This Privacy Policy applies to all users of the 111ph platform accessible at 111ph.click, including the website, any mobile-optimised interface, and all related services operated by 111ph ("we," "us," "our"). When you create an account, deposit funds, place bets, or otherwise interact with 111ph, you are sharing personal information with us. We take that responsibility seriously.
This policy has been written to comply with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines (DPA), and its implementing rules and regulations issued by the National Privacy Commission (NPC). As a player at 111ph, you have specific rights under the DPA that are outlined in this document.
Quick Note: This Privacy Policy forms part of the 111ph Terms and Conditions. By registering an account at 111ph, you confirm that you have read and understood both documents.
111ph handles every Filipino player's data with care, transparency, and full compliance with Philippine privacy law.
1. Overview – 111ph and Your Privacy
At 111ph, we believe that transparency about data practices is not just a legal requirement – it's a basic form of respect for the people who trust us with their information. Filipino players who register at 111ph share personal details with us in order to use the platform, and we want every one of those players to know exactly what happens with that information from the moment they sign up.
We are the data controller for personal data processed in connection with the 111ph platform. This means we are responsible for deciding how and why your data is used. We do not sell your personal data to advertisers, data brokers, or unaffiliated commercial third parties. Your data is used to run your 111ph account, process your transactions, keep the platform secure, and comply with applicable legal and regulatory obligations.
If you have any questions about this Privacy Policy or how 111ph handles your personal data, you can reach our Data Protection Officer (DPO) at any time using the contact details in Section 14 of this document.
2. What Personal Data We Collect
The categories of personal data that 111ph collects from players are set out in the table below. We collect only the data we genuinely need to operate the platform and meet our legal obligations – nothing more.
| Data Category | Examples | Why We Collect It |
|---|---|---|
| Identity Data | Full name, date of birth, gender, government-issued ID details | Account registration, age verification, KYC compliance |
| Contact Data | Email address, mobile number, residential address | Account communications, verification, support |
| Financial Data | GCash/Maya account reference, bank account details, transaction history | Processing deposits and withdrawals, anti-fraud checks |
| Technical Data | IP address, device type, browser type, operating system, session duration | Security monitoring, fraud detection, platform optimisation |
| Usage Data | Pages visited, games played, bets placed, time spent on platform | Improving 111ph's features, personalisation, responsible gaming monitoring |
| Communications Data | Support chat logs, email correspondence, feedback submissions | Resolving disputes, improving support quality, record-keeping |
| Marketing Preferences | Communication opt-in/opt-out status, preferred notification channels | Sending promotional communications only where consent is given |
111ph does not collect sensitive personal information such as racial or ethnic origin, religious beliefs, health data, or political opinions unless specifically required by law and with your explicit consent.
3. How We Collect Your Data
111ph collects personal data through the following means:
Directly From You
The primary source of your personal data is you. When you register your 111ph account, you provide your name, contact details, and date of birth. When you make a deposit or withdrawal, you provide payment account details. When you contact support, you provide the information in your message. When you complete identity verification, you provide document images and related details.
Automatically Through Your Use of 111ph
When you visit and use the 111ph platform, we automatically collect certain technical data about your device and session. This includes your IP address, the type of browser and device you are using, the pages you access, and the duration of your session. This data is collected using standard web technologies including server logs and cookies.
From Third Parties
In some cases, 111ph receives data about you from third parties. For example, payment processors confirm the result of transactions and may share associated reference data. Identity verification service providers confirm whether your submitted documents match their records. If you were referred to 111ph by another player, we receive the referral reference from that player's account. In all cases, third-party data sharing is limited to what is necessary for the purpose.
4. How We Use Your Personal Data
111ph uses the personal data we collect for the following purposes:
- Account management: Creating, maintaining, and closing your 111ph player account, including processing your login credentials and profile updates
- Transaction processing: Handling deposits and withdrawals via GCash, Maya, bank transfer, and other supported payment methods
- Identity verification: Confirming that you meet the minimum age requirement (21 years) and that your account details are genuine
- Regulatory compliance: Meeting 111ph's obligations under applicable Philippine gaming, anti-money laundering, and data privacy laws
- Fraud prevention and security: Detecting and preventing unauthorised access, fraudulent transactions, and platform abuse
- Customer support: Responding to your queries, resolving disputes, and providing assistance with account or technical issues
- Responsible gaming: Monitoring usage patterns to identify potential signs of problem gambling and to enforce self-exclusion and deposit limit requests
- Platform improvement: Analysing aggregate usage data to improve the 111ph interface, game selection, and overall player experience
- Marketing communications: Sending promotional offers, bonus notifications, and platform updates – but only where you have opted in to receive these
111ph does not use your personal data for automated decision-making that has a significant legal or similarly significant effect on you without providing a means for human review. If you have concerns about any decision made in relation to your account, contact our support team.
