Privacy Policy

This Privacy Policy explains how Tlc99, operating through the website tlc99-au.com, collects, uses, discloses and protects personal information of players and website visitors. It applies to all users who access or use our services from Australia or in connection with tlc99-au.com, including prospective, current and former account holders. By using our website or services, you acknowledge that you have read and understood this Privacy Policy. This Privacy Policy is effective as of 1 January 2026 and supersedes any earlier version published on tlc99-au.com.

Who We Are

OBSERVE: The corporate details of Tlc99 are not fully specified in the available data. To avoid creating false or misleading statements under Australian law, we provide only verifiable information and clearly mark what is unspecified.

EXPAND: For privacy compliance, users must know who is responsible for their data and how to contact that party, even when some registration particulars are still being clarified.

REFLECT: We therefore describe the operator in functional terms, identify the service domain, and provide concrete contact points for privacy-related queries.

Tlc99 provides online gambling services to users accessing and using the website:

• Service name: Tlc99 (referred to as "Tlc99", "we", "us", "our")
• Primary service domain: https://tlc99-au.com
• Related historical/mirror domains: https://tlc99.vip, https://tlc99.com (may redirect to or from tlc99-au.com)

The precise legal entity name, registered office address and company registration number are currently not specified in the available data and may depend on the licensing jurisdiction (for example, a Curaçao or Philippine operator). When these details are confirmed, we will update this section and, where required, notify users in accordance with the "Updates" section below.

Data Protection Contact

• Data protection contact / responsible department: Data Protection Team, Tlc99
• E-mail (primary - privacy, support and rights requests): [email protected]
• E-mail (general information): [email protected]
• Phone: not specified
• Postal address for correspondence: not specified (you may contact us by email to obtain the current mailing details if required for a written complaint or request).

All requests relating to this Privacy Policy, your personal information or your privacy rights should be directed to the above data protection contact by email in the first instance.

What Personal Data We Collect

OBSERVE: Operating an online gambling service to Australian users requires collecting identity, transactional, behavioural and technical data to run accounts, process payments, manage risk and comply with KYC/AML expectations.

EXPAND: We also rely on cookies and analytics tools to ensure functionality, detect abuse and improve performance. Some of this data is collected directly from you, some automatically via your device.

REFLECT: We group the information into clear categories so you can understand what we collect and why.

1. Identification and Contact Data

• Full name, date of birth and age verification details
• Residential address, country of residence and, where applicable, proof of address
• E-mail address (including those used to contact [email protected] or [email protected])
• Phone number or other communication identifiers, if provided
• Document details (e.g., ID card, passport, driving licence) and copies you upload for verification or responsible gambling checks

2. Account and Service Data

• Username, password (stored in hashed form), security questions and answers
• Account status, registration date, verification status and internal risk flags
• Communication preferences (marketing opt-in/opt-out, language, notification settings)
• Customer support interactions, including emails and any logs of live chat or internal tickets

3. Financial and Payment Data

• Deposit and withdrawal records, including timestamps, amounts, currencies and methods (for example, PayID transfers and cryptocurrency payments used in line with our banking arrangements)
• Limited payment instrument details, such as masked account numbers or wallet identifiers, to the extent necessary to process transactions and comply with security requirements
• Transaction status, chargeback information, and any payment-related disputes

4. Gambling and Behavioural Data

• Betting and game history, including games played, stakes, winnings, losses, bonuses used and session durations
• Login and logout times, interaction with account tools (e.g., limits, self-exclusion)
• Clickstream and navigation data on tlc99-au.com, such as pages visited, banners clicked and referral sources
• Risk, anti-fraud and responsible gambling indicators generated from your behaviour (e.g., unusual activity, rapid play patterns)

5. Technical and Log Data

• IP address, approximate geolocation derived from IP, device identifiers and device attributes (operating system, browser type, screen resolution, language settings)
• Log files relating to access attempts, authentication events, errors and key system actions
• Security-related metadata used to identify suspicious behaviour (e.g., multiple failed logins, device changes)

6. Cookies and Similar Technologies

• Unique cookie identifiers that help recognise your browser or device
• Session data to maintain your login and keep your bets and account actions linked to you during a session
• Analytics data collected through first- and third-party tools that measure how users interact with our services
• Advertising identifiers (where applicable and consented) used for measuring the performance of campaigns and, when permitted, for tailoring marketing

7. Special Categories and Sensitive Data

We do not intentionally seek to collect sensitive information (such as health or religious beliefs). However, information about problem gambling, self-exclusion or interaction with responsible gambling tools may indirectly reveal aspects of your health or vulnerabilities. We treat such information with special care and restrict access to authorised personnel only.

Legal Basis for Processing

OBSERVE: While Australian privacy law is primarily governed by the Privacy Act 1988 (Cth) and the Australian Privacy Principles, our users may also expect alignment with broader international standards such as the GDPR.

EXPAND: Operating an online casino for Australian users involves processing that is necessary for contract performance, legal compliance, legitimate interests and, in some instances, consent.

REFLECT: We therefore rely on multiple legal bases, depending on the nature of each processing activity.

1. Performance of a Contract

• To create, manage and secure your Tlc99 account
• To process deposits, bets, game participation and withdrawals (including via PayID and cryptocurrency where offered)
• To provide customer support and to communicate with you about your account, transactions and service changes
• To honour promotions and bonuses in accordance with the applicable terms and conditions

2. Compliance with Legal and Regulatory Obligations

• To verify your identity and age, and to perform know-your-customer (KYC) and anti-money laundering/counter-terrorism financing (AML/CTF) screenings, even where rules arise from the operator's licensing jurisdiction outside Australia (for example, a Curaçao or Philippines regulator, if applicable)
• To keep appropriate records of transactions and communications for tax, accounting or regulatory reporting
• To respond to lawful requests from regulators, law enforcement or other competent authorities
• To apply responsible gambling measures and maintain records of self-exclusion or limits where required or recommended by regulatory standards

3. Legitimate Interests

• To operate, maintain, test and improve the functionality, performance and security of tlc99-au.com
• To prevent, detect and investigate fraud, abuse of bonuses, account takeover and other unlawful or suspicious activity
• To enforce our terms and conditions and protect our legal rights and interests
• To perform aggregated and anonymised analytics on user behaviour to improve our games, promotions, interfaces and risk models

Where we rely on legitimate interests, we balance our interests against your privacy rights and take steps to minimise impact, such as using pseudonymised or aggregated data where feasible.

4. Consent

• To send you electronic direct marketing communications (e-mail, SMS, push notifications) about offers, promotions or products of Tlc99 or its partners, where required under applicable law
• To place or read non-essential cookies and similar technologies for analytics or advertising, where the relevant law treats those activities as consent-based
• To share your information with selected affiliates and advertising networks for personalised marketing, only where you have provided valid consent

You may withdraw your consent at any time (see "Your Rights" below). Withdrawal will not affect the lawfulness of processing carried out before the withdrawal.

Purpose of Processing

OBSERVE: Each category of data has specific functional, legal and commercial purposes.

EXPAND: Clarifying these purposes helps users understand why information is required and supports compliance with purpose limitation principles under Australian and international standards.

REFLECT: We link purposes to activities so that you can evaluate whether they are reasonable in the context of an online gambling service.

