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;
• 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 and participant support;
• 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Where consent is used, it will be requested for the relevant purpose and may be withdrawn for future processing where applicable.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 third-party operational systems where reasonably necessary to run its website, client journey and educational services. Current operational providers include:

• Netlify - website hosting and website form processing;
• Zoho CRM / Zoho Flow - participant records, programme-registration processing, consent records and workflow automation; and
• Google / Gmail - email communication and related business correspondence.

TCC intends to use TrainerCentral as a learning-management platform for selected programmes. Participant information will not be transferred to TrainerCentral until the relevant programme configuration is activated and TCC has confirmed the required privacy, processor and data-transfer arrangements.

Where TCC later activates a payment provider such as Maya, or another material operational system, this Privacy Notice will be reviewed and updated before relevant personal information is transferred where an update is 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 and Learning Data

TCC may process attendance, participation, chat, learning-progress or similar information where reasonably necessary to administer an educational programme.

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.

Participant recording or screen capture of protected TCC programme 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 learntradingin21days@gmail.com. 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: