Privacy Policy

111ph ("111ph", "we", "us", "our") operates the online gaming platform accessible at https://111ph.cam (the "Platform"). In the course of providing our services — which include online casino games, sports betting, bingo, slot games, live dealer tables, and associated account management and payment functions — 111ph necessarily collects and processes personal data belonging to users, prospective users, and visitors to the Site.

This Privacy Policy governs all personal data processing activities carried out by 111ph in connection with the Platform, whether data is collected online, through mobile browsing, or via any other channel used to access 111ph services. It applies to all registered players, users who browse the Platform without registering, and any individual who contacts 111ph's customer support team.

Where 111ph engages third-party service providers to process data on its behalf, such processing is governed by data processing agreements that require those providers to meet standards consistent with those set out in this Policy and in the Philippine Data Privacy Act of 2012.

For the purposes of the Data Privacy Act of 2012 and this Privacy Policy, the data controller responsible for personal data processed through 111ph.cam is:

If you have questions or concerns about how 111ph processes your personal data, or if you wish to exercise any of your rights as a data subject, please contact us using the details above. We will endeavor to respond to all data-related inquiries within fifteen (15) business days of receipt.

111ph collects the following categories of personal data from users, depending on the nature of your interaction with the Platform:

111ph does not intentionally collect sensitive personal information beyond what is strictly required for identity verification and regulatory compliance. Where sensitive information is collected (such as government ID numbers), it is handled with additional safeguards consistent with the requirements of the Data Privacy Act of 2012.

111ph collects personal data through the following means:

• Direct Provision: Data you actively provide when registering an account, completing KYC verification, making deposits or withdrawal requests, contacting customer support, or participating in promotions;
• Automated Technologies: Data collected automatically when you access or use the Platform, including via cookies, web beacons, pixel tags, session replay tools, and server logs (see Section 8 for full cookie information);
• Third-Party Sources: Data received from payment processors (including GCash, PayMaya, BDO, BPI, and other banking partners) in connection with transaction processing; data from identity verification service providers used to support KYC compliance; data from fraud detection and AML screening services;
• Publicly Available Sources: In limited circumstances relevant to AML or fraud investigations, data obtained from publicly accessible government registries or databases.

111ph processes personal data only for specified, legitimate purposes and on the basis of one or more recognized legal grounds under the Data Privacy Act of 2012. The primary legal bases we rely upon are:

• Contract Performance: Processing necessary for the performance of the player account agreement and delivery of gaming services, including account management, processing wagers, handling deposits and withdrawals, and operating the bonus system;
• Legal Obligation: Processing required to comply with applicable Philippine law, including AML obligations, KYC requirements, tax reporting, and obligations arising from regulatory directions or court orders;
• Legitimate Interests: Processing for purposes of fraud prevention, platform security, responsible gaming monitoring, product improvement, and customer service optimization, where such interests are not overridden by the data subject's rights and freedoms;
• Consent: Processing for marketing communications and certain cookie categories where your explicit consent is obtained and can be withdrawn at any time.

Where consent is the legal basis for a particular processing activity, you retain the right to withdraw that consent at any time by contacting 111ph support or updating your account preferences. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

111ph uses the personal data it collects for the following purposes:

• Creating and managing your 111ph player account, including authentication and security;
• Processing your deposits and withdrawal requests through your chosen Philippine payment method (GCash, PayMaya, BDO, BPI, etc.);
• Verifying your identity and age (21+) in compliance with applicable regulatory requirements;
• Conducting AML screening, fraud detection, and account security monitoring to protect both 111ph and its players;
• Operating the VIP loyalty programme and calculating rewards, cashback, and tier progression;
• Administering promotional offers and bonus programs, including verifying eligibility and detecting abuse;
• Monitoring gaming activity for responsible gaming indicators and intervening where player welfare may be at risk;
• Providing customer support and resolving account queries, complaints, and disputes;
• Analysing platform usage patterns to improve game selection, features, and overall user experience;
• Sending transactional communications (e.g., deposit confirmations, withdrawal status updates, account security alerts) that are necessary for the operation of your account;
• Sending promotional communications where you have opted in to receive them (you may opt out at any time);
• Complying with applicable Philippine law, including cooperating with regulatory authorities such as PAGCOR and the National Privacy Commission (NPC) where required.

111ph may share your personal data with the following categories of recipients:

• Payment Service Providers: GCash (Mynt), PayMaya (Voyager Innovations), and Philippine banking partners (BDO, BPI, Metrobank, UnionBank) — for the purpose of processing deposit and withdrawal transactions;
• Identity Verification Providers: Third-party KYC and identity verification services used to validate government-issued IDs and conduct liveness checks;
• Fraud Prevention & AML Screening Services: Specialist providers used to screen transactions and player activity against sanctions lists, politically exposed persons (PEP) databases, and fraud pattern libraries;
• Game Software Providers: JILI, Pragmatic Play, PG Soft, Evolution Gaming, and other providers may receive limited technical data (session identifiers, wager data) to operate games and maintain their own audit logs;
• Regulatory Authorities: PAGCOR and the National Privacy Commission, and any other Philippine government body to which disclosure is required by law or court order;
• IT Infrastructure & Cloud Providers: Hosting, storage, and security service providers operating under contractual data processing obligations consistent with this Policy;
• Professional Advisors: Legal, audit, and compliance professionals where disclosure is necessary for the protection of 111ph's legal rights.