Core Service Provision

• Registering and maintaining player accounts on tlc99-au.com
• Enabling participation in casino games, betting products and promotions
• Processing deposits, wagers, payouts, refunds and chargebacks
• Providing support and handling enquiries, complaints and disputes

Service Management and Improvement

• Monitoring performance and stability of our platform
• Analysing aggregated usage patterns to enhance user experience, game offerings and interfaces
• Testing new features, products and security mechanisms
• Training staff using anonymised or appropriately minimised data where possible

Marketing and Promotions

• Sending promotional messages and personalised offers, subject to your marketing preferences and applicable consent requirements
• Conducting surveys, contests and loyalty programs
• Measuring effectiveness of campaigns and adjusting our marketing strategy

Analytics, Risk Management and Fraud Prevention

• Detecting suspicious patterns related to fraud, bonus abuse, account compromise or money laundering
• Performing risk scoring and identity verification checks
• Enforcing betting limits, self-exclusion and other responsible gambling tools
• Producing aggregated statistical reports for internal management and, where required, regulators

Legal, Regulatory and Compliance Purposes

• Complying with licensing, AML/CTF or other regulatory conditions that may apply in the operator's home jurisdiction or in other relevant jurisdictions
• Responding to lawful orders, subpoenas or requests from public authorities
• Establishing, exercising or defending legal claims, including retaining relevant evidence

Disclosure & Sharing

OBSERVE: Providing gambling services typically requires collaboration with payment providers, technology suppliers, verification services and potentially regulators in several jurisdictions.

EXPAND: Sharing is limited to what is necessary and proportionate for the stated purposes and subject to appropriate safeguards.

REFLECT: We identify the main categories of recipients, rather than listing every individual organisation, as partners may change over time.

1. Group Entities and Operators

• Companies within the broader Tlc99 operating structure, to the extent necessary to manage your account, provide support, process payments, manage risk or comply with regulatory obligations
• Potential successor entities in case of reorganisation, merger, acquisition or transfer of business, subject to privacy protections at least as protective as this Policy

2. Payment and Financial Service Providers

• Banks, PayID intermediaries and financial institutions involved in processing fiat payments to and from your account
• Cryptocurrency payment processors, exchanges or wallet service providers used to support crypto deposits and withdrawals
• Fraud monitoring and chargeback handling providers

3. Technical and Professional Service Providers

• IT hosting and cloud infrastructure providers supporting tlc99-au.com
• Game suppliers and platform providers who host or operate games you access, where necessary to deliver the game and ensure fair play
• Identity verification, KYC, AML and sanctions screening providers
• Analytics, security monitoring and anti-fraud service providers
• Professional advisers (lawyers, auditors, tax advisers) where strictly required

4. Affiliates and Advertising Networks

• Marketing affiliates who refer players to tlc99-au.com, usually using pseudonymised identifiers and aggregated data
• Advertising networks and platforms for measuring campaign performance and, where legally permitted and based on consent where required, for targeted advertising

5. Public Authorities and Regulators

• Regulatory authorities in the jurisdictions where we are licensed or operate, such as gaming regulators or financial intelligence units, when required by their rules
• Law enforcement and other public authorities in any relevant jurisdiction where disclosure is required or permitted by law, court order or to protect our rights or the rights of others

We do not sell your personal information as that term is commonly understood, but we may share data with third parties for the purposes described in this Policy, subject to contractual confidentiality and data protection obligations.

International Transfers

OBSERVE: Tlc99 serves users in Australia while aspects of the operation, including potential licensing, hosting or support, may occur in other countries such as Curaçao, the Philippines and elsewhere in the Asia-Pacific region or beyond.

EXPAND: As a result, your information may be transferred to, stored in or accessed from countries whose privacy laws differ from those in Australia.

REFLECT: We adopt safeguards that align with recognised international standards to protect your information during these transfers.

• Your data may be processed in jurisdictions where our servers, group companies, game suppliers, KYC/AML providers, payment partners or support teams are located. This may include, without limitation, countries in the Asia-Pacific region, the European Economic Area (EEA), Curaçao, the Philippines and other locations.
• Where applicable and feasible, we use contractual mechanisms modelled on internationally recognised safeguards (such as standard data protection clauses and robust data processing agreements) requiring recipients to:
  • protect personal information with at least the same level of security and confidentiality we apply; and
  • use the information only for the specific purposes and in accordance with our instructions.
• We take technical and organisational measures (encryption in transit, strict access controls, logging and auditing) to reduce risks associated with cross-border transfers.

