111ji Privacy Policy – How We Handle Your Personal Data

About This Privacy Policy

This Privacy Policy applies to all personal data collected and processed by 111ji ("we," "us," "our") in connection with your use of the 111ji online gaming platform at 111ji.app. It covers data collected through account registration, gaming activity, payment transactions, customer support interactions, and your general use of the site and any associated mobile interfaces.

111ji is committed to handling your personal information responsibly and in accordance with applicable Philippine data protection laws, including the Data Privacy Act of 2012 (Republic Act 10173). We take our obligations as a data controller seriously, and this policy is designed to give you a clear and honest picture of how your data flows through the 111ji platform.

By registering an account on 111ji and using any part of the platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with how 111ji handles your personal data, please do not register an account or continue using the platform.

Personal Data We Collect

2.1 Identity and Registration Data

When you register your 111ji account, we collect your full legal name, date of birth, gender, and a copy of a government-issued identification document for identity verification purposes. This data is required to comply with our know-your-customer (KYC) obligations and to confirm that you meet the minimum age requirement of 21 years.

2.2 Contact Data

We collect your email address, Philippine mobile number, and residential address. These are used to communicate account-related notifications, verify your identity, process withdrawals to your registered address, and reach you if there is a security issue with your account.

2.3 Financial and Payment Data

When you make a deposit or request a withdrawal on 111ji, we collect information about the payment method used — such as your GCash-registered mobile number, Maya account reference, or bank account name and number. Full card numbers and sensitive authentication credentials are handled directly by our payment processing partners and are not stored on 111ji servers.

2.4 Gaming Activity Data

We maintain records of all gaming activity associated with your 111ji account, including wagers placed, games played, session durations, wins and losses, and bonus usage. This information is used for account management, dispute resolution, fraud prevention, responsible gaming monitoring, and regulatory reporting purposes.

2.5 Device and Technical Data

When you access 111ji, our systems automatically collect certain technical information including your IP address, browser type and version, operating system, device identifiers, time zone, and referring URLs. This data helps us secure the platform, diagnose technical issues, prevent fraudulent access, and improve performance across different devices and connection types.

2.6 Communications Data

If you contact 111ji support — whether by email, live chat, or any other channel — we retain records of your communications, including your messages and our responses. This allows us to track the resolution of your issues, maintain quality standards, and refer back to previous interactions if a related issue arises.

How We Collect Your Data

111ji collects your personal data through the following channels:

• Direct input: Information you provide when registering your account, completing identity verification, making deposits or withdrawals, or contacting support.
• Automated collection: Technical and usage data collected automatically as you browse and interact with the 111ji platform, through cookies, server logs, and analytics tools.
• Third-party sources: Identity verification providers, payment processors, and fraud prevention services may share data with us to supplement what you have provided directly, for the purpose of verifying your identity and protecting your account.
• Publicly available sources: In limited circumstances, we may cross-reference your information against publicly available data — for example, to validate an address or confirm that a name matches official records — as part of our compliance obligations.

How We Use Your Personal Data

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

111ji does not sell your personal data to third parties for their own marketing purposes. We do not use your gaming data to create profiles for third-party advertising networks.

Legal Bases for Processing

Under the Data Privacy Act of 2012, 111ji must have a valid legal basis for each type of personal data processing. The bases we rely on are:

• Contractual necessity: Processing required to perform our contract with you — operating your account, processing payments, and settling wagers.
• Legal obligation: Processing required to comply with applicable law — including KYC, anti-money laundering checks, and regulatory reporting.
• Legitimate interests: Processing for fraud prevention, platform security, and improving the 111ji experience, where our interests do not override your data protection rights.
• Consent: For certain marketing communications, if applicable, we will ask for your explicit consent and provide an easy way to withdraw it at any time.

Who We Share Your Data With

111ji shares your personal data only with the categories of third parties listed below, and only to the extent necessary for the stated purpose. We do not sell or rent your data.

• Payment processors: GCash, Maya, GrabPay, Coins.ph, InstaPay/PESONet, BDO, BPI, UnionBank and Visa/Mastercard processing networks — to facilitate deposits and withdrawals in Philippine pesos.
• Identity verification providers: Third-party KYC and document verification services that help us confirm your identity and meet our legal obligations as a gaming platform operating in the Philippines.
• Fraud prevention and security services: Specialised providers that analyse transaction patterns and access behaviour to detect and prevent fraudulent activity on 111ji accounts.
• IT and hosting providers: Providers of server infrastructure, cloud storage, and platform software that process data on our behalf under strict confidentiality and data processing agreements.
• Regulatory and law enforcement authorities: Government bodies, tax authorities, and law enforcement agencies where we are legally required to disclose your information — for example, under anti-money laundering regulations or a valid court order.
• Professional advisers: Legal, accounting, and audit firms that need access to account data in the course of providing professional services to 111ji, subject to confidentiality obligations.

International Data Transfers

Some of the third-party service providers used by 111ji may be located or operate servers outside the Philippines. Where your personal data is transferred internationally, 111ji takes steps to ensure that appropriate safeguards are in place — including contractual clauses that require the recipient to protect your data to a standard consistent with Philippine data protection requirements.