111ph protects every Filipino player's data with industry-standard security measures and strict access controls.
5. Legal Basis for Processing
Under the Data Privacy Act of 2012 (Republic Act No. 10173), 111ph must have a lawful basis for each category of personal data processing. The legal bases we rely on are as follows:
| Processing Purpose | Legal Basis |
|---|---|
| Account creation and management | Performance of a contract (your registration agreement with 111ph) |
| Processing deposits and withdrawals | Performance of a contract |
| Identity and age verification | Legal obligation and performance of a contract |
| Anti-money laundering checks | Legal obligation under Philippine AML regulations |
| Fraud detection and security | Legitimate interests of 111ph and its players |
| Responsible gaming monitoring | Legitimate interests and regulatory obligation |
| Marketing communications | Your consent (opt-in required; you may opt out at any time) |
| Platform analytics and improvement | Legitimate interests of 111ph |
6. Sharing Your Personal Data
111ph does not sell your personal data to any third party. We share your data only with the categories of recipients described below, and only to the extent necessary for each stated purpose.
Payment Service Providers
When you make a deposit or request a withdrawal at 111ph, your payment details are shared with the relevant payment processor – such as GCash, Maya, BDO, BPI, or UnionBank – in order to complete the transaction. These providers process your data under their own privacy policies and applicable financial regulations.
Identity Verification Partners
111ph uses third-party identity verification services to confirm the authenticity of documents submitted during the KYC (Know Your Customer) process. These partners receive the document images and associated data you submit and return a verification result to 111ph.
Regulatory and Law Enforcement Bodies
111ph may be required by Philippine law or by court order to disclose your personal data to regulatory authorities, law enforcement agencies, or other government bodies. We will only make such disclosures when legally obligated to do so and will inform you unless doing so is legally prohibited.
Technology and Infrastructure Providers
Certain aspects of 111ph's infrastructure are operated by third-party technology providers, including cloud hosting services and security monitoring tools. These providers access personal data only as necessary to perform their contracted services and are bound by data processing agreements that restrict how they handle your information.
What we never do: 111ph never sells, rents, or trades your personal data with advertising networks, data brokers, or unaffiliated commercial entities for their own marketing purposes.
7. Cookies and Tracking Technologies
111ph uses cookies and similar tracking technologies on the platform. A cookie is a small text file placed on your device by a website you visit. Cookies are widely used to make websites work effectively and to provide useful information to website operators.
Types of Cookies We Use
- Strictly Necessary Cookies: Required for the 111ph platform to function correctly. These enable core features such as secure login, session management, and bet placement. These cookies cannot be disabled.
- Performance Cookies: Collect anonymised data about how players use 111ph – such as which pages are visited most and where errors occur – to help us improve the platform. No personally identifiable information is collected via these cookies.
- Functional Cookies: Remember your preferences and settings on 111ph, such as your preferred language or notification settings, to provide a more personalised experience.
- Security Cookies: Used to authenticate users, prevent fraud, and protect the 111ph platform and its players from unauthorised access and malicious activity.
You can control cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the 111ph platform. Strictly necessary cookies cannot be disabled as the platform cannot function without them.
8. How Long We Keep Your Data
111ph retains your personal data only for as long as necessary to fulfil the purposes for which it was collected, unless a longer retention period is required by law. The key retention periods are as follows:
- Active account data: Retained for the duration of your account and for a minimum of five (5) years after account closure, as required under Philippine anti-money laundering regulations.
- Transaction records: Retained for a minimum of five (5) years following the transaction date in compliance with applicable financial record-keeping laws.
- Identity verification documents: Retained for five (5) years after account closure or the completion of the verification process, whichever is later.
