Privacy Policy
for 1111jl

This Privacy Policy ("Policy") is issued by 1111jl ("1111jl," "we," "us," or "our") and applies to all personal data collected, processed, stored, or otherwise handled in connection with your use of the 1111jl online casino platform, accessible at https://1111jl.app, including all games, features, promotions, customer support channels, and any associated mobile-optimized interfaces (collectively, the "Platform").

This Policy is drafted in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC). Where applicable, we also observe relevant international data protection standards to the extent they align with our obligations under Philippine law.

By registering an account on 1111jl, accessing the Platform, or otherwise providing us with your personal data, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you should discontinue use of the Platform and contact our support team to request account closure.

1111jl collects only the personal data that is necessary for the purposes described in this Policy. The categories of personal data we collect include the following:

Registration & Identity Data

When you create a 1111jl account, we collect information such as your full legal name, date of birth, nationality, gender, residential address, email address, and mobile number. This information is required to establish your identity, verify your eligibility to use the Platform, and comply with our Know Your Customer (KYC) obligations.

Identity Verification Documents

As part of our KYC process, we may collect copies of government-issued identification documents such as your Philippine passport, SSS ID, UMID, PhilHealth ID, or driver's license. We may also collect proof of address documents such as utility bills, bank statements, or barangay certificates. These documents are used solely for identity verification and regulatory compliance purposes.

Financial Data

We collect information related to your financial transactions on the Platform, including deposit and withdrawal amounts, payment method details (such as GCash account references, PayMaya account references, BPI, BDO, or Metrobank account details), transaction histories, and account balances. We do not store full payment card numbers or full bank account numbers on our servers.

Gaming Activity Data

We collect records of your gaming activity on the Platform, including games played, wagers placed, game outcomes, session durations, bonus usage, and responsible gaming tool settings. This data is used for account management, dispute resolution, fraud prevention, and regulatory reporting.

Technical & Device Data

We automatically collect certain technical data when you access the Platform, including your IP address, device type, operating system, browser type and version, screen resolution, time zone, and referring URL. This data helps us maintain Platform security, detect fraudulent activity, and optimize the user experience.

Communications Data

When you contact our support team via live chat, email, or any other channel, we retain records of those communications, including the content of messages, timestamps, and any attachments. This data is used to resolve your queries, improve our support services, and maintain records of our interactions with you.

1111jl collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, participate in promotions, or update your account settings.
• Automatically — through cookies, web beacons, server logs, and similar tracking technologies when you access or interact with the Platform. See Section 7 for more detail on our use of cookies.
• From third-party payment providers — such as GCash, PayMaya, BPI, BDO, and Metrobank, in connection with processing your financial transactions on the Platform.
• From identity verification service providers — who assist us in verifying the authenticity of documents submitted during the KYC process.
• From fraud prevention and security partners — who provide us with signals and data to help detect and prevent fraudulent activity on the Platform.

We do not purchase personal data from data brokers or third-party marketing lists. All personal data we hold about you has been collected through one of the channels described above.

1111jl uses the personal data we collect for the following purposes:

We do not use your personal data for automated decision-making that produces legal or similarly significant effects without human review. Where profiling is used — for example, to identify responsible gaming risk indicators — it is used to support human decision-making, not replace it.

Under the Data Privacy Act of 2012, 1111jl processes your personal data on the following legal bases:

• Contractual necessity — processing is necessary to perform our contract with you, including providing access to the Platform, processing transactions, and managing your account.
• Legal obligation — processing is required to comply with applicable Philippine laws, including the Anti-Money Laundering Act (AMLA), PAGCOR regulatory requirements, and the Data Privacy Act itself.
• Legitimate interests — processing is necessary for our legitimate interests in operating a secure, fair, and commercially viable platform, including fraud prevention, security monitoring, and service improvement, provided those interests are not overridden by your rights and interests.
• Consent — where we rely on your consent as the legal basis for processing (for example, for certain marketing communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

1111jl does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We share your personal data only in the following circumstances and only to the extent necessary for the stated purpose:

Service Providers

We share personal data with trusted third-party service providers who assist us in operating the Platform, including payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, game software providers, cloud hosting providers, and customer support platform providers. All service providers are contractually bound to process your data only on our instructions and in accordance with applicable data protection law.