By using tlc99-au.com, you understand that your information may be transferred internationally as described in this section, subject to these safeguards.

Data Retention

OBSERVE: Gambling and financial services providers must retain records to comply with AML/CTF, tax and regulatory obligations, while also respecting data minimisation and storage limitation principles.

EXPAND: Different categories of data warrant different retention durations based on statutory requirements, contract needs and risk management considerations.

REFLECT: We adopt retention rules that are as specific as possible while acknowledging that laws and regulatory expectations may change.

• Account and identification data: Typically retained for up to 5 - 7 years after account closure or last transaction, to meet AML/CTF and record-keeping obligations in the applicable licensing jurisdiction and for the limitation periods of potential claims.
• Transactional and payment data: Retained for a minimum of 5 - 7 years from the relevant transaction date for accounting, audit and regulatory reasons.
• Gambling and behavioural data: Retained while your account is active and thereafter for as long as necessary (generally up to 5 years) to handle disputes, responsible gambling records and investigation logs.
• Marketing data: Retained while you remain opted-in and for a reasonable period (up to 2 years) after you withdraw consent, to record your opt-out and ensure we honour your preferences.
• Technical logs and security data: Stored for shorter periods (typically 6 - 24 months), unless required longer for specific investigations, security incidents or legal proceedings.
• Customer support communications: Retained for up to 5 years after resolution of the query or closure of the account, to manage follow-up questions and potential disputes.

When data is no longer required for the purposes for which it was collected and we are not legally obliged to keep it, we will securely delete, anonymise or de-identify it. If you request deletion, we will also assess whether we must retain certain data to comply with applicable law or to defend legal claims, in which case we will restrict its use to those limited purposes.

Your Rights

OBSERVE: Australian users expect strong privacy protections aligned with global best practice, including many rights similar to those under the EU General Data Protection Regulation (GDPR).

EXPAND: Although Tlc99 is focused on Australia, we structure our user rights framework broadly in line with GDPR-style standards, offering rights of access, correction, deletion, restriction, objection, portability and marketing opt-out. The prompt also references Mexican law; we therefore ensure that our rights framework is at least as protective as those regimes, even though our primary target market is Australia.

REFLECT: The following rights can be exercised free of charge, subject to limited exceptions. We respond without undue delay and generally within 30 days.

1. Right of Access

• You may request confirmation whether we process your personal information and obtain a copy of certain information we hold about you, together with details about how we use it.

2. Right to Rectification

• You may request that we correct or update inaccurate or incomplete personal information (for example, if your address or email has changed).

3. Right to Erasure ("Right to be Forgotten")

• You may ask us to delete personal information where:
  • it is no longer necessary for the purposes for which it was collected;
  • you have withdrawn consent (where consent was the only lawful basis); or
  • you believe we processed it unlawfully.
• This right is not absolute; we may retain information where required by anti-money laundering, gambling or other laws, or where necessary to establish, exercise or defend legal claims.

4. Right to Restrict Processing

• You may request that we limit processing of your data (for example, to storage only) where:
  • you contest the accuracy of the data (for a period enabling us to verify it);
  • processing is unlawful, but you do not want deletion; or
  • we no longer need the data, but you require it to establish, exercise or defend a legal claim.

5. Right to Object

• You may object at any time to:
  • processing of your data for direct marketing purposes (including profiling related to such marketing); and
  • processing based on our legitimate interests, where you believe your privacy interests outweigh our reasons.
• We will honour all objections to marketing and will assess other objections on a case-by-case basis.

6. Right to Data Portability

• To the extent applicable under international standards, you may request a copy of certain information in a structured, commonly used and machine-readable format and ask us to transmit it to another controller where technologically feasible.

