Privacy Policy

1. Who We Are

1.1 tbjl Casino is an online gaming platform accessible at tbjl.club, offering live dealer games, slots, bingo, fishing games, and other casino entertainment to eligible players in the Philippines.

1.2 For the purposes of the Data Privacy Act of 2012, tbjl is the personal information controller responsible for the personal data you provide when using our services.

1.3 If you have any questions about this Privacy Policy or how tbjl handles your data, please contact our Data Protection Officer (DPO) using the details in Section 14.

2. Personal Data We Collect

2.1 tbjl collects the following categories of personal data:

2.2 tbjl does not intentionally collect sensitive personal information (as defined under RA 10173) beyond what is strictly necessary for identity verification and regulatory compliance.

3. How We Collect Your Data

3.1 Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in promotions.

3.2 Automatically — through cookies, web beacons, and server logs when you visit tbjl.club or use our platform. See Section 7 for details on cookies.

3.3 From third parties — including identity verification service providers, payment processors (e.g., GCash, PayMaya, banks), and fraud prevention services, where necessary to verify your identity or process transactions.

3.4 tbjl will always inform you at the point of collection what data is being collected and why, consistent with the transparency requirements of RA 10173.

4. How We Use Your Personal Data

4.1 tbjl uses your personal data for the following purposes:

• Account management — creating, maintaining, and securing your tbjl account;
• Identity and age verification — confirming you are 21 or older and verifying your identity as required by law;
• Payment processing — facilitating deposits and withdrawals via GCash, PayMaya, bank transfer, and debit card;
• Game operation — delivering casino games, recording results, and resolving disputes;
• Regulatory compliance — meeting anti-money laundering (AML), counter-terrorism financing (CTF), and PAGCOR reporting obligations;
• Responsible gaming — monitoring gaming patterns to identify problem gambling indicators and enforcing self-exclusion requests;
• Customer support — responding to your enquiries, complaints, and feedback;
• Marketing communications — sending you promotional offers and updates, where you have consented to receive them;
• Security and fraud prevention — detecting and preventing unauthorized access, cheating, and financial fraud;
• Platform improvement — analyzing usage data to improve tbjl's features, performance, and user experience.

4.2 tbjl will not use your personal data for any purpose incompatible with those listed above without first obtaining your consent or establishing another lawful basis.

5. Legal Basis for Processing

5.1 tbjl processes your personal data on the following legal bases under RA 10173:

• Contractual necessity — processing required to perform our contract with you (e.g., operating your account, processing payments);
• Legal obligation — processing required to comply with applicable laws (e.g., AML/CTF obligations, PAGCOR reporting, age verification);
• Legitimate interests — processing for fraud prevention, security, and platform improvement, where these interests are not overridden by your rights;
• Consent — processing for marketing communications and non-essential cookies, where you have given explicit consent. You may withdraw consent at any time.

6. Sharing Your Personal Data

6.1 tbjl does not sell your personal data. We may share your data with the following categories of recipients only where necessary and lawful:

• Payment processors — GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other Philippine banks, for the purpose of processing your transactions;
• Identity verification providers — third-party KYC service providers who assist with age and identity verification;
• Game software providers — licensed game studios whose software powers tbjl's casino games, who may receive anonymized session data;
• Regulatory authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where required by law;
• Fraud prevention services — third-party providers who assist tbjl in detecting and preventing fraudulent activity;
• Professional advisers — lawyers, auditors, and accountants, subject to confidentiality obligations.

6.2 All third parties with whom tbjl shares personal data are required to handle that data in accordance with applicable privacy laws and tbjl's data processing agreements.

6.3 tbjl may disclose your personal data if required to do so by law, court order, or in connection with legal proceedings.

7. Cookies & Tracking Technologies

7.1 tbjl uses cookies and similar tracking technologies on tbjl.club to enhance your experience, maintain your session, and analyze platform usage.

7.2 Types of cookies used by tbjl:

• Essential cookies — required for the platform to function (e.g., session management, login state). These cannot be disabled.
• Analytics cookies — used to understand how players use tbjl.club, which pages are most visited, and where improvements can be made. Data is aggregated and anonymized.
• Preference cookies — used to remember your settings and preferences (e.g., language, display options).
• Marketing cookies — used to deliver relevant promotional content. These are only set with your consent.

