ph1111 Privacy Policy

1 Introduction

1.1 ph1111 ("the Company," "we," "us," or "our") operates the online casino and sports betting platform accessible at ph1111.vip ("the Platform"). This Privacy Policy describes how ph1111 collects, processes, uses, discloses, stores, and protects personal data obtained from individuals ("you," "your," or "Data Subject") who access or use the Platform.

1.2 ph1111 is committed to protecting the privacy and personal data of all users. We comply with the Data Privacy Act of 2012 (Republic Act No. 10173, or "DPA"), its Implementing Rules and Regulations, and the data protection requirements imposed by the Philippine Amusement and Gaming Corporation (PAGCOR) on licensed online gaming operators.

1.3 This Privacy Policy applies to all data collected through the Platform, including via registration, account usage, financial transactions, customer support interactions, and technical systems such as cookies and analytics tools. It applies to Philippine residents and all other persons whose data is processed by ph1111 in connection with the Platform.

1.4 By accessing the Platform and creating a ph1111 account, you consent to the collection and processing of your personal data as described in this Privacy Policy, to the extent that such consent is required as a legal basis under applicable law.

2 Personal Data We Collect

2.1 Registration Data. When you create a ph1111 account, we collect: full legal name, date of birth, email address, mobile telephone number, and a username and password chosen by you. This data is required to establish your account identity and to verify your eligibility to use the Platform.

2.2 Identity Verification (KYC) Data. Prior to your first withdrawal, ph1111 collects KYC documentation including: a copy of a valid government-issued photo identification document (such as a PhilSys National ID, Philippine passport, UMID, or driver's license) and a contemporaneous selfie photograph. In certain circumstances, we may request proof of residential address such as a utility bill or bank statement issued within the past three months.

2.3 Financial Data. We collect data relating to your financial transactions on the Platform, including deposit amounts, payment method identifiers (such as GCash account references, bank account last digits, or e-wallet handles), withdrawal requests, and transaction histories. We do not collect or store full bank account numbers, card numbers, or e-wallet PINs.

2.4 Gaming Activity Data. We collect records of your activity on the Platform including games played, bet amounts, game outcomes, session durations, bonus usage, and betting patterns. This data is retained for regulatory compliance, dispute resolution, and responsible gaming monitoring purposes.

2.5 Technical & Device Data. We automatically collect certain technical data when you access the Platform, including: IP address, browser type and version, operating system, device identifiers, referring URL, pages visited, time and duration of visits, and error logs.

2.6 Communications Data. When you contact ph1111 customer support — whether by live chat or email — we collect and retain records of those communications, including the content of your messages and any documents or screenshots you provide.

3 How We Collect Personal Data

3.1 ph1111 collects personal data through the following means:

• Directly from you — when you register an account, submit KYC documents, make deposits or withdrawals, contact support, or update your account settings.
• Automatically — through cookies, web beacons, and server logs when you access and navigate the Platform.
• From payment service providers — GCash, Maya, and bank partners may provide transaction confirmation data to ph1111 for reconciliation and fraud prevention purposes.
• From identity verification services — ph1111 may use third-party KYC verification services that cross-reference submitted identity documents against government databases or watchlists.
• From fraud prevention and analytics providers — technical and behavioural data may be analysed by third-party services operating under contractual data processing agreements with ph1111.

4 Legal Basis for Processing

4.1 ph1111 processes your personal data on the following legal bases under the Data Privacy Act of 2012 and its Implementing Rules and Regulations:

• Contractual necessity: Processing your registration data, KYC information, financial data, and gaming activity data is necessary to perform our contractual obligations to you as a ph1111 account holder and to provide the services you have requested.
• Legal obligation: Processing KYC and transaction data is required by PAGCOR licensing conditions, Philippine anti-money laundering laws (Republic Act No. 9160 as amended), and other applicable regulatory obligations.
• Legitimate interests: ph1111 processes technical and device data for fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Where required by law and not covered by the above bases, ph1111 will seek your explicit consent before processing your personal data for specific purposes.

5 How We Use Your Personal Data

5.1 ph1111 uses your personal data for the following purposes:

• Creating and administering your ph1111 account;
• Verifying your identity and age eligibility (21+ as required by PAGCOR);
• Processing deposits, withdrawals, and related financial transactions via GCash, Maya, BPI, BDO, Metrobank, UnionBank, 7-Eleven Cliqq, USDT TRC20, and Coins.ph;
• Providing and operating the gaming services on the Platform;
• Complying with PAGCOR licensing conditions and Philippine anti-money laundering obligations;
• Detecting and preventing fraud, cheating, money laundering, and other prohibited activities;
• Providing customer support and resolving disputes;
• Monitoring and enforcing responsible gaming measures, including deposit limits, session controls, and self-exclusion;
• Sending transactional communications such as deposit confirmations, withdrawal notifications, and security alerts;
• Improving the Platform's features, performance, and user experience;
• Complying with any court order, regulatory direction, or lawful government request.

5.2 ph1111 does not use your personal data to make solely automated decisions that produce significant legal effects on you without human oversight.