7. Right to Withdraw Consent

• Where processing relies on your consent (e.g., marketing or certain cookies), you may withdraw consent at any time by adjusting your account preferences or contacting us.
• Withdrawal of consent will not affect prior lawful processing but may affect our ability to continue providing some optional services.

8. Procedure, Timeframes and Cost

• You can exercise your rights by:
  • contacting us at [email protected]; or
  • using any available account tools on tlc99-au.com (where offered) for access, corrections or marketing preferences.
• We will acknowledge and respond to your request without undue delay and, in any event, within 30 days of receipt. Where the request is particularly complex or numerous, we may extend this period, but will inform you of any extension and the reasons.
• We will not charge you for exercising your rights, unless requests are manifestly unfounded or excessive. In such cases, we may charge a reasonable fee or refuse to act, in accordance with applicable law.
• Before acting on a request, we may need to verify your identity (for example, by asking you to log in to your account or provide additional details) to protect your information against unauthorised access or deletion.

Cookies & Tracking Technologies

OBSERVE: tlc99-au.com relies on cookies and similar technologies for core functionality and to improve user experience.

EXPAND: Some cookies are strictly necessary for the site to function (for example, to keep you logged in), while others relate to performance, analytics or advertising.

REFLECT: Transparent explanation and user controls help align with international standards and user expectations.

Types of Cookies We Use

• Session cookies: Temporary cookies that remain on your device only while your browser is open. They support essential operations such as navigation, bet placement and maintaining your logged-in session.
• Persistent cookies: Remain on your device for a predefined period or until you delete them. They allow us to remember your preferences (e.g., language, region) and recognise you when you return.
• First-party cookies: Set directly by tlc99-au.com to support core functionality and security.
• Third-party cookies: Set by external providers, such as analytics services or advertising networks, to help us measure traffic and, where permitted, deliver or analyse marketing.

Purposes of Cookies

• Strictly necessary / functional: Enable you to navigate the site, use secure areas, perform account actions and place bets. These cookies are essential and cannot be turned off in our systems.
• Performance and analytics: Help us understand how visitors use tlc99-au.com, which pages are popular, and whether error messages are encountered. We typically use aggregated data from these cookies to improve performance and usability.
• Advertising and marketing: Used, where applicable and lawful, to measure effectiveness of our promotions and, with your consent where required, to deliver more relevant advertising on our site or third-party platforms.

Managing Cookies

• You can control cookies using your browser settings, where you may:
  • block all cookies;
  • block cookies from specific sites; or
  • delete cookies when you close your browser.
• If we provide an internal cookie or privacy settings panel on tlc99-au.com, you can use it to manage non-essential cookies and marketing preferences.
• Please note that blocking or deleting certain cookies may impact your ability to log in, place bets or use some features of the site.

Data Security

OBSERVE: Handling gambling, financial and identity information requires robust security that addresses confidentiality, integrity and availability.

EXPAND: We implement technical and organisational measures aligning with recognised international security practices (such as ISO 27001-type controls), and we continuously evolve them in response to threats and industry developments.

REFLECT: While no system can be guaranteed as perfectly secure, we are committed to maintaining a high standard of protection for your data.

Technical Measures

• Encryption in transit: We use TLS 1.2 or higher to encrypt data transmitted between your browser and tlc99-au.com, reducing the risk of interception.
• Encryption at rest (where appropriate): Sensitive data (such as passwords and certain financial identifiers) is encrypted or securely hashed to protect it against unauthorised access.
• Access controls: Personal information is accessible only to authorised personnel and service providers on a need-to-know basis, using role-based permissions and authentication controls. Multi-factor authentication (MFA) is implemented for key administrative systems where feasible.
• Network and system security: Firewalls, intrusion detection/prevention tools, anti-malware technologies and regular patching are used to protect our infrastructure.