Regulatory & Law Enforcement Authorities

We may disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or other competent Philippine government authorities where required by law, court order, or regulatory directive. We may also disclose data to law enforcement agencies where necessary to prevent, detect, or investigate fraud, money laundering, or other criminal activity.

Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 1111jl's business, your personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and the privacy practices of the acquiring entity prior to your data being transferred.

1111jl uses cookies and similar tracking technologies to operate and improve the Platform. A cookie is a small text file placed on your device when you visit a website. We use the following categories of cookies:

• Strictly necessary cookies — essential for the Platform to function. These include session authentication cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies — remember your preferences such as language settings, game display preferences, and responsible gaming tool configurations.
• Analytics cookies — help us understand how players use the Platform, which pages are most visited, and where technical issues occur. This data is aggregated and anonymized where possible.
• Security cookies — used to detect and prevent fraudulent activity, bot traffic, and unauthorized access attempts.

You can manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from accessing the Platform. For analytics and functional cookies, you may opt out without affecting your ability to use core Platform features.

1111jl retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following retention periods apply:

• Account and identity data — retained for the duration of your account and for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
• Financial transaction records — retained for a minimum of five (5) years from the date of the transaction, as required by Philippine anti-money laundering regulations.
• Gaming activity records — retained for a minimum of three (3) years from the date of the activity, for dispute resolution and regulatory audit purposes.
• KYC documents — retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Support communications — retained for two (2) years from the date of the last communication, unless a longer period is required for ongoing dispute resolution.
• Technical and device data — retained for up to twelve (12) months from collection, unless required for longer periods for security or fraud investigation purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures. Where anonymization is not technically feasible, data is securely destroyed.

1111jl implements appropriate technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. Our security measures include:

• Encryption of data in transit using TLS (Transport Layer Security) protocols.
• Encryption of sensitive data at rest using industry-standard encryption algorithms.
• Access controls limiting data access to authorized personnel on a need-to-know basis.
• Regular security assessments, vulnerability scanning, and penetration testing of Platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems holding personal data.
• Staff training on data protection obligations and security best practices.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 1111jl will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected individuals without undue delay, in accordance with RA 10173 and NPC Circular 16-03.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 1111jl. You may exercise any of these rights by contacting our Data Protection Officer (DPO) using the contact details in Section 14.

We will respond to all data subject rights requests within thirty (30) days of receipt. Where a request is complex or we receive a high volume of requests, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reasons for it.

If you are not satisfied with our response to a data subject rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

The 1111jl Platform is strictly intended for individuals who are 21 years of age or older. We do not knowingly collect personal data from individuals under the age of 21. The minimum legal age for participation in real-money casino gaming in the Philippines is 21 years, and 1111jl enforces this requirement rigorously through our registration and KYC processes.

If we become aware that we have inadvertently collected personal data from an individual under the age of 21, we will take immediate steps to delete that data and close the associated account. Any winnings accrued on an account found to belong to an underage individual will be forfeited.

Some of the third-party service providers used by 1111jl — including cloud hosting providers, game software providers, and identity verification services — may process personal data outside of the Philippines. Where such cross-border transfers occur, 1111jl ensures that appropriate safeguards are in place to protect your personal data, in accordance with Section 21 of RA 10173 and the NPC's guidelines on cross-border data transfers.

Safeguards for cross-border transfers may include contractual clauses requiring the recipient to apply data protection standards equivalent to those required under Philippine law, or transfers to jurisdictions that the NPC has recognized as providing an adequate level of data protection.

You may request information about the specific safeguards applicable to any cross-border transfer of your personal data by contacting our Data Protection Officer using the details in Section 14.

1111jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory guidance. When material changes are made, we will notify registered players via email and/or through a prominent notice on the Platform prior to the changes taking effect.

The effective date of the current version of this Policy is stated at the top of this document. We encourage you to review this Policy periodically to stay informed about how we protect your personal data. Your continued use of the Platform following the effective date of any updated Policy constitutes your acknowledgment of the changes.

Previous versions of this Policy are available upon request by contacting our Data Protection Officer.

1111jl has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and with the 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, please contact our DPO using the details below.

Please note that our contact email address is provided as plain text only and is not a clickable link. Copy and paste it into your email client to get in touch.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing the Data Privacy Act of 2012.