Your Privacy at tr-99ph

1. Introduction

This Privacy Policy ("Policy") describes how tr-99ph ("the Company," "we," "us," or "our") collects, processes, stores, and protects the personal information of users ("Player," "User," or "you") who access or use the tr-99ph online gaming platform at tr-99ph.com (the "Platform").

tr-99ph is committed to protecting the privacy and personal data of all its users, particularly Filipino players who entrust us with their information. This Policy is drafted in compliance with the Republic Act No. 10173 (Data Privacy Act of 2012) of the Philippines and its Implementing Rules and Regulations, as enforced by the National Privacy Commission (NPC).

By registering an account or using any service on the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, please discontinue use of the Platform immediately.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming Policy, which together form the complete framework governing your use of tr-99ph.

2. Personal Data We Collect

tr-99ph collects personal data through various means, including account registration, platform usage, and communications with our support team. The categories of data we collect include:

We do not collect sensitive personal information such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where strictly required for responsible gaming compliance (e.g., self-exclusion records).

3. How We Use Your Personal Data

tr-99ph uses the personal data we collect for the following purposes:

• Account Management: To create, maintain, and manage your tr-99ph player account, including identity verification and KYC compliance.
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver the full range of tr-99ph platform services.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, money laundering, and other illegal activities.
• Regulatory Compliance: To fulfill our obligations under Philippine gaming regulations, the Data Privacy Act of 2012, anti-money laundering laws, and other applicable legislation.
• Responsible Gaming: To monitor gaming behavior, enforce self-exclusion requests, apply deposit limits, and identify players who may be at risk of problem gambling.
• Customer Support: To respond to your inquiries, resolve disputes, and provide technical assistance through our support channels.
• Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided explicit consent. You may opt out at any time.
• Platform Improvement: To analyze usage patterns, conduct internal research, and improve the performance, features, and user experience of the Platform.
• Legal Proceedings: To establish, exercise, or defend legal claims in the event of a dispute.

4. Legal Basis for Processing

tr-99ph processes your personal data on the following legal grounds as recognized under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual Necessity: Processing is necessary to perform the contract between you and tr-99ph — specifically, to provide the gaming services you have registered for.
• Legal Obligation: Processing is required to comply with applicable Philippine laws, including anti-money laundering regulations, PAGCOR licensing requirements, and tax obligations.
• Legitimate Interests: Processing is necessary for tr-99ph's legitimate business interests, including fraud prevention, platform security, and service improvement, provided these interests are not overridden by your rights.
• Consent: For marketing communications and non-essential cookies, we rely on your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing & Disclosure

tr-99ph does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your data only in the following limited circumstances:

• Service Providers: We engage trusted third-party service providers to assist in operating the Platform, including payment processors (e.g., GCash, PayMaya, BPI, BDO), identity verification services, IT infrastructure providers, and customer support platforms. These providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection laws.
• Regulatory Authorities: We may disclose your data to PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), or other Philippine government agencies where required by law or upon receipt of a valid legal order.
• Law Enforcement: We may share data with law enforcement agencies in the Philippines where we are legally compelled to do so, or where disclosure is necessary to prevent or investigate criminal activity.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of tr-99ph's business, your personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations.
• With Your Consent: We may share your data with other parties where you have given us explicit prior consent to do so.

In all cases of data sharing, tr-99ph implements appropriate contractual safeguards to ensure your personal information remains protected.

6. Cookies & Tracking Technologies

tr-99ph uses cookies and similar tracking technologies to enhance your experience on the Platform. Cookies are small text files stored on your device that help us recognize you, remember your preferences, and analyze how the Platform is used.

We use the following types of cookies:

• Essential Cookies: Required for the Platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against fraud. These cannot be disabled.
• Functional Cookies: Remember your preferences such as language settings, display options, and game history to provide a more personalized experience.
• Analytics Cookies: Help us understand how players interact with the Platform — which pages are visited most, how long sessions last, and where users encounter issues. This data is aggregated and anonymized.
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of our campaigns. These are only activated with your explicit consent.

You can manage your cookie preferences through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform. Continued use of tr-99ph after being informed of our cookie practices constitutes acceptance of essential and functional cookies.

