111jll Privacy Policy

01 Introduction

1.1 111jll ("we", "us", "our") is committed to protecting the privacy and personal data of every Filipino player who uses our online casino and sports betting platform at https://111jll.bet. This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of your personal information.

1.2 This policy is issued in compliance with Republic Act No. 10173, the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR) as administered by the National Privacy Commission (NPC) of the Philippines. It is also consistent with the guidelines of the Philippine Amusement and Gaming Corporation (PAGCOR) regarding player data management.

1.3 By accessing the 111jll platform, registering an account, making a deposit, or otherwise using our services, you acknowledge that you have read, understood, and consent to the data practices described in this Privacy Policy. If you do not agree, you must discontinue use of the 111jll platform.

1.4 This Privacy Policy should be read alongside our Terms and Conditions and our Responsible Gaming Policy, both of which are available on the 111jll platform.

02 Data We Collect

2.1 111jll collects personal data that is necessary to provide you with a safe, compliant, and personalised gaming experience. The categories of personal data we collect include:

2.2 111jll does not intentionally collect special categories of sensitive personal data (such as health data, political opinions, or religious beliefs) unless explicitly required for responsible gaming purposes (e.g., processing a self-exclusion request).

03 How We Collect Data

3.1 111jll collects personal data through the following means:

• Direct provision: Information you provide when registering an account, completing KYC, submitting a support request, or filling in any platform form;
• Automated technologies: Cookies, web beacons, pixel tags, and server logs that automatically record technical and usage data when you interact with the 111jll platform;
• Third-party providers: KYC verification partners, payment processors (GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard), fraud prevention services, and analytics providers may share relevant data with us in the course of providing their services;
• Publicly available sources: In limited circumstances, we may verify information against publicly available records or databases to comply with our anti-money laundering obligations.

04 How We Use Your Data

4.1 111jll uses the personal data we collect for the following purposes:

• To create and manage your 111jll player account;
• To verify your identity and age (21+) in accordance with PAGCOR requirements and Philippine law;
• To process deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard;
• To deliver and personalise your gaming experience across casino games, sports betting, bingo, and slots;
• To administer bonuses, promotions, and loyalty programmes;
• To detect, investigate, and prevent fraud, money laundering, and other prohibited activities;
• To send you account-related notifications, transaction receipts, and security alerts;
• To provide customer support in English and Filipino via live chat and email;
• To comply with legal and regulatory obligations, including PAGCOR reporting requirements and anti-money laundering (AML) obligations;
• To improve platform functionality, user experience, and game offering through aggregated analytics;
• To send marketing communications where you have consented to receive them (you may opt out at any time).

4.2 111jll will not use your personal data for purposes materially different from those listed above without providing you with prior notice and, where required, obtaining your consent.

05 Legal Basis for Processing

5.1 Under the Data Privacy Act of 2012, 111jll processes your personal data on one or more of the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and 111jll, including account management, payment processing, and game delivery;
• Legal obligation: Processing required to comply with Philippine laws and PAGCOR regulations, including KYC, AML reporting, and age verification;
• Legitimate interests: Processing necessary for 111jll's legitimate business interests, including fraud prevention, security monitoring, and platform analytics, where these interests are not overridden by your data rights;
• Consent: Processing based on your freely given, specific, and informed consent — primarily for direct marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

06 Sharing Your Data

6.1 111jll does not sell, rent, or trade your personal data. We may share your data with the following categories of trusted third parties, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard — to process financial transactions;
• KYC & identity verification providers: To carry out age and identity verification as required by PAGCOR;
• Game providers: Licensed third-party game studios that supply casino games, live dealer tables, slots, and bingo products available on the 111jll platform;
• Fraud prevention & security services: To detect and prevent fraudulent activity, money laundering, and unauthorised access;
• Cloud & hosting providers: Infrastructure partners who host the 111jll platform under strict data processing agreements;
• Regulatory & law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies where disclosure is required by law or court order.

6.2 All third-party processors engaged by 111jll are contractually required to process your personal data solely on 111jll's documented instructions and to implement appropriate technical and organisational security measures.

07 Data Retention

7.1 111jll retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, including satisfying legal, regulatory, accounting, or reporting obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in accordance with Philippine AML regulations;
• Transaction and financial data: Retained for a minimum of five (5) years following the transaction date, in accordance with PAGCOR and AMLC requirements;
• Communications data: Live chat and email records retained for up to two (2) years for quality assurance and dispute resolution purposes;
• Technical and usage data: Retained for up to twelve (12) months for security monitoring and platform analytics purposes.

7.2 Upon the expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be attributed to an identifiable individual.

08 Security Measures

8.1 111jll implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and 111jll servers;
• AES-256 encryption for sensitive data stored at rest;
• Multi-factor authentication (MFA) options for player accounts;
• Role-based access controls limiting staff access to personal data on a strict need-to-know basis;
• Continuous security monitoring, intrusion detection systems, and regular vulnerability assessments;
• PCI DSS-compliant payment processing to protect financial data;
• Regular staff training on data protection and information security best practices.

8.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 111jll will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, in accordance with the requirements of the Data Privacy Act of 2012.

09 Cookies & Tracking Technologies

9.1 111jll uses cookies and similar tracking technologies (including web beacons, pixel tags, and local storage) to operate the platform, enhance your user experience, and collect analytics data. The types of cookies we use are as follows:

• Strictly Necessary Cookies: Essential for the platform to function. These include session management, login authentication, and security cookies. These cannot be disabled without impairing platform functionality;
• Functional Cookies: Remember your preferences such as language settings, currency display (PHP), and game history to provide a personalised experience;
• Analytics Cookies: Collect aggregated, anonymised information about how players use the 111jll platform — such as which game categories are most popular and how players navigate between pages — to help us improve our service;
• Marketing Cookies: Used to deliver relevant promotional content and measure the effectiveness of 111jll marketing campaigns. These are only set with your consent.

9.2 You can manage and control cookie settings through your browser preferences. Most modern browsers (Chrome, Firefox, Safari, Edge) allow you to block or delete cookies. Please note that disabling strictly necessary cookies may prevent some parts of the 111jll platform from functioning correctly.

10 Your Rights

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

• Right to be Informed: The right to know whether 111jll holds personal data about you, and to be informed of the purposes and manner of its processing;
• Right of Access: The right to request a copy of the personal data 111jll holds about you, along with information about how it is processed;
• Right to Rectification: The right to request correction of any inaccurate, incomplete, or outdated personal data we hold 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 111jll's 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 111jll's 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 your data rights have been violated.

10.2 To exercise any of the above rights, please contact the 111jll Data Protection Officer at [email protected] with the subject line "Data Rights Request". We will respond to all verified requests within thirty (30) days, in accordance with NPC guidelines.

11 Children & Minors

11.1 The 111jll platform is strictly intended for persons aged 21 years and above, in accordance with Philippine gambling regulations. 111jll does not knowingly collect personal data from individuals under the age of 21.

11.2 If 111jll becomes aware that personal data has been collected from a person under the age of 21, we will immediately suspend the associated account, delete the personal data in question, and take appropriate steps in accordance with applicable law.

11.3 If you are a parent or guardian and believe your child may have provided personal data to 111jll, please contact us immediately at [email protected]. We take underage gambling prevention extremely seriously and will act on all such reports without delay.

12 International Data Transfers

12.1 In providing our services, some of your personal data may be transferred to, stored in, or processed in countries outside of the Philippines. This may occur when 111jll uses cloud hosting providers or third-party game providers whose infrastructure is located in other jurisdictions.

12.2 Where such transfers occur, 111jll ensures that adequate safeguards are in place to protect your personal data in accordance with the requirements of the Data Privacy Act of 2012. These safeguards include contractual data processing agreements that require overseas recipients to maintain data protection standards equivalent to those required by Philippine law.

12.3 By using the 111jll platform and accepting this Privacy Policy, you consent to the international transfer of your personal data as described in this section, subject to the safeguards described above.

13 Changes to This Policy

13.1 111jll reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or platform functionality. When material changes are made, we will publish the revised policy on this page with an updated "Last Updated" date.

13.2 For significant changes that materially affect how we process your personal data, 111jll will endeavour to notify you via your registered email address. However, it remains your responsibility to review this Privacy Policy periodically to stay informed of our current practices.

13.3 Your continued use of the 111jll platform following the publication of any revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree to any changes, you must cease using the platform and may request account closure.

14 Contact Us

14.1 If you have any questions, concerns, or requests regarding this Privacy Policy or how 111jll processes your personal data, please contact our Data Protection Officer using the following details:

• Email: [email protected]
• Subject Line: "Privacy Policy Enquiry" or "Data Rights Request"
• Live Chat: Available 24/7 directly through the 111jll platform
• Response Time: We aim to respond to all privacy-related enquiries within 5 business days and data rights requests within 30 days

14.2 If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority for data protection matters in the Philippines.