Organisational Measures

• Policies and procedures: We maintain internal policies governing information security, acceptable use, access management and incident handling.
• Staff training: Employees and contractors with access to personal information receive training on data protection, confidentiality and security best practices relevant to their roles.
• Vendor due diligence: We assess service providers' security measures and include data protection clauses in our contracts.
• Regular reviews: Our security measures are periodically reviewed and improved to address emerging threats and regulatory expectations.

Incident Response

• We maintain procedures to detect, investigate and respond to potential data breaches or security incidents.
• Where required by applicable law, we will notify relevant authorities and affected users of a data breach without undue delay, providing information about what happened and recommended steps you can take to protect yourself.

Complaints & Contacts

OBSERVE: Users need clear channels to raise concerns, assert their rights and seek redress.

EXPAND: We provide a structured complaint process and information on escalation to supervisory authorities where applicable.

REFLECT: Transparent handling of complaints supports accountability and trust.

How to Contact Us

• E-mail (primary contact for privacy and complaints): [email protected]
• E-mail (general information): [email protected]
• Website: https://tlc99-au.com
• Telephone / postal address: not specified; contact us by email if you require alternative channels.

Internal Complaint Procedure

1. Submit your complaint: Send an email to [email protected] with:
   • your full name and, if applicable, your tlc99-au.com username;
   • a clear description of your concern or the right you wish to exercise; and
   • any relevant supporting documentation (e.g., screenshots, correspondence).
2. Acknowledgement: We aim to acknowledge receipt of your complaint within 5 business days.
3. Investigation: Your complaint will be reviewed by our Data Protection Team or other appropriate staff. We may contact you for further information or clarification.
4. Response: We will endeavour to provide a substantive response within 30 days from receipt of your complaint or request. If we cannot respond within this timeframe due to complexity or volume, we will inform you of the delay and the expected resolution date.
5. Further steps: If you are not satisfied with our response, you may request that your complaint be escalated within our organisation for further review.

Escalation to Supervisory Authorities

If, after contacting us, you are not satisfied with how we have handled your complaint or request, you may have the right to lodge a complaint with a relevant data protection or privacy authority in your country of residence or the place where you believe a breach occurred. For Australian users, the main authority is:

• Office of the Australian Information Commissioner (OAIC)
  Website: https://www.oaic.gov.au
  Online complaint form and contact details are available on the OAIC website.

Users located in other jurisdictions may contact their local data protection authority or privacy regulator, where applicable.

Updates

OBSERVE: Our services, technologies and regulatory environment may change over time.

EXPAND: We must be able to update this Privacy Policy while providing transparency about material changes and allowing users to react.

REFLECT: We use versioning, clear timestamps and proportional notification mechanisms.

Policy Changes and Version Control

• This Privacy Policy may be updated periodically to reflect changes in:
  • our services, practices or technology;
  • applicable laws or regulatory expectations; or
  • our corporate structure or licensing arrangements.
• The "Last updated" date at the end of this document shows the most recent revision.
• Where changes are minor (for example, clarifications or corrections) we will update the Policy on tlc99-au.com without special notice, but we encourage you to review it regularly.

Notification of Material Changes

• Where we make material changes that significantly affect how we process your personal information or your rights (such as introducing new data uses or changing international transfer practices), we will provide additional notice, which may include:
  • e-mail notifications to the address associated with your tlc99-au.com account;
  • prominent banners or pop-up notices on the website; and/or
  • notifications within your account dashboard (where available).
• Where feasible and required, we will provide such notice at least 30 days before the effective date of the material change, so you can review the updated Policy.

User Options on Changes

• If you do not agree with the updated Privacy Policy, you may:
  • adjust your privacy or marketing settings as allowed in your account; and/or
  • request account closure and, where permissible, deletion or restriction of your personal information.
• Continuing to use tlc99-au.com after the effective date of an updated Privacy Policy will generally be understood as your acceptance of the changes, to the extent permitted by law.

Last updated: January 2026