marketing communications and optional platform features, where you have provided clear and informed consent. Consent may be withdrawn at any time without affecting the lawfulness of processing prior to withdrawal.

Data Sharing & Disclosure

tbjl may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data processing agreements:

• PAGCOR and Regulatory Authorities: tbjl is legally required to share player data with PAGCOR for licensing compliance, audit, and investigation purposes. tbjl may also disclose data to other Philippine government authorities, law enforcement agencies, or courts where required by law or valid legal process.
• Payment Service Providers: Financial data is shared with payment processors (GCash/GXI, Maya/Paymaya Inc., bank partners) solely for the purpose of processing deposits and withdrawals.
• KYC and Compliance Service Providers: Identity verification data is shared with accredited third-party KYC providers engaged to conduct identity verification on behalf of tbjl for PAGCOR compliance.
• Game Software Providers: Gameplay data is shared with licensed game software providers (e.g., JILI, PG Soft, Pragmatic Play) to the extent necessary for the operation of their games on the tbjl platform.
• IT and Security Service Providers: Technical data may be shared with tbjl's cloud infrastructure, cybersecurity, and platform maintenance providers, subject to strict confidentiality obligations.
• Anti-Money Laundering Compliance: Transaction data may be reported to the Anti-Money Laundering Council (AMLC) as required by the Revised Anti-Money Laundering Act and its implementing regulations.

All third-party service providers engaged by tbjl are contractually bound to process personal data only for the specified purposes, to maintain appropriate security measures, and to comply with applicable data protection laws.

Data Retention

tbjl retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to applicable legal and regulatory retention requirements. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with tbjl's data disposal procedures. Where data must be retained beyond the standard retention period due to an ongoing investigation, legal dispute, or regulatory inquiry, it will be retained for as long as required for those purposes.

Data Security

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

• Encryption: All personal data transmitted between your device and the tbjl platform is protected using SSL/TLS encryption. Sensitive data at rest (including KYC documents and financial records) is stored in encrypted form.
• Access Controls: Access to personal data within tbjl's systems is restricted to authorized personnel who require it for the performance of their duties, subject to role-based access controls and audit logging.
• Authentication: tbjl employs multi-factor authentication for internal system access and offers SMS OTP two-factor authentication to players for additional account security.
• Penetration Testing and Security Audits: tbjl conducts periodic security assessments to identify and remediate vulnerabilities in the platform and its underlying infrastructure.
• Incident Response: tbjl maintains a data breach response procedure. In the event of a personal data breach that is likely to result in harm to affected individuals, tbjl will notify the National Privacy Commission within 72 hours and affected individuals without undue delay, in accordance with the DPA.

While tbjl takes all reasonable steps to protect your data, no method of electronic storage or transmission over the internet is 100% secure. Players are encouraged to maintain strong account passwords and to enable two-factor authentication to protect their own accounts.

Cookies & Tracking Technologies

The tbjl website uses cookies and similar tracking technologies to deliver and improve the platform's functionality. The types of cookies used on tbjl include:

• Strictly Necessary Cookies: Required for the platform to function, including session management, authentication, and security features. These cookies cannot be disabled without impairing platform functionality.
• Functional Cookies: Enable enhanced platform features such as language preferences, game lobby state, and user interface customization. These cookies may be disabled but may impact platform usability.
• Analytics Cookies: Used to collect aggregated and anonymized data about platform usage to help tbjl understand how players interact with the platform and identify areas for improvement. This data is processed at the aggregate level and does not identify individual users.
• Security Cookies: Support tbjl's fraud detection and account security systems, including the identification of unusual login activity and cross-site request forgery prevention.

You may configure your browser to block or delete cookies. Note that disabling strictly necessary cookies will impair your ability to use the tbjl platform. tbjl does not use third-party advertising or retargeting cookies.

Your Data Privacy Rights

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

• Right to be Informed: You have the right to be informed of how your personal data is collected, used, and stored. This Privacy Policy fulfils tbjl's obligation to inform you.
• Right of Access: You may request a copy of the personal data tbjl holds about you, together with information about the purposes and recipients of processing.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data. You may update certain personal details (such as your mobile number) directly within your account settings. Other corrections may be requested through the support team.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected. Note that tbjl is required to retain certain data for the mandatory retention periods described in Section 8 and cannot fulfill erasure requests that conflict with these legal obligations.
• Right to Object: You may object to the processing of your personal data for purposes other than contractual necessity or legal compliance, including direct marketing communications.
• Right to Data Portability: Where technically feasible, you may request a copy of your personal data in a structured, commonly used, and machine-readable format.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to the withdrawal.
• Right to File a Complaint: If you believe your data privacy rights have been violated, you may file a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.

To exercise any of your rights, please contact tbjl's Data Privacy Officer using the contact details in Section 15. tbjl will respond to all valid data rights requests within 15 business days. tbjl reserves the right to verify your identity before processing a data rights request.

Marketing Communications

With your consent, tbjl may send you promotional communications including bonus offers, tournament announcements, new game notifications, and platform updates via SMS and in-app notifications. tbjl does not send unsolicited marketing communications to players who have not opted in.

You may opt out of marketing communications at any time by:

• Adjusting your notification preferences within your tbjl account settings;
• Contacting tbjl's customer support team through the live chat channel and requesting removal from marketing lists.

Opting out of marketing communications does not affect your receipt of transactional communications that are necessary for the operation of your account, such as deposit confirmations, withdrawal notifications, and account security alerts.

Children's Privacy — 21+ Platform

During the account registration and KYC verification process, tbjl collects and verifies your date of birth and government-issued identity document specifically for the purpose of confirming that you meet the minimum age requirement. Any account found to have been registered using false age information will be suspended, all balances will be forfeited, and the matter may be referred to relevant authorities.

If you are a parent or guardian and you believe your child has created an account on tbjl, please contact tbjl's support team immediately using the contact details in Section 15.

Updates to This Privacy Policy

tbjl reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, applicable laws, or regulatory requirements. Material changes to this Privacy Policy will be communicated to registered players via SMS notification or through a prominent notice on the tbjl platform, at least 7 days before the changes take effect.

Your continued use of the tbjl platform following the effective date of any updated Privacy Policy constitutes your acceptance of the changes. The most current version of this Privacy Policy is always available at tbjl.asia/privacy-policy. If you do not agree to any updates, you should cease using the platform and contact support to close your account.

Contact & Data Privacy Officer

For all data privacy inquiries, exercise of data subject rights, or concerns about tbjl's data practices, please contact tbjl's Data Privacy Officer through the following channels:

• Live Chat: Available 24/7 within the tbjl platform — the fastest way to reach the support team for general inquiries.
• Email (DPO): [email protected] — Subject line: "Data Privacy Request" for priority handling by tbjl's Data Privacy Officer. (Plain text — not a clickable link.)

For complaints or inquiries directed to the Philippine National Privacy Commission, please refer to the NPC's official website and published complaints procedure. tbjl will cooperate fully with any NPC investigation or inquiry relating to tbjl's data processing activities.