111jll Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 111jll ("Company," "Platform," "we," "us," "our"), operating the website at 111jll.cam, collects, processes, stores, and protects the personal information of individuals ("Player," "User," "you") who register for, access, or use 111jll's online gaming services.

111jll is committed to safeguarding the privacy of every Filipino player who entrusts us with their personal data. This Policy is designed to comply with the Republic Act No. 10173 — the Philippines' Data Privacy Act of 2012 — and its implementing rules and regulations, as administered by the National Privacy Commission (NPC). We are equally guided by applicable anti-money-laundering regulations that require the collection and retention of certain identity and financial data.

By registering a 111jll account, depositing funds, or otherwise using the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal information as described herein. If you do not agree to this Policy, please do not use the 111jll platform and contact our support team to close your account.

2. Data Controller

For the purposes of the Data Privacy Act of 2012 and applicable data protection law, 111jll is the data controller responsible for the personal information collected through the platform. As data controller, 111jll determines the purposes and means by which your personal data is processed.

Where 111jll engages third-party service providers to process personal data on its behalf — including payment processors, KYC verification providers, and fraud detection services — those providers act as data processors under written data processing agreements that obligate them to handle your information in accordance with this Policy and applicable law.

For all privacy-related inquiries, you may contact the 111jll Data Protection Officer (DPO) using the contact details provided in Section 15 of this Policy.

3. Personal Data We Collect

111jll collects personal data through multiple channels: directly from you during account registration and KYC verification; automatically through your use of the platform; and from third-party service providers involved in payment processing and identity verification. The categories of personal data we collect include:

111jll does not collect or process sensitive personal information as defined under the Data Privacy Act of 2012 (e.g., racial or ethnic origin, religious beliefs, health records) except where voluntarily disclosed by you in support communications and strictly necessary for the matter at hand.

4. How We Use Your Personal Data

111jll uses the personal data collected for the following specific, legitimate purposes:

4.1 Account Management

Your identity and contact data are used to create, maintain, and manage your 111jll player account, including verifying your eligibility to use the platform, maintaining your account dashboard, processing your login credentials, and sending account-related notifications such as deposit confirmations, withdrawal updates, and security alerts.

4.2 Payment Processing

Financial data including your GCash number, Maya account details, or bank account information is used exclusively to process deposits to and withdrawals from your 111jll account. This data is shared with our authorised payment processing partners solely for transaction execution and fraud prevention purposes.

4.3 Regulatory Compliance

111jll is required by applicable Philippine law — including the Anti-Money Laundering Act (AMLA) and PAGCOR regulations — to collect, verify, and retain certain identity and financial records. KYC documentation and transaction histories are maintained in compliance with these legal obligations and may be disclosed to regulatory authorities upon lawful request.

4.4 Platform Security and Fraud Prevention

Technical data (IP addresses, device identifiers, login timestamps) is used to monitor for unauthorised access, detect multi-account violations, identify bonus abuse, and protect the integrity of the 111jll platform. This processing is conducted in 111jll's legitimate interest to maintain a secure and fair gaming environment for all players.

4.5 Customer Support

Communications data is used to respond to your inquiries, resolve disputes, process complaints, and improve the quality of 111jll's support services. Support interactions may be recorded for quality assurance and training purposes with appropriate access controls in place.

4.6 Responsible Gaming

Gaming activity data — including session frequency, bet sizes, and loss patterns — is used by 111jll's responsible gaming system to identify players who may be exhibiting signs of problem gambling behaviour. This processing enables 111jll to trigger proactive outreach, apply account limits, or initiate cooling-off periods in accordance with our responsible gaming obligations.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 111jll processes your personal data on the following lawful bases:

• Contractual necessity: Processing required to perform the contract between you and 111jll (i.e., to operate your account and provide gaming services);
• Legal obligation: Processing required to comply with applicable Philippine law, including AML obligations, PAGCOR regulations, and NPC data management standards;
• Legitimate interests: Processing conducted for 111jll's legitimate interests in preventing fraud, maintaining platform security, and ensuring the integrity of the gaming environment — where such interests are not overridden by your fundamental rights;
• Consent: Processing for optional purposes — such as marketing communications — conducted only where you have provided explicit, freely given, and informed consent. You may withdraw marketing consent at any time.

6. Data Sharing & Disclosure

111jll shares your personal data with third parties only in the following defined circumstances:

1. Payment processors: GCash (Mynt), Maya (PayMaya Philippines), BancNet, and other authorised payment service providers receive financial data necessary to execute transactions on your behalf;
2. KYC and identity verification providers: Third-party identity verification services receive your government ID documents and selfie images solely for the purpose of verifying your identity prior to withdrawal;
3. Fraud and AML detection services: Transaction data may be shared with authorised fraud prevention and anti-money-laundering compliance partners;
4. Regulatory and law enforcement authorities: 111jll will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, or law enforcement agencies where required by law or upon receipt of a valid legal order;
5. Game software providers: Certain gameplay data (game round IDs, bet values) is transmitted to licensed game providers to generate outcomes and resolve disputes. Personally identifiable information is not shared with game providers beyond what is technically necessary;
6. Corporate transactions: In the event of a merger, acquisition, or restructuring involving 111jll, your personal data may be transferred to the successor entity, with appropriate notice to you.

7. Data Retention

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

• Account data and KYC documents: Retained for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Gaming activity records: Retained for three (3) years from the date of each game session;
• Support communications: Retained for two (2) years following resolution of the relevant matter;
• Technical logs: Retained for up to twelve (12) months for security and audit purposes.