- Support communications: Retained for two (2) years from the date of the last interaction for quality assurance and dispute resolution purposes.
- Marketing preference records: Retained for as long as your account is active, or until you withdraw your marketing consent, whichever comes first.
When data is no longer required and its retention period has expired, 111ph securely deletes or anonymises it so that it can no longer be associated with you.
111ph gives every Filipino player clear rights over their personal data under the Data Privacy Act of 2012.
9. How We Protect Your Data
111ph takes the security of your personal data seriously. We implement technical and organisational measures appropriate to the risk involved in processing your data. These measures are regularly reviewed and updated as technology and threat landscapes evolve.
Our security measures include, but are not limited to:
- Encryption of data in transit using TLS (Transport Layer Security) protocols
- Encryption of sensitive data at rest, including payment details and identity documents
- Access controls that restrict employee access to personal data on a strict need-to-know basis
- Regular security assessments, penetration testing, and vulnerability scanning
- 24/7 automated monitoring for unusual account activity and potential breaches
- Secure password hashing for all account credentials
- Incident response procedures in place to address and contain any data breach promptly
In the unlikely event of a personal data breach that is likely to result in a risk to your rights and freedoms, 111ph will notify you and the National Privacy Commission as required under the Data Privacy Act of 2012 within the prescribed timeframes.
10. Your Data Rights Under Philippine Law
As a data subject under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 111ph. To exercise any of these rights, contact our Data Protection Officer using the details in Section 14.
Right to Be Informed
You have the right to know how 111ph collects, uses, stores, and shares your personal data. This Privacy Policy fulfils that obligation – it is always available on the 111ph website.
Right of Access
You can request a copy of the personal data 111ph holds about you at any time. We will provide this within 30 calendar days of receiving your verified request.
Right to Rectification
If your personal data held by 111ph is inaccurate or incomplete, you have the right to have it corrected. Contact support or update your details in your account settings.
Right to Erasure
You can request deletion of your personal data in certain circumstances – for example, where it is no longer necessary for the purpose it was collected and no legal retention obligation applies.
Right to Object
You can object to 111ph processing your data for direct marketing at any time by updating your communication preferences in your account or contacting support.
Right to Complain
If you believe 111ph has handled your data unlawfully, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.
11. Minors and Age Restrictions
111ph does not knowingly collect personal data from individuals under the age of 21. Our platform is strictly for adults who meet the minimum legal age requirement for online gaming in the Philippines. Age verification is conducted as part of the registration process, and accounts found to belong to underage individuals are immediately suspended.
If you are a parent or guardian and believe that your child has registered an account or shared personal data with 111ph, please contact us immediately at support@111ph.click. We will investigate the matter promptly and, if confirmed, delete all data associated with the underage individual's account.
12. International Data Transfers
111ph's primary operations and data storage are based in the Philippines. In certain circumstances, personal data may be processed by our third-party service providers whose systems are located in other countries. Where such international transfers occur, 111ph ensures that appropriate 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 clauses that require third-party processors outside the Philippines to handle your data to a standard equivalent to that required under Philippine law. 111ph only transfers personal data internationally where there is a legitimate operational reason to do so and where the receiving party has demonstrated adequate data protection standards.
13. Changes to This Privacy Policy
111ph may update this Privacy Policy from time to time to reflect changes in our data practices, operational requirements, or the legal and regulatory environment. When we make material changes, we will notify registered players by email and/or through an in-platform notification before the updated policy takes effect.
The effective date at the top of this page shows when the current version was last updated. We recommend reviewing this Privacy Policy periodically so you remain informed about how 111ph protects your personal data. Your continued use of the 111ph platform after the effective date of an updated Privacy Policy constitutes your acknowledgment of the changes.
If you object to any changes made to this Privacy Policy, you should stop using the 111ph platform and contact us to request account closure. Any data collected prior to the update will continue to be handled in accordance with the policy that was in effect at the time of collection.
14. Contact Our Data Protection Officer
If you have any questions about this Privacy Policy, want to exercise your data rights, or have concerns about how 111ph is handling your personal data, please contact our Data Protection Officer directly. We aim to respond to all privacy-related enquiries within five (5) business days.
Related Documents: This Privacy Policy should be read alongside the Terms and Conditions and Responsible Gaming Policy, both of which form part of your agreement with 111ph.