All third parties with whom 111ph shares personal data are required to maintain appropriate technical and organizational measures to protect the data shared, and to use it only for the purpose for which it was disclosed.

111ph uses cookies and similar tracking technologies on the Platform to enable core functionality, improve performance, and understand how users interact with the Site. The following types of cookies are used:

You may manage your cookie preferences through your browser settings. Disabling strictly necessary cookies may impair the functionality of the Platform. For analytics and marketing cookies, you may withdraw consent at any time through your account settings or by contacting 111ph support.

111ph retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to applicable legal, regulatory, and operational retention requirements. The following general retention periods apply:

• Active Account Data: Retained for the duration of your active account plus a minimum of five (5) years following account closure, consistent with AML record-keeping obligations under Philippine law;
• KYC Verification Documents: Retained for a minimum of five (5) years from the date of verification or from the date of the last transaction, whichever is later;
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction;
• Support Communications: Retained for three (3) years from the date of the last interaction, unless a longer period is required in connection with an ongoing dispute or investigation;
• Cookie and Analytics Data: Non-personally identifiable aggregated analytics data may be retained for up to two (2) years from collection. Session-level cookie data is deleted at the end of each browser session unless persistent cookies are set;
• Marketing Consent Records: Retained for the period of consent plus three (3) years to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of the original data. Data retained solely for backup or disaster recovery purposes is deleted in alignment with backup rotation schedules.

111ph's security programme includes, but is not limited to, the following measures:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between users' devices and the Platform;
• Encryption of sensitive personal data stored in 111ph's systems, including KYC documents and payment credentials;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Multi-factor authentication requirements for administrative access to systems containing personal data;
• Regular security vulnerability assessments and penetration testing;
• Intrusion detection and monitoring systems operating around the clock;
• Data breach response procedures including notification obligations to the National Privacy Commission (NPC) in accordance with the Data Privacy Act of 2012.

While 111ph takes all reasonable precautions to protect your personal data, no internet-based platform can guarantee absolute security. You are encouraged to use strong, unique passwords for your account, enable two-factor authentication, and report any suspected unauthorized account activity to 111ph support immediately.

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations, you have the following rights with respect to your personal data held by 111ph. To exercise any of these rights, contact 111ph at the details provided in Section 16.

111ph will respond to all data subject rights requests within fifteen (15) business days of receipt. Requests may be subject to identity verification to ensure we are responding to the legitimate account holder. Some rights are subject to limitations where processing is required for legal compliance or fraud prevention.

Where 111ph discovers or is notified that personal data has been collected from an individual under 21 years of age, all associated personal data will be deleted promptly and the relevant account will be closed. If you believe that a minor has provided personal data to 111ph, please contact our support team immediately using the details in Section 16.

Some of 111ph's third-party service providers — including cloud infrastructure providers, game software providers, and fraud detection services — may be located outside of the Philippines or may process data in servers located in other jurisdictions. Where personal data is transferred outside the Philippines, 111ph ensures that appropriate safeguards are in place consistent with the requirements of the Data Privacy Act of 2012, including the execution of data transfer agreements incorporating the National Privacy Commission's standard contractual clauses or equivalent protections.

111ph will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without implementing the safeguards described above, and will provide information on such safeguards upon request.

The 111ph Platform does not contain links to third-party websites for general browsing purposes. Where third-party payment processors (such as GCash or PayMaya) are accessed during deposit or withdrawal flows, such interactions are governed by the privacy policies of those providers. 111ph is not responsible for the data practices of third-party payment providers and recommends that users review the privacy policies of those providers independently.

111ph may update or revise this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or Platform operations. Where material changes are made, 111ph will notify registered users via the email address associated with their account and/or through a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. Your continued use of 111ph following the posting of an updated Privacy Policy constitutes your acknowledgment of the updated Policy. If you do not agree with the updated Policy, you must cease using the Platform and contact 111ph support to arrange account closure.

We encourage you to review this Privacy Policy periodically to stay informed about how 111ph protects your personal data.

For any questions, requests, or concerns relating to this Privacy Policy or the processing of your personal data by 111ph, please contact us through the following channels. All contact details are provided as plain text only — they are not clickable links.

• General Support: [email protected]
• Data Privacy Inquiries: [email protected]
• Live Chat: Available 24/7 through your 111ph account dashboard
• Response Time: Data subject rights requests acknowledged within 3 business days; full response within 15 business days

If you are not satisfied with 111ph's response to your data privacy concern, you have the right to lodge a complaint with the Philippine National Privacy Commission (NPC). The NPC is the authority responsible for enforcing the Data Privacy Act of 2012 in the Philippines. Information on how to contact the NPC and submit a complaint is available through official Philippine government channels.