Privacy Policy of 111jl

This Privacy Policy ("Policy") describes how 111jl ("Company," "we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of individuals ("you," "your," or "Player") who access or use the 111jl online gaming platform at https://111jl.ws and all associated services, features, and applications (collectively, the "Platform").

111jl is committed to protecting the privacy and personal data of all Filipino players and users of the Platform. This Policy has been prepared in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

By registering for a 111jl account, accessing the Platform, or using any of our services, you acknowledge that you have read and understood this Privacy Policy and you consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please discontinue use of the Platform immediately.

This Policy applies to all personal data collected through the Platform, including data submitted during registration, KYC verification, deposits and withdrawals, gameplay activity, customer support interactions, and any other engagement with 111jl services.

111jl collects personal data that is necessary to provide a secure, compliant, and functional online gaming experience. The categories of personal data we collect are as follows:

2.1 Registration & Identity Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (used to verify that you meet the 21+ age requirement);
• Email address and mobile phone number;
• Username and encrypted account password;
• Residential address (city, province, region within the Philippines).

2.2 Identity Verification (KYC) Data

• Copies of government-issued identification documents (e.g., Philippine National ID, passport, driver's license, SSS/GSIS card, voter's ID);
• Selfie or live photo for biometric identity verification purposes;
• Source of funds documentation where required for enhanced due diligence.

2.3 Financial & Transaction Data

• GCash account number, Maya/PayMaya account details, or linked bank account information (BPI, BDO, Metrobank);
• Deposit and withdrawal transaction history, amounts, and timestamps;
• Payment method reference numbers and transaction IDs.

2.4 Gameplay & Activity Data

• Game session records including games played, bet amounts, wins, losses, and session duration;
• Bonus and promotion usage history;
• Responsible gaming tool activations (deposit limits, self-exclusion requests, cooling-off periods).

2.5 Technical & Device Data

• IP address and general geolocation (city/region level);
• Device type, operating system, and browser information;
• Cookie identifiers and session tokens;
• Platform access logs and timestamps.

2.6 Communications Data

• Records of customer support chat transcripts and email correspondence;
• Feedback, complaints, and dispute records submitted to 111jl.

111jl uses your personal data only for purposes that are directly related to the provision, improvement, and security of the Platform. The specific purposes for which we process your data are:

• Account Creation & Management: To register your account, verify your identity, maintain your player profile, and provide access to 111jl services;
• Age & Identity Verification: To confirm that you meet the minimum age requirement of 21 years and to verify your identity as required by our KYC obligations;
• Payment Processing: To facilitate deposits and withdrawals via your chosen payment channel (GCash, Maya, BPI, BDO, Metrobank, etc.) and to maintain accurate transaction records;
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, unauthorized account access, and other illegal conduct on the Platform;
• Regulatory Compliance: To fulfill our obligations under applicable Philippine law, including the Anti-Money Laundering Act (AMLA), the Data Privacy Act (RA 10173), and PAGCOR regulatory requirements;
• Customer Support: To respond to your inquiries, resolve disputes, and provide assistance with account-related matters;
• Responsible Gaming: To monitor gameplay patterns that may indicate problem gambling behavior, and to administer responsible gaming tools such as deposit limits and self-exclusion;
• Platform Improvement: To analyze usage data and improve the features, performance, and user experience of the 111jl platform;
• Communications: To send you transactional notifications (e.g., deposit confirmations, withdrawal updates) and, where you have opted in, promotional communications about 111jl offers and tournaments.

Under the Philippine Data Privacy Act of 2012 (RA 10173), 111jl processes your personal data on one or more of the following lawful bases:

• Consent: Where you have given your explicit consent to the processing of your personal data for one or more specific purposes — for example, when you complete the registration form and agree to this Privacy Policy;
• Contractual Necessity: Where processing is necessary for the performance of the contract between you and 111jl — including account management, payment processing, and the provision of gaming services as set out in our Terms & Conditions;
• Legal Obligation: Where processing is required to comply with a legal obligation to which 111jl is subject — including KYC requirements, anti-money laundering reporting, and regulatory directives from PAGCOR and the NPC;
• Legitimate Interests: Where processing is necessary for the legitimate interests pursued by 111jl, including fraud prevention, platform security, and service improvement, provided that such interests are not overridden by your fundamental rights and freedoms.

Where we rely on consent as the legal basis for processing, you have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing that occurred prior to the withdrawal.

111jl does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. Your personal data may be shared only in the following limited circumstances:

• Payment Service Providers: We share necessary financial data with regulated payment processors to facilitate transactions. These include GCash (Mynt), Maya (Paymaya Philippines), GrabPay, InstaPay-connected banks (BPI, BDO, Metrobank), and QR Ph network operators. These providers are bound by strict data protection obligations;
• Identity Verification Partners: We may share KYC documentation with regulated identity verification service providers to fulfill our age and identity verification obligations;
• Game Content Providers: Certain gameplay data may be shared with our licensed game content providers (such as JILI Games) for the purpose of game operation, dispute resolution, and audit purposes;
• Regulatory & Law Enforcement Authorities: We are legally required to disclose certain data to Philippine government authorities, including the Anti-Money Laundering Council (AMLC), PAGCOR, the Bureau of Internal Revenue (BIR), and law enforcement agencies, upon receipt of a valid legal order or as required by applicable law;
• Professional Advisors: We may share personal data with our legal counsel, auditors, and compliance consultants where necessary for the purposes of legal advice, audit, or regulatory filing, subject to professional confidentiality obligations;
• Business Transfers: In the event of a merger, acquisition, restructuring, or sale of 111jl's business assets, your personal data may be transferred to the successor entity, subject to the same data protection obligations as set out in this Policy.

111jl uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small data file placed on your device when you visit a website. Cookies allow us to recognize your browser, maintain your session, and remember your preferences.

The types of cookies used on the 111jl platform are as follows:

Essential and security cookies are strictly necessary for the operation of the Platform and cannot be disabled without affecting core functionality. Functional and analytics cookies can be managed through your browser settings. Most browsers allow you to refuse cookies, delete existing cookies, or receive a warning before a cookie is stored.

111jl retains your personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account Data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements;
• KYC & Identity Documents: Retained for a minimum of five (5) years from the date of the last transaction or account closure, as required under the Anti-Money Laundering Act (RA 9160, as amended);
• Transaction Records: Retained for a minimum of five (5) years to satisfy financial audit and regulatory reporting obligations;
• Customer Support Records: Retained for two (2) years following the resolution of the relevant inquiry or dispute;
• Technical & Log Data: Retained for twelve (12) months for security monitoring and fraud investigation purposes;
• Marketing Preferences: Retained until you withdraw consent or request removal, whichever is earlier.

Upon expiry of the applicable retention period, personal data will be securely deleted, anonymized, or archived in a manner that prevents re-identification, in accordance with NPC guidelines on data disposal.

111jl implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security framework includes:

• Encryption: All data transmitted between your device and the 111jl platform is encrypted using TLS (Transport Layer Security) 1.2 or higher. Account passwords are stored using industry-standard one-way hashing algorithms;
• Access Controls: Access to personal data is restricted to authorized 111jl personnel who require it for their specific job functions. All staff with data access undergo regular security training;
• Infrastructure Security: 111jl's servers are hosted in secure, access-controlled data center facilities with continuous monitoring, firewalls, intrusion detection systems, and regular vulnerability assessments;
• Payment Security: Financial data processed through GCash, Maya, and bank channels is handled exclusively by PCI DSS-compliant payment processors. 111jl does not store full payment card numbers or complete e-wallet credentials on its servers;
• Incident Response: 111jl maintains a documented data breach response procedure. In the event of a personal data breach that poses a real risk to your rights and freedoms, 111jl will notify the National Privacy Commission (NPC) and affected individuals in accordance with NPC Circular requirements.

Under the Philippine Data Privacy Act of 2012 (RA 10173) and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by 111jl:

• Right to Be Informed: The right to be told how your personal data is collected, used, and shared — which is the primary purpose of this Privacy Policy;
• Right to Access: The right to request a copy of the personal data that 111jl holds about you, along with information about how it is being processed;
• Right to Correction: The right to request correction of inaccurate, incomplete, or outdated personal data in your 111jl account;
• Right to Erasure / Right to Be Forgotten: 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 overriding legal retention obligations;
• Right to Object: The right to object to the processing of your personal data for 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, machine-readable format where technically feasible;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission (NPC) of the Philippines if you believe that your data privacy rights have been violated.

To exercise any of the above rights, please submit a written request to [email protected]. Please include your full name, registered email address, and a description of the right you wish to exercise. 111jl will respond to your request within fifteen (15) business days from receipt, in accordance with NPC guidelines.

The 111jl platform is strictly intended for use by adults aged 21 years and above, in accordance with Philippine law governing participation in casino-style online gambling. 111jl does not knowingly collect, process, or store personal data of individuals under the age of 21.

During the registration process, all users are required to confirm their age and to submit verifiable government-issued identification. 111jl's KYC procedures are specifically designed to identify and prevent underage registration.

If 111jl becomes aware that personal data of a person under the age of 21 has been collected — whether through misrepresentation during registration or any other means — the following actions will be taken immediately:

• The account will be permanently suspended;
• All personal data associated with the account will be deleted from 111jl's systems, subject to any mandatory legal retention requirements;
• Any funds in the account will be handled in accordance with applicable regulations.

Parents and guardians who believe that a minor has registered on the 111jl platform are urged to contact us immediately at [email protected] so that we can take prompt action. We take underage access to gambling platforms with the utmost seriousness.

The 111jl platform may, from time to time, contain references to third-party services such as payment processors, game providers, or regulatory bodies. While these references are made in good faith for informational purposes, 111jl does not control the privacy practices of third-party websites or services and is not responsible for their content or data handling practices.

This Privacy Policy applies exclusively to the 111jl platform at https://111jl.ws. When you interact with a third-party service — for example, when initiating a GCash or Maya transaction — you will be subject to that service provider's own privacy policy and terms of use. 111jl encourages you to review the privacy policies of any third-party services you use in connection with your 111jl account.

111jl primarily stores and processes personal data within secure facilities serving the Philippines. In limited circumstances — for example, where a game content provider or technical infrastructure partner operates servers in another country — your personal data may be transferred to, stored in, or processed in a jurisdiction outside the Philippines.

Where such international transfers occur, 111jl ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under Philippine law. These safeguards may include:

• Contractual clauses requiring the recipient to process personal data in accordance with RA 10173 and NPC standards;
• Transfers only to entities operating in jurisdictions with adequate data protection laws as recognized by the NPC;
• Data processing agreements that impose binding data protection obligations on all third-party processors.

By using the 111jl platform and agreeing to this Privacy Policy, you consent to the transfer of your personal data to third-party processors in other jurisdictions, subject to the safeguards described above.

111jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, our data processing practices, or the features of the Platform. The current version of this Policy will always be accessible at https://111jl.ws/privacy-policy.

When material changes are made to this Policy, 111jl will provide notice to registered users by one or more of the following methods:

• Displaying a prominent notice on the 111jl platform upon your next login;
• Sending a notification to the email address registered to your account;
• Updating the "Effective Date" shown at the top of this Policy.

Your continued use of the 111jl platform following notification of changes to this Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree to the updated terms, you must stop using the Platform and may request account closure by contacting [email protected].

111jl recommends that you review this Privacy Policy periodically to stay informed about how we are protecting your personal data.

111jl has designated a Data Protection Officer (DPO) in accordance with the requirements of the Philippine Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, you may contact us through the following channel:

If you are not satisfied with 111jl's response to your data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the regulatory authority responsible for enforcing RA 10173. Information on how to file a complaint with the NPC is available on the NPC's official government website.

111jl takes all data privacy inquiries seriously and will make every effort to address your concerns promptly, fairly, and transparently. We are committed to maintaining the trust of every Filipino player who chooses to enjoy the 111jl platform.