1111jl Privacy Policy

1 Who We Are — The Data Controller

1111jl operates the online gaming platform accessible at 1111jl.one. For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations issued by the National Privacy Commission (NPC), 1111jl is the Personal Information Controller (PIC) in respect of the personal data of its registered players and platform visitors.

As a Personal Information Controller, 1111jl determines the purposes and means of processing personal data collected through the platform and bears primary responsibility for ensuring that all processing activities comply with the Data Privacy Act, applicable NPC circulars, and PAGCOR's data governance requirements.

Where 1111jl engages third-party service providers to process data on its behalf — such as payment processors, KYC verification services, or analytics providers — those parties act as Personal Information Processors (PIPs) under contractual arrangements that impose data protection obligations consistent with this Policy and applicable law.

2 Personal Data We Collect

1111jl collects personal data that is necessary, relevant, and not excessive in relation to the purposes for which it is processed. The categories of personal data we collect are described below:

3 How We Collect Your Data

1111jl collects personal data through the following means:

3.1 Direct Collection

Information you actively provide to 1111jl when you register an account, complete the KYC verification process, make a deposit or withdrawal, contact customer support, respond to surveys or promotions, or otherwise interact with the platform in a way that requires submitting information.

3.2 Automated Collection

Technical and usage data collected automatically as you access and use the 1111jl platform, including through cookies, web beacons, server logs, and similar tracking technologies. See Section 7 for full details of our Cookie Policy.

3.3 Third-Party Sources

In certain circumstances, 1111jl may receive data about you from third parties, including:

• Payment providers (e.g., GCash, PayMaya, BDO, BPI, Metrobank) confirming transaction details;
• KYC and identity verification service providers engaged by 1111jl to validate documents;
• Fraud detection and anti-money laundering screening services;
• PAGCOR or other regulatory authorities where information is lawfully shared in the public interest or for compliance purposes.

4 Purposes of Processing

1111jl processes your personal data for the following purposes, each of which corresponds to a lawful basis described in Section 5:

5 Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 1111jl processes your personal data only where a lawful basis exists. The primary legal bases applicable to our processing activities are:

• Contractual Necessity: Processing necessary for the performance of your account agreement with 1111jl, including account creation, payment processing, game access, and customer support.
• Legal Obligation: Processing required for compliance with PAGCOR regulations, the Anti-Money Laundering Act, the Data Privacy Act, and other applicable Philippine laws. 1111jl cannot operate lawfully without fulfilling these obligations.
• Legitimate Interest: Processing necessary for 1111jl's legitimate interests in operating a secure, fair, and commercially viable gaming platform — including fraud detection, platform security, and business analytics — provided such interests are not overridden by your privacy rights.
• Consent: Processing based on your freely given, specific, and informed consent — primarily in relation to marketing communications and optional platform features. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 How We Share Your Data

1111jl does not sell your personal data. We may share your personal data with third parties only in the following circumstances:

6.1 Service Providers (Personal Information Processors)

We engage trusted third-party vendors to process data on our behalf under strict contractual data protection agreements. These include payment processors (GCash, PayMaya, BDO, BPI, Metrobank, crypto processors), KYC verification services, fraud detection providers, cloud hosting providers, and customer support platform operators. All PIPs engaged by 1111jl are required to implement data protection standards consistent with R.A. 10173.

6.2 Regulatory and Law Enforcement Authorities

1111jl is required by law to share certain player data with PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, the Bureau of Internal Revenue (BIR), and other competent Philippine authorities upon lawful demand or as required by applicable regulations. Disclosures under this section are made in strict compliance with the requirements of the relevant authority.

6.3 Game Providers

Third-party game providers whose titles appear on the 1111jl platform may receive limited technical data (such as session identifiers) necessary to operate their games within the platