ph111 Privacy Policy

ph111 ("ph111," "we," "us," or "our") operates the online gaming platform accessible at https://ph111.app (the "Platform"). We are committed to protecting the privacy and personal data of every individual who accesses or uses the ph111 Platform, including registered players, visitors, and prospective members (collectively, "you" or "User").

This Privacy Policy ("Policy") describes how ph111 collects, uses, stores, discloses, and protects your personal data in connection with your use of the Platform. It has been prepared in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

This Policy should be read together with ph111's Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference. In the event of any conflict between this Policy and the Terms & Conditions with respect to privacy matters, this Policy shall prevail.

ph111 collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include:

ph111 does not intentionally collect sensitive personal information (as defined under the Data Privacy Act) beyond what is strictly required for identity verification and regulatory compliance. Where sensitive personal information is collected, it is handled with the highest level of security and care.

ph111 collects your personal data through the following means:

• Direct Interactions: Data you provide when you register for a ph111 account, complete KYC verification, make deposits or withdrawals, contact our support team, or respond to surveys and promotions.
• Automated Technologies: Data collected automatically when you access the ph111 Platform, including through cookies, web beacons, server logs, and similar tracking technologies. This includes your IP address, device identifiers, and browsing behaviour on the Platform.
• Third-Party Sources: Data received from payment processors (such as GCash, PayMaya, and partner banks) to verify transactions; identity verification service providers for KYC purposes; and fraud prevention and anti-money laundering screening services.
• Regulatory Sources: Data received from PAGCOR, the Anti-Money Laundering Council (AMLC), or other Philippine regulatory authorities in connection with our compliance obligations.

ph111 uses your personal data for the following purposes:

• Account Management: To create, maintain, and manage your ph111 account, including verifying your identity and age (21+ requirement) and processing your registration.
• Platform Operation: To provide you with access to ph111's games, features, and services, including processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, Metrobank, and other supported payment methods.
• Regulatory Compliance: To comply with our obligations under Philippine law, including the Data Privacy Act, the Anti-Money Laundering Act (AMLA), PAGCOR licensing requirements, and any other applicable regulations. This includes conducting Know Your Customer (KYC) checks and filing mandatory reports with the AMLC where required.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent transactions, money laundering, account takeovers, and other illegal or prohibited activities on the ph111 Platform.
• Responsible Gaming: To monitor gaming behaviour and identify players who may be at risk of problem gambling, and to administer responsible gaming tools such as deposit limits, loss limits, and self-exclusion.
• Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Communications: To send you transactional notifications (e.g., deposit confirmations, withdrawal updates, security alerts) and, where you have opted in, promotional communications about ph111 offers and new games.
• Platform Improvement: To analyse usage patterns, conduct research, and improve the functionality, performance, and user experience of the ph111 Platform.
• Legal Proceedings: To establish, exercise, or defend legal claims involving ph111 or its players.

ph111 will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or establishing another lawful basis for processing.

Under the Philippine Data Privacy Act of 2012, ph111 processes your personal data on the following legal bases:

• Contractual Necessity: Processing is necessary to perform our contract with you — specifically, to operate your ph111 account and provide the gaming services you have requested.
• Legal Obligation: Processing is required to comply with ph111's obligations under Philippine law, including AMLA, PAGCOR regulations, and NPC requirements.
• Legitimate Interests: Processing is necessary for ph111's legitimate interests, including fraud prevention, platform security, and improving our services, provided these interests are not overridden by your rights and freedoms.
• Consent: Where ph111 relies on your consent as the legal basis for processing (e.g., for marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

ph111 does not sell, rent, or trade your personal data to third parties for commercial purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, UnionBank, and other payment service providers, solely to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC and identity verification service providers engaged by ph111 to verify your identity and age in compliance with PAGCOR and AMLA requirements.
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government agencies, where disclosure is required by law or regulatory mandate.
• Law Enforcement: Philippine law enforcement agencies, where disclosure is required by a valid court order, subpoena, or other lawful process.
• Technology Service Providers: Cloud hosting providers, cybersecurity firms, and platform analytics providers engaged by ph111 under strict data processing agreements that prohibit them from using your data for any purpose other than providing services to ph111.
• Professional Advisers: Lawyers, auditors, and accountants engaged by ph111, subject to professional confidentiality obligations.

ph111 uses cookies and similar technologies to enhance your experience on the Platform. A cookie is a small text file placed on your device when you visit a website. ph111 uses the following types of cookies:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in to your ph111 account and security cookies that help detect fraudulent activity. These cannot be disabled.
• Functional Cookies: Used to remember your preferences, such as your preferred language and display settings, to provide a more personalised experience on ph111.
• Analytics Cookies: Used to collect anonymised data about how users interact with the ph111 Platform, helping us identify areas for improvement. This data does not identify you personally.

ph111 does not use third-party advertising or tracking cookies. You can manage or delete cookies through your browser settings at any time. Please note that disabling strictly necessary cookies may affect the functionality of the ph111 Platform, including your ability to log in to your account.

ph111 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and the ph111 Platform is encrypted using 256-bit SSL/TLS technology. Sensitive data stored in ph111's systems is encrypted at rest using industry-standard encryption algorithms.
• Access Controls: Access to personal data within ph111's systems is restricted to authorised personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations and regular data privacy training.
• Firewalls and Intrusion Detection: ph111's infrastructure is protected by enterprise-grade firewalls and real-time intrusion detection and prevention systems.
• Regular Security Audits: ph111 conducts regular security assessments, penetration testing, and vulnerability scans to identify and remediate potential security weaknesses.
• Incident Response: ph111 maintains a documented data breach response plan. In the event of a personal data breach that poses a real risk to your rights and freedoms, ph111 will notify the NPC and affected individuals within the timeframes required by Philippine law.

ph111 retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following retention periods apply:

• Account Data: Retained for the duration of your active ph111 account, plus a minimum of five (5) years following account closure, in accordance with AMLA record-keeping requirements.
• Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act.
• KYC Documents: Retained for a minimum of five (5) years following the end of the business relationship, as required by PAGCOR and AMLA regulations.
• Gaming History: Retained for a minimum of three (3) years for dispute resolution and responsible gaming monitoring purposes.
• Support Communications: Retained for a minimum of two (2) years for quality assurance and dispute resolution purposes.
• Marketing Preferences: Retained until you withdraw your consent or request deletion, subject to any overriding legal retention obligations.

Upon expiry of the applicable retention period, ph111 will securely delete or anonymise your personal data in a manner that prevents reconstruction or identification.

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph111:

To exercise any of these rights, please contact ph111's Data Protection Officer (DPO) by emailing [email protected]. ph111 will respond to all verified data subject requests within 15 business days of receipt, in accordance with NPC guidelines. We may request proof of identity before processing your request to protect against unauthorised access to your data.

If you are not satisfied with ph111's response to your privacy request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

The ph111 Platform is strictly intended for individuals who are 21 years of age or older, in accordance with Philippine gaming regulations. ph111 does not knowingly collect personal data from individuals under the age of 21.

If ph111 becomes aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete that data and close the associated account. Any winnings accrued by an underage player will be forfeited, and deposits will be returned subject to verification of the deposit source.

If you are a parent or guardian and believe that your child under the age of 21 has provided personal data to ph111, please contact our support team immediately at [email protected] so that we can take appropriate action.

The ph111 Platform may contain references to third-party services, such as payment providers (GCash, PayMaya, BPI, BDO, Metrobank). When you interact with these third-party services, you are subject to their own privacy policies and terms of use, which are separate from and independent of this Policy.

ph111 is not responsible for the privacy practices or content of any third-party services. We encourage you to review the privacy policies of any third-party services you use in connection with your ph111 account before providing them with your personal data.

ph111 reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, or NPC guidelines. When we make material changes to this Policy, we will:

• Update the "Last Updated" date at the top of this page.
• Notify registered ph111 players via email to the address associated with their account.
• Display a prominent notice on the ph111 Platform for a reasonable period following the update.

Your continued use of the ph111 Platform after the effective date of any revised Privacy Policy constitutes your acceptance of the updated Policy. If you do not agree with the changes, you must cease using the Platform and may request account closure in accordance with ph111's Terms & Conditions.

The most current version of this Privacy Policy will always be available at https://ph111.app/privacy-policy.

ph111 has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Privacy Policy and the Philippine Data Privacy Act. If you have any questions, concerns, or requests relating to your personal data or this Policy, please contact our DPO:

For general enquiries about your ph111 account, our 24/7 customer support team is available via live chat on the Platform. For privacy-specific matters, please direct your correspondence to the DPO email address above to ensure your request is handled by the appropriate team.

If you wish to escalate a privacy concern that has not been resolved to your satisfaction by ph111, you may file a complaint with the National Privacy Commission (NPC) of the Philippines through their official channels.