Where retention beyond these standard periods is required by law or regulatory order, 111jll will retain the relevant data until the applicable obligation is satisfied. Data that is no longer required is securely deleted or anonymised in accordance with 111jll's data disposal procedures.

8. Data Security

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

• Transport encryption: All data transmitted between your device and 111jll servers is encrypted using TLS 1.2 or higher (256-bit SSL);
• Storage encryption: Sensitive data stored on 111jll servers — including KYC documents and financial records — is encrypted at rest using AES-256 encryption;
• Access controls: Access to personal data is restricted on a strict need-to-know basis, with role-based access controls and multi-factor authentication required for all staff with data access;
• Password security: Player passwords are stored using one-way cryptographic hashing; 111jll staff cannot view your password in plain text;
• Penetration testing and audits: 111jll engages independent security firms to conduct periodic penetration tests and security audits of its systems;
• Incident response: In the event of a data breach that poses a risk to your rights, 111jll will notify the National Privacy Commission (NPC) within 72 hours of discovery, and will notify affected players without undue delay.

While 111jll takes all reasonable steps to protect your personal data, no online system can be guaranteed to be completely secure. You are responsible for maintaining the confidentiality of your own 111jll login credentials and for immediately notifying 111jll if you suspect any unauthorised access to your account.

9. Cookies & Tracking Technologies

111jll uses cookies and similar tracking technologies to operate the platform, maintain your logged-in session, and understand how players interact with the site. A "cookie" is a small text file stored on your device by your web browser.

9.1 Types of Cookies Used

• Essential cookies: Strictly necessary for the platform to function — including session management, login persistence, security tokens, and load balancing. These cannot be disabled without breaking core platform functionality;
• Analytics cookies: Used to collect anonymised data about how players navigate the 111jll platform, which pages are most visited, and where players encounter errors. This data is used to improve the platform experience;
• Fraud prevention cookies: Used to detect suspicious browser behaviour, identify potential bot traffic, and protect the platform's integrity;
• Preference cookies: Used to remember your in-session preferences such as language and display settings.

9.2 Managing Cookies

You can configure your browser to block or delete cookies at any time. However, disabling essential cookies will prevent you from accessing your 111jll account and using core platform features. Instructions for managing cookies are available in your browser's settings or help documentation. 111jll does not use cookies for cross-site advertising or third-party tracking purposes.

10. Your Privacy Rights

As a data subject under the Data Privacy Act of 2012 and applicable privacy law, you have the following rights in respect of the personal data that 111jll holds about you:

To exercise any of the rights listed above, submit a written request to the 111jll Data Protection Officer using the contact details in Section 15. 111jll will respond to all verified data rights requests within thirty (30) calendar days of receipt. Where a request is complex or high in volume, an extension of up to a further thirty (30) days may apply, and you will be notified accordingly.

Note that certain rights are subject to limitations — for example, the right to erasure does not override 111jll's legal obligation to retain transaction records for anti-money-laundering compliance. Where 111jll cannot fulfill a request in full, we will explain the specific reason and what partial steps can be taken.

11. Minors & Age Policy

111jll strictly prohibits access by individuals under the age of twenty-one (21) years, in accordance with Philippine gaming regulations. The 111jll platform does not knowingly collect personal data from individuals under 21. Age verification is conducted as part of the registration and KYC process to enforce this requirement.

If 111jll discovers or is notified that personal data belonging to an individual under 21 has been collected — whether through misrepresentation during registration or any other means — that data will be immediately deleted, the associated account will be permanently closed, and the matter may be referred to relevant authorities. If you are a parent or guardian and believe your child has registered a 111jll account, please contact the DPO at the address in Section 15 immediately.

12. International Data Transfers

Certain personal data processed by 111jll may be transferred to and stored in servers or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or internationally operating KYC verification services. Where such transfers occur, 111jll takes steps to ensure your personal data receives a level of protection consistent with the Data Privacy Act of 2012.

These steps may include entering into contractual data transfer arrangements with the receiving party, verifying that the receiving jurisdiction has adequate data protection standards, or applying appropriate safeguards such as standard contractual clauses. You may request details of the specific safeguards in place for international transfers by contacting the DPO.

13. Third-Party Services & Links

The 111jll platform may contain references to third-party game providers, payment processors, or other services. This Privacy Policy applies only to data processed directly by 111jll through the 111jll.cam platform. 111jll is not responsible for the privacy practices of third-party game software providers, and players are encouraged to review the privacy policies of those providers independently.

When you use a payment method such as GCash or Maya to deposit or withdraw funds at 111jll, the transaction is also governed by GCash's and Maya's respective privacy policies and terms of service. 111jll's handling of your payment data is limited to what is necessary to initiate and verify transactions on your behalf.

14. Policy Updates & Amendments

111jll reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, platform operations, or data processing practices. The effective date of the most recent version is displayed at the top of this document.

For material changes — those that significantly affect your rights or how your personal data is used — 111jll will notify registered players by email or via a prominent in-platform notification at least fourteen (14) days before the change takes effect. Your continued use of the 111jll platform after the effective date of any amendment constitutes your acceptance of the revised Policy.

Previous versions of the 111jll Privacy Policy are available upon request from the DPO.

15. Contact & Data Protection Officer

111jll has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests related to your personal data and how it is handled by 111jll, please contact the DPO through the following channels:

Data Protection Officer — 111jll
Email: [email protected]
Subject Line: Data Privacy Inquiry / [Your Account Username]

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated and your complaint has not been adequately resolved by 111jll. The NPC provides complaint and advisory services to Philippine data subjects, and 111jll cooperates fully with all NPC inquiries and investigations.