6 Data Sharing & Third-Party Disclosure

6.1 ph1111 does not sell, rent, or trade your personal data to any third party for their own commercial purposes. We disclose personal data only in the following limited circumstances:

• Service providers: We share data with contracted service providers who process it on our behalf, including KYC verification vendors, payment processors, cloud infrastructure providers, fraud detection tools, and customer support platforms. All such providers are bound by data processing agreements requiring them to protect your data and use it only for the specified purpose.
• Regulatory authorities: ph1111 is required to share certain data with PAGCOR, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies where required by law or regulatory obligation.
• Law enforcement: ph1111 may disclose personal data to Philippine law enforcement or judicial authorities in response to a lawfully issued order, subpoena, or warrant.
• Business transfers: In the event of a merger, acquisition, or sale of all or part of ph1111's business, your personal data may be transferred to the acquirer subject to the same privacy protections described in this Policy.

6.2 Where ph1111 engages third-party game providers (such as JILI, PG Soft, or Pragmatic Play), those providers may receive limited technical session data necessary to operate their games. They do not receive your KYC documents or full financial data.

7 Data Retention

7.1 ph1111 retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligation. The following retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years following account closure, as required by PAGCOR regulations and Philippine anti-money laundering laws.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming activity records: Retained for a minimum of three (3) years from the date of each game session.
• Customer support communications: Retained for two (2) years from the date of the communication, unless longer retention is required for an unresolved dispute.
• Technical and device data: Retained for up to twelve (12) months from collection.

7.2 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised so that it can no longer be associated with an identifiable individual.

8 Data Security

8.1 ph1111 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph1111's servers;
• Encryption at rest for sensitive personal data including KYC documents and financial transaction records;
• Multi-factor authentication requirements for internal staff accessing personal data systems;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular penetration testing and vulnerability assessments of the Platform and underlying infrastructure;
• Incident response procedures for detecting, containing, and notifying affected individuals and the National Privacy Commission (NPC) of personal data breaches, as required by the DPA.

8.2 Notwithstanding these measures, no internet transmission or electronic storage system is entirely secure. While ph1111 takes its security obligations seriously, we cannot absolutely guarantee the security of data transmitted to or stored on the Platform.

9 Cookies & Tracking Technologies

9.1 ph1111 uses cookies and similar tracking technologies on the Platform. Cookies are small text files placed on your device when you visit a website. They enable core functionality, improve performance, and support analytics.

9.2 ph1111 uses the following categories of cookies:

• Strictly necessary cookies: Required for core Platform functions including login session management, security tokens, and payment flow continuity. These cannot be disabled without impairing core functionality.
• Performance and analytics cookies: Collect aggregated, anonymised data about how players navigate and use the Platform to help us identify performance issues and improve the user experience.
• Functional cookies: Remember your preferences such as language settings, display preferences, and last-visited game categories.
• Fraud prevention cookies: Assigned session identifiers and device fingerprinting data used to detect and prevent fraudulent account activity and multi-accounting.

9.3 You may control cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from accessing the Platform, but may affect certain features and personalisation functionality. ph1111 does not currently respond to "Do Not Track" browser signals.

10 Your Data Subject Rights

10.1 Under the Data Privacy Act of 2012 and its Implementing Rules, you have the following rights in respect of your personal data processed by ph1111:

10.2 To exercise any of the above rights, submit a written request to ph1111's Data Protection Officer (DPO) via the contact information in Section 13. We will respond to all verified data subject requests within fifteen (15) business days of receipt.

10.3 Please note that certain rights may be subject to limitations where retention of your personal data is required by law — for example, KYC and transaction data retained under PAGCOR and anti-money laundering obligations cannot be deleted upon request during the mandatory retention period, even if you close your account.

10.4 If you are unsatisfied with ph1111's response to a data subject request or believe we are processing your personal data in violation of the DPA, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

11 Children's Privacy

11.1 The ph1111 Platform is intended solely for adults aged 21 years and above, in compliance with PAGCOR regulations governing online casino gaming in the Philippines. ph1111 does not knowingly collect personal data from persons under 21 years of age.

11.2 If ph1111 becomes aware that it has collected personal data from a person under 21 years of age, we will immediately close the associated account, delete the personal data, and return any funds present in the account to the payment source used for deposit, subject to applicable legal requirements.

11.3 If you are a parent or guardian and believe that a minor has registered on the ph1111 Platform, please contact our customer support team or DPO immediately via the details in Section 13. We will take immediate action to investigate and address the matter.

12 Updates to This Privacy Policy

12.1 ph1111 may update this Privacy Policy from time to time to reflect changes in our data processing practices, the Platform's features, applicable Philippine law, or regulatory requirements. Material changes will be communicated to registered players by email to their registered address and/or by a prominent notice on the Platform.

12.2 The date at the top of this Privacy Policy indicates when it was most recently updated. We encourage you to review this Privacy Policy periodically. Your continued use of the Platform following the effective date of any update constitutes your acknowledgment of the revised Policy.

13 Contact & Data Protection Officer

13.1 ph1111 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. For data subject requests, privacy complaints, or questions about this Policy, please contact:

• Data Protection Officer — ph1111
• Email: [email protected] (plain text — not a clickable link)
• Live Chat: 24/7 via the site widget — reference "Privacy / DPO Request" at the start of your message
• Response commitment: All privacy-related queries acknowledged within 3 business days; full response within 15 business days

13.2 For complaints to the National Privacy Commission of the Philippines, refer to the NPC's official website and complaint procedures. ph1111 will cooperate fully with any NPC investigation.