Privacy Policy — 111jili

1 Introduction

This Privacy Policy ("Policy") describes how 111jili ("we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of users ("you" or "Player") who access or use the 111jili platform at https://111jili.org and all associated services (collectively, the "Service").

111jili is committed to protecting the privacy and personal data of all Filipino players who use our platform. We recognize that trust is the foundation of any good relationship — and that means being completely transparent about how we handle your information.

This Policy is issued in compliance with Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations. By registering for a 111jili account or using the Service, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

2 Data Controller

For the purposes of the Data Privacy Act of 2012 and this Policy, 111jili acts as the Personal Information Controller in respect of the personal data collected through the 111jili platform.

As Personal Information Controller, 111jili determines the purposes and means of processing your personal data and is responsible for ensuring that such processing is carried out in accordance with applicable Philippine data privacy laws and regulations.

If you have any questions, concerns, or requests relating to the processing of your personal data, you may contact our Data Protection Officer using the contact details provided in Section 15 of this Policy.

3 Personal Data We Collect

111jili collects the following categories of personal data from players:

3.1 Identity Data

• Full legal name as it appears on your government-issued identification
• Date of birth (to verify that you are at least 21 years of age)
• Gender
• Nationality and country of residence
• Government-issued identification number (e.g., Philippine National ID, passport, driver's licence)
• Copies of identity documents submitted for KYC (Know Your Customer) verification

3.2 Contact Data

• Email address
• Mobile phone number
• Residential address (including barangay, city/municipality, province, and postal code)

3.3 Financial Data

• GCash account number or registered mobile number
• PayMaya (Maya) account details
• Philippine bank account details (bank name, account number) for withdrawal processing
• Debit card details (card number, expiry date) where applicable
• Transaction history including deposits, withdrawals, and wagers

3.4 Technical Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session data including login timestamps and session duration
• Cookies and similar tracking technologies (see Section 8)

3.5 Gaming Data

• Game history, bet amounts, and outcomes
• Bonus and promotion usage history
• Responsible gaming settings and self-exclusion records
• Customer support interaction records including chat transcripts and support ticket history

4 How We Collect Your Data

111jili collects personal data through the following means:

• Direct collection: Information you provide when registering for a 111jili account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the 111jili platform, including through cookies, web beacons, and server logs. See Section 8 for full details on our use of cookies.
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment confirmation data from GCash, PayMaya, and Philippine banking partners.
• Regulatory sources: Information received from PAGCOR or other Philippine regulatory authorities in connection with licensing compliance, self-exclusion registers, or regulatory investigations.

5 Legal Basis for Processing

111jili processes your personal data on the following legal bases as recognized under the Data Privacy Act of 2012:

• Contractual necessity: Processing required to perform our contract with you — including account management, payment processing, and game delivery.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements, anti-money laundering (AML) obligations under RA 9160 as amended, and KYC requirements.
• Legitimate interests: Processing necessary for 111jili's legitimate business interests, including fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Where we rely on your consent as the legal basis for processing (for example, for certain marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 How We Use Your Personal Data

111jili uses the personal data we collect for the following purposes:

• Account management: Creating and maintaining your 111jili player account, verifying your identity and age (21+), and managing your account settings and preferences.
• Payment processing: Processing deposits and withdrawals through approved Philippine payment channels including GCash, PayMaya, and local bank transfers.
• Regulatory compliance: Meeting our obligations under PAGCOR licensing conditions, AML regulations, and the Data Privacy Act of 2012, including filing required reports with regulatory authorities.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, money laundering, unauthorized account access, and other illegal or prohibited conduct on the platform.
• Customer support: Responding to your enquiries, resolving complaints, and providing technical assistance through our 24/7 support channels.
• Service improvement: Analyzing usage patterns and player behavior (in aggregated, anonymized form where possible) to improve the 111jili platform, game selection, and user experience.
• Responsible gaming: Monitoring gaming activity to identify potential problem gambling behaviors and administering responsible gaming tools including deposit limits and self-exclusion.
• Marketing communications: Sending you information about 111jili promotions, bonuses, and new games where you have consented to receive such communications. You may opt out at any time.

7 Data Sharing & Disclosure

111jili does not sell your personal data. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya (Maya), BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, and other approved Philippine payment service providers, for the purpose of processing your deposits and withdrawals.
• KYC and identity verification providers: Third-party service providers who assist 111jili in verifying your identity and age in compliance with regulatory requirements.
• Fraud prevention and AML partners: Service providers who assist 111jili in detecting and preventing fraudulent activity and money laundering.
• Technology and platform providers: Cloud hosting providers, game software providers, and IT service providers who support the operation of the 111jili platform, subject to appropriate data processing agreements.
• Regulatory authorities: PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent Philippine government authorities, where disclosure is required by law or regulatory obligation.
• Professional advisers: Lawyers, auditors, and other professional advisers where necessary for the conduct of 111jili's business, subject to professional confidentiality obligations.

All third-party service providers who process personal data on behalf of 111jili are required to do so only in accordance with our instructions and in compliance with applicable data privacy laws. We do not permit our service providers to use your personal data for their own purposes.

8 Cookies & Tracking Technologies

111jili uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and analyze platform usage. The following types of cookies are used:

• Essential cookies: Strictly necessary for the operation of the 111jili platform, including session management, authentication, and security. These cookies cannot be disabled without affecting platform functionality.
• Functional cookies: Used to remember your preferences and settings, such as language preferences and responsible gaming configurations, to provide a more personalized experience.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the 111jili platform, helping us identify areas for improvement. This data does not identify individual players.
• Security cookies: Used to detect and prevent fraudulent activity, unauthorized access attempts, and other security threats to the platform and your account.

You can manage your cookie preferences through your browser settings. Please note that disabling essential cookies may prevent you from accessing certain features of the 111jili platform. For more information on managing cookies, refer to your browser's help documentation.

9 Data Retention

111jili retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

The following general retention periods apply:

• Account data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with PAGCOR licensing requirements and AML regulations.
• KYC and identity documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, as required by RA 9160 (Anti-Money Laundering Act) as amended.
• Transaction records: Retained for a minimum of five (5) years following the date of the transaction.
• Customer support records: Retained for three (3) years following the resolution of the relevant support interaction.
• Marketing consent records: Retained until you withdraw your consent or for three (3) years following your last interaction with 111jili marketing communications, whichever is earlier.

When personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, 111jili will securely delete or anonymize the data in accordance with our data disposal procedures.

10 Data Security

111jili implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption: All data transmitted between your device and the 111jili platform is encrypted using industry-standard SSL/TLS protocols.
• Data encryption at rest: Sensitive personal data, including financial information and identity documents, is encrypted when stored on 111jili's servers.
• Access controls: Access to personal data is restricted to authorized 111jili personnel and service providers who require it to perform their duties, on a strict need-to-know basis.
• Two-factor authentication: 111jili supports and encourages the use of two-factor authentication (2FA) to protect your account from unauthorized access.
• Regular security audits: 111jili conducts regular security assessments and penetration testing to identify and address potential vulnerabilities in our systems.
• Incident response: In the event of a personal data breach that poses a risk to your rights and freedoms, 111jili will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of RA 10173.

While 111jili takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the security of your 111jili account credentials and for notifying us immediately if you suspect unauthorized access to your account.

11 Your Data Subject Rights

Under the Data Privacy Act of 2012 of the Philippines, you have the following rights in relation to your personal data held by 111jili:

• Right to be informed: The right to be informed about how your personal data is collected, used, and processed — as set out in this Privacy Policy.
• Right of access: The right to request a copy of the personal data that 111jili holds about you, together with information about how it is being processed.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data that 111jili holds about you.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to applicable legal retention obligations.
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, and to transmit it to another data controller where technically feasible.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe that 111jili has processed your personal data in violation of RA 10173.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 15. We will respond to all valid requests within thirty (30) days. In complex cases, this period may be extended by a further thirty (30) days, and we will notify you accordingly.

12 Children's Privacy

The 111jili platform is strictly intended for adults aged 21 years and above in accordance with Philippine gaming regulations. 111jili does not knowingly collect personal data from individuals under the age of 21.

If you are under 21 years of age, you are not permitted to register for or use the 111jili Service. If 111jili becomes aware that personal data has been collected from a person under the age of 21, 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 provided personal data to 111jili, please contact us immediately using the details in Section 15 so that we can take appropriate action.

13 International Data Transfers

111jili primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to, or accessed by, service providers located outside the Philippines — for example, cloud infrastructure providers or game software suppliers operating internationally.

Where personal data is transferred outside the Philippines, 111jili ensures that appropriate safeguards are in place to protect your data in accordance with the requirements of RA 10173 and the regulations of the National Privacy Commission. Such safeguards may include:

• Contractual clauses requiring the recipient to process personal data to the same standard as required under Philippine law.
• Transfers to countries or organizations that have been assessed as providing an adequate level of data protection.
• Other legally recognized transfer mechanisms as approved by the National Privacy Commission.

14 Changes to This Privacy Policy

111jili reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. When material changes are made, we will notify registered players via email or a prominent notice on the 111jili platform prior to the changes taking effect.

The effective date at the top of this Policy will always reflect the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how 111jili protects your personal data.

Your continued use of the 111jili platform following the effective date of any amendment constitutes your acknowledgment of the updated Policy. If you do not agree with the changes, you may request account closure in accordance with our Terms & Conditions, available at 111jili.org/terms-conditions.

15 Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 111jili, please contact our Data Protection Officer:

We aim to respond to all data privacy enquiries within thirty (30) days. For urgent security concerns such as suspected unauthorized access to your account, please contact our 24/7 live support team immediately through the 111jili platform.