By registering and using your 111ji account, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines. We only permit such transfers where a valid legal basis and adequate protection exists.

Data Retention

111ji retains your personal data for as long as your account remains active and for a period thereafter as required by law or legitimate business need. The general retention periods that apply to the main categories of data we hold are:

• Account and identity data: Retained for the duration of your account and for a minimum of five years after account closure, in line with anti-money laundering record-keeping requirements.
• Financial transaction records: Retained for a minimum of five years following each transaction, as required by applicable financial regulations in the Philippines.
• Gaming activity records: Retained for a minimum of three years for dispute resolution and responsible gaming monitoring purposes.
• Communications and support records: Retained for two years from the date of each interaction, or longer if the communication relates to an unresolved complaint or legal matter.
• Technical and device data: Retained for up to twelve months for security monitoring and fraud prevention purposes.

After the applicable retention period has expired, your personal data will be securely deleted or anonymised so that it can no longer be linked to you as an individual.

Cookies and Tracking Technologies

9.1 What Are Cookies?

Cookies are small text files placed on your device when you visit a website. They allow the site to remember information about your visit — such as your login session, preferences, and how you navigated the page. 111ji uses cookies and similar technologies to operate the platform, secure your session, and understand how players use the site.

9.2 Types of Cookies 111ji Uses

• Strictly necessary cookies: Required for the platform to function — including maintaining your login session, remembering your language preference, and protecting your account from session hijacking. These cannot be disabled without breaking the platform.
• Functional cookies: Remember your preferences and settings to provide a more personalised experience — for example, which game lobby section you last visited on 111ji.
• Analytics cookies: Collect aggregate, anonymised data about how players navigate and use the 111ji platform. This information helps us identify areas for improvement. We use reputable analytics tools under data processing agreements that restrict how your data is used.
• Security cookies: Used to detect and prevent fraudulent logins, bot activity, and suspicious access patterns on your 111ji account.

9.3 Managing Your Cookie Preferences

You can adjust your browser settings to block or delete cookies at any time. Note that disabling strictly necessary cookies will prevent the 111ji platform from functioning correctly. For other cookie categories, adjusting your browser preferences or using the cookie consent tool on the platform allows you to manage your preferences without affecting core platform access.

Your Data Protection Rights

Under the Data Privacy Act of 2012 and related regulations, you have a set of rights regarding the personal data that 111ji holds about you. Here is what each right means in practice:

To exercise any of these rights, email support@111ji.app with the subject "Data Rights Request" and describe what you are requesting. We will acknowledge your request promptly and respond within the period required by applicable law. We may ask you to verify your identity before we process your request to prevent unauthorised access to another person's data.

Children's Privacy

111ji is strictly an adults-only platform for players aged 21 and above. We do not knowingly collect personal data from anyone under 21 years of age. If we discover that an account has been created by someone under the minimum age, we will close that account immediately and delete any associated personal data, subject to our legal obligations to retain records of the incident.

If you believe that a minor has registered or attempted to register an account on 111ji, please notify us immediately at support@111ji.app so we can investigate and take appropriate action.

Security Measures

Protecting your personal and financial data is a core responsibility at 111ji. We implement the following technical and organisational security measures:

• Encryption in transit: All data transmitted between your device and the 111ji platform is encrypted using TLS (Transport Layer Security) to prevent interception.
• Encryption at rest: Sensitive account and financial data stored on 111ji servers is encrypted at rest to protect against unauthorised access in the event of a security breach.
• Access controls: Access to player data within 111ji is restricted on a need-to-know basis. Staff who do not require access to your personal information as part of their role cannot access it.
• Fraud detection systems: Automated monitoring systems flag unusual account activity — such as logins from new devices or unusual transaction patterns — for review by our security team.
• Regular security assessments: 111ji conducts regular technical security assessments to identify and address vulnerabilities in the platform.

Despite these measures, no online platform can guarantee absolute security. If you suspect that your 111ji account has been compromised, contact support immediately so we can take protective action.

Changes to This Privacy Policy

111ji may update this Privacy Policy from time to time to reflect changes in our data practices, platform features, or applicable law. When we make material changes, we will notify registered players by email using the address on their account, and we will update the "last updated" date at the top of this page.

We encourage you to review this Privacy Policy periodically so you remain informed about how 111ji handles your personal data. Continued use of the platform after a revised Privacy Policy takes effect constitutes your acceptance of the updated policy.

Contact Us and How to Make a Complaint

If you have any questions about this Privacy Policy, about how 111ji processes your personal data, or if you wish to exercise any of your data rights, please get in touch:

• Email: support@111ji.app — use the subject "Privacy Inquiry" or "Data Rights Request" so your message is routed correctly.
• Platform support: Use the Help or Support section within your 111ji account for the quickest initial response to general account questions.
• FAQ: The 111ji FAQ covers common questions about accounts, payments, and data that may answer your query without needing to contact support directly.

If you are not satisfied with how 111ji has handled a privacy complaint after raising it with us directly, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines, which is the relevant supervisory authority for data protection matters in the Philippines.