7. Data Security

tr-99ph implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. Our security framework includes:

• SSL/TLS Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS protocols, ensuring that your information cannot be intercepted in transit.
• Secure Data Storage: Personal and financial data is stored on secured servers with restricted access controls, firewalls, and intrusion detection systems.
• Access Controls: Access to personal data within tr-99ph is strictly limited to authorized personnel who require it to perform their job functions. All staff with data access are subject to confidentiality obligations.
• Two-Factor Authentication: tr-99ph supports two-factor authentication (2FA) for player accounts to provide an additional layer of security against unauthorized access.
• Regular Security Audits: We conduct periodic security assessments and vulnerability testing to identify and address potential weaknesses in our systems.
• Incident Response: In the event of a data breach that poses a risk to your rights, tr-99ph will notify affected players and the National Privacy Commission within the timeframes required by Philippine law.

While we take all reasonable precautions to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

8. Data Retention

tr-99ph retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. The following general retention periods apply:

• Account Data: Retained for the duration of your active account relationship with tr-99ph, plus a minimum of five (5) years following account closure, as required for anti-money laundering compliance.
• Transaction Records: Financial transaction records are retained for a minimum of five (5) years in accordance with AMLC regulations and tax requirements.
• KYC Documents: Identity verification documents are retained for the period required by PAGCOR licensing conditions and applicable law, typically five (5) years from the date of submission.
• Support Communications: Customer support records are retained for up to three (3) years from the date of the last interaction.
• Marketing Data: Data used for marketing purposes is retained until you withdraw your consent or request deletion, whichever occurs first.
• Self-Exclusion Records: Records of self-exclusion requests are retained indefinitely to prevent re-registration during the exclusion period.

Upon expiry of the applicable retention period, your personal data will be securely deleted, destroyed, or anonymized in a manner that prevents reconstruction or identification.

9. Your Data Subject Rights

As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by tr-99ph:

• Right to Be Informed: You have the right to be informed about how your personal data is collected, processed, and used — which is the primary purpose of this Privacy Policy.
• Right of Access: You may request a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to Rectification: If any of your personal data is inaccurate or incomplete, you have the right to request that it be corrected or updated.
• Right to Erasure: You may request the 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.
• Right to Object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests.
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, and machine-readable format for transfer to another service provider.
• Right to Lodge a Complaint: If you believe your data rights have been violated, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details provided in Section 13 of this Policy. We will respond to all verified requests within thirty (30) days of receipt.

10. Children's Privacy

tr-99ph is strictly an adult gaming platform. In accordance with Philippine gaming regulations, you must be at least 21 years of age to register and use our services. We do not knowingly collect personal data from individuals under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe that your child has registered on tr-99ph, please contact us immediately at the details provided in Section 13.

tr-99ph employs age verification procedures during registration and reserves the right to request proof of age at any time. Accounts that cannot be verified as belonging to a person aged 21 or over will be suspended pending verification.

11. International Data Transfers

tr-99ph primarily stores and processes your personal data within the Philippines. However, some of our third-party service providers — including cloud infrastructure providers and game software licensors — may process data in other countries.

Where personal data is transferred outside the Philippines, tr-99ph ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under the Data Privacy Act of 2012. These safeguards may include:

• Contractual clauses requiring the recipient to apply equivalent data protection standards.
• Transfers to countries recognized by the National Privacy Commission as providing adequate data protection.
• Binding corporate rules where data is transferred within a corporate group.

By using the tr-99ph Platform, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where necessary for the provision of our services, subject to the safeguards described above.

12. Updates to This Privacy Policy

tr-99ph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The date of the most recent revision is displayed at the top of this page. We encourage you to review this Policy periodically to stay informed about how we protect your personal data. Your continued use of the Platform following the posting of an updated Policy constitutes your acceptance of the revised terms.

If you have concerns about any changes to this Policy, you are welcome to contact our Data Protection Officer before the changes take effect.

13. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data, please contact tr-99ph's designated Data Protection Officer through the following channel:

• Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 via the chat widget on the Platform
• Response Time: We aim to acknowledge all privacy-related requests within 72 hours and resolve them within 30 days

For unresolved complaints, you may also contact the National Privacy Commission of the Philippines through their official government channels. tr-99ph fully cooperates with NPC investigations and takes all privacy complaints seriously.