7.3 You can manage your cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to use core tbjl services, but may limit some personalization features.

8. Data Retention

8.1 tbjl retains your personal data for as long as your account is active and for a period thereafter as required by applicable law. Specific retention periods include:

• Account and identity data — retained for the duration of your account plus five (5) years after closure, as required by AML regulations;
• Transaction records — retained for five (5) years from the date of the transaction, in compliance with AMLC requirements;
• Gaming records — retained for three (3) years for dispute resolution and regulatory audit purposes;
• Support communications — retained for two (2) years from the date of the last interaction;
• Marketing consent records — retained until you withdraw consent, plus one (1) year thereafter.

8.2 When personal data is no longer required, tbjl will securely delete or anonymize it in accordance with our data disposal procedures.

9. Your Privacy Rights

9.1 Under the Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal data held by tbjl:

• Right to be informed — the right to know what personal data tbjl collects and how it is used;
• Right of access — the right to request a copy of the personal data tbjl holds about you;
• Right to rectification — the right to correct inaccurate or incomplete personal data;
• Right to erasure — the right to request deletion of your personal data, subject to legal retention obligations;
• Right to object — the right to object to processing based on legitimate interests, including direct marketing;
• Right to data portability — the right to receive your personal data in a structured, commonly used format;
• Right to withdraw consent — where processing is based on consent, the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

9.2 To exercise any of these rights, please contact tbjl's Data Protection Officer using the details in Section 14. tbjl will respond to all verified requests within fifteen (15) business days, as required by the NPC.

9.3 If you believe tbjl has not handled your personal data in accordance with RA 10173, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

10. Data Security

10.1 tbjl implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction:

• SSL/TLS encryption — all data in transit between your device and tbjl.club is encrypted;
• AES-256 encryption — sensitive data stored in tbjl's systems is encrypted at rest;
• Access controls — personal data is accessible only to authorized tbjl personnel on a strict need-to-know basis;
• Two-factor authentication — available for all tbjl player accounts to add an extra layer of login security;
• Regular security audits — tbjl conducts periodic vulnerability assessments and penetration testing;
• Staff training — all tbjl personnel with access to personal data receive regular data privacy and security training.

10.2 While tbjl takes all reasonable steps to protect your data, no online platform can guarantee absolute security. You are responsible for keeping your tbjl login credentials confidential and for notifying us immediately if you suspect unauthorized access to your account.

11. Children's Privacy

11.1 tbjl Casino services are strictly for persons aged 21 years and older. tbjl does not knowingly collect personal data from individuals under the age of 21.

11.2 If tbjl discovers that personal data has been collected from a person under 21, that account will be immediately suspended, all data will be deleted, and any funds will be handled in accordance with applicable law.

11.3 If you are a parent or guardian and believe your child has registered at tbjl, please contact us immediately at the details provided in Section 14 so we can take prompt action.

12. International Data Transfers

12.1 tbjl's primary operations and data storage are based in the Philippines. In some cases, personal data may be processed by third-party service providers located outside the Philippines — for example, cloud infrastructure providers or game software licensors.

12.2 Where personal data is transferred outside the Philippines, tbjl ensures that appropriate safeguards are in place, including contractual data processing agreements that require the recipient to provide a level of data protection equivalent to that required under RA 10173.

12.3 tbjl will not transfer your personal data to a jurisdiction that does not provide adequate data protection without first obtaining your consent or establishing another lawful transfer mechanism.

13. Updates to This Privacy Policy

13.1 tbjl may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or regulatory guidance. The updated policy will be published at tbjl.club/privacy-policy with a revised "Last Updated" date.

13.2 Where changes are material, tbjl will notify registered players via email or in-platform notification at least seven (7) days before the changes take effect.

13.3 Your continued use of tbjl services after the effective date of any update constitutes your acceptance of the revised Privacy Policy. If you do not agree with the changes, you may close your account by contacting tbjl support.

14. Contact Us & Data Protection Officer

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or tbjl's data practices, please contact our Data Protection Officer:

14.2 If you are not satisfied with tbjl's response to your privacy concern, you may escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the independent authority responsible for enforcing RA 10173.