Privacy Notice

1. Information We May Collect

Depending on how you interact with TCC, we may process:

• first and last name;
• email address and mobile number;
• selected programme, session, cohort or service;
• trading-experience category and other programme-administration information you provide;
• registration, enrolment, attendance and completion status;
• programme acknowledgements and acceptance records;
• consent and marketing preferences;
• campaign source, referral or TCC Marketing Partner identifiers where included in a registration link;
• enquiry, support and complaint information;
• payment status and transaction reference when paid services are activated;
• learning-platform activity reasonably necessary to administer a programme;
• course, workshop and community membership, posts, comments, questions, participation activity and related learning records;
• where applicable to the Performance Lab or another evidence-based development service, profile information, assessment responses, journals, mentor observations, development records, performance evidence, Statements of Account or trade records submitted by the participant, performance analytics and intervention records;
• communication history; and
• reasonable technical information generated by website or service infrastructure, such as submission date/time, IP address, browser/device information or security metadata.

TCC does not require brokerage account credentials, trading passwords or brokerage login information to provide its educational services.

2. Why We Use Personal Information

We may process personal information to:

• register or enrol participants in TCC programmes and services;
• identify participants and maintain programme records;
• provide confirmations, access information, reminders and schedule updates;
• administer sessions, cohorts, learning resources, workshops, community spaces and participant support;
• establish and review trader-development profiles, assessments, evidence, progress, interventions and performance milestones where these form part of an applicable TCC programme;
• process cancellations, transfers, refunds and complaints;
• maintain acceptance, consent and transaction evidence;
• administer TCC Marketing Partner referrals and attribution where applicable;
• process payments when paid services are activated;
• protect TCC systems, participants and intellectual property from misuse or security threats;
• comply with applicable legal or regulatory requirements;
• establish, exercise or defend legal rights; and
• send optional marketing communications where you have separately opted in or another lawful basis applies.

3. Lawful Basis

Depending on the activity, TCC may process personal information on the basis of consent, steps requested before entering a contract, performance or administration of a contract, compliance with a legal obligation, or legitimate interests that do not override the rights of the data subject.

Where consent is used, it will be requested for the relevant purpose and may be withdrawn for future processing where applicable.

4. Necessary Service Communications

Programme and service communications necessary to administer a registration or enrolment are separate from optional marketing. TCC may contact participants about confirmation, access details, reminders, schedule changes, service delivery and support where reasonably necessary to provide the service.

5. Optional Marketing

Marketing consent is separate and optional and should remain unchecked by default. Declining marketing does not prevent a person from registering for or receiving a TCC service for which they are otherwise eligible.

You may withdraw marketing consent at any time by contacting TCC.

6. Operational Service Providers

TCC uses internal systems and third-party operational service providers where reasonably necessary to operate its website, administer the client journey, deliver learning services, communicate with participants, maintain records and protect its systems.

Current operational arrangements may include:

• The Foundry / TCC operational environment - TCC's internal operational system of record for participant, programme, consent, communication, evidence and administrative records, supported by infrastructure providers used to host, secure, store or process those records;
• TrainerCentral - learning-management, course, workshop, learner-account and community functionality, including enrolment, attendance, learning activity and community participation where enabled;
• Netlify - website hosting and related web infrastructure;
• Supabase - database, authentication, storage and supporting backend infrastructure used within TCC's operational systems; and
• Zoho Mail and other authorised communications providers - service, support and administrative communications where applicable.

Where TCC activates or materially changes a payment provider, account-data connectivity provider, analytics service or another material operational system, TCC will review the relevant privacy, security, processor and data-transfer arrangements and update this Notice where required.

TCC may change operational providers over time. Personal information will be shared only where reasonably necessary for the relevant service or processing purpose and subject to appropriate contractual, technical or organisational safeguards where required.

7. Brokerage Independence and No Brokerage Data Sharing

TCC is not a brokerage, introducing broker, broker affiliate or broker client-acquisition channel.

TCC does not sell, provide or transfer participant personal information to brokerages for broker marketing, client acquisition, account opening, trading-related solicitation or brokerage referral activity.

TCC does not receive brokerage commissions, trading rebates or broker referral payments for participant brokerage activity.

If a participant independently visits a brokerage website, application page or registration page, any personal information submitted there is collected directly by that brokerage under its own terms, privacy notice and regulatory arrangements. TCC does not control that independent collection.

8. TCC Marketing Partner Programme

TCC may operate a Marketing Partner Programme through which approved community members or partners refer prospective participants to TCC educational programmes or services.

Where referral or partner identifiers are used, TCC may process those identifiers to attribute a qualifying TCC registration or purchase and administer the applicable TCC referral reward. This programme relates only to TCC services and does not involve brokerage referrals or brokerage rebates.

9. Event, Session, Learning, Community and Performance-Development Data

Where TCC records a session or captures identifiable audio, video or images, TCC will provide appropriate notice and process that information for the stated purpose. Attendance administration, learning records and promotional use are not treated as automatically interchangeable purposes.

Where separate permission is required for promotional or marketing use of identifiable participant content, TCC will handle that permission separately.

TrainerCentral and other authorised learning environments may process learner-account information, enrolment and attendance records, course progress, workshop participation, community membership, posts, comments, questions, files, and other learning or community activity necessary to provide and administer the relevant service.

Where a participant joins the Performance Lab or another evidence-based trader-development service, TCC may process information such as Starting Trader Profile data, assessment responses, journals, participant-submitted Statements of Account or trade records, mentor observations, development reviews, performance analytics, intervention records and evidence used to assess programme milestones. TCC will use such information for declared trader-development, programme administration, evidence-integrity, review, support and related legitimate service purposes.

TCC does not require participants to provide brokerage passwords, authentication codes, remote-access credentials or authority to operate a trading account. Any future read-only account-data connection or materially different account-data collection will be subject to the applicable privacy notice and any additional authorisation or acknowledgement required for that activity.

Participant recording or screen capture of protected TCC programme or community content is governed by the applicable TCC General Terms of Service and Programme Terms.

10. International Processing

Some technology providers may process or store information outside the Philippines. TCC will take reasonable measures appropriate to the circumstances to protect personal information handled through its service providers and to maintain appropriate contractual or operational safeguards where required.

11. Retention

TCC may retain programme registrations, enrolment records, acceptance and consent records, enquiries, support records and related administrative information for up to five (5) years from the relevant registration, programme activity or last meaningful interaction where reasonably necessary for programme administration, participant-history verification, support, complaints, disputes, record keeping, legal protection or other legitimate business or legal purposes.

Information may be deleted or anonymised earlier where it is no longer reasonably required. Information may be retained longer where required by law or reasonably necessary for the establishment, exercise or defence of a legal claim.

The five-year period is a TCC retention policy and does not override the principle that personal information should be retained only while an appropriate purpose exists.

12. Security and Access Controls

TCC will maintain reasonable organisational and technical safeguards proportionate to the information it processes. Access to participant information should be limited to staff, contractors or authorised service providers who require access for legitimate TCC operations.

Participants should not send passwords, full payment-card numbers, brokerage credentials or other unnecessary sensitive information to TCC.

13. Personal Data Breaches

TCC will assess suspected personal-data breaches and will make notifications to affected individuals and the National Privacy Commission where legally required. Applicable notification requirements and timelines will be followed where a reportable breach is identified.

14. Data Subject Rights

Subject to applicable Philippine law, data subjects may have rights including:

• the right to be informed;
• access;
• objection;
• correction or rectification;
• erasure or blocking where applicable;
• data portability where applicable;
• damages where legally appropriate; and
• the right to file a complaint with the National Privacy Commission.

Privacy requests may be submitted to support@currencyclub.top. Reasonable identity verification may be required before TCC provides, changes or deletes personal records.

15. Automated Decision-Making and Profiling

TCC does not currently use automated decision-making or profiling that independently makes decisions producing significant effects on programme applicants or participants. If such processing is introduced, this Notice will be reviewed before use.

16. Browser Storage, Cookies and Tracking

The current TCC website may use limited technical or session storage necessary for website functionality, including preserving an active campaign route during a browser session.

TCC does not currently intentionally use behavioural-advertising or profiling technology on the website. If Meta Pixel, Google Analytics or other non-essential tracking or behavioural-advertising technology is introduced, TCC will conduct a separate cookie/tracking and privacy review before activation.

17. Third-Party Websites

TCC pages may link to third-party websites or services. Those organisations operate under their own terms and privacy practices. This Privacy Notice does not control how an independent third party processes information after a visitor leaves a TCC-controlled page.

18. Age

Trading-related TCC programme registration is generally limited to people aged 18 or older unless TCC expressly states otherwise for a particular service. If TCC discovers that information was submitted contrary to an applicable age requirement, it may investigate and restrict or delete the record as appropriate.

19. Changes to This Privacy Notice

TCC may update this Privacy Notice when its systems, providers, programmes or processing activities change. The applicable version and effective date will remain identifiable.

A material new use of personal information will not be treated as automatically covered by an earlier consent where applicable law requires a new notice, lawful basis or consent.

20. Contact and Privacy Requests

Privacy requests and privacy-related concerns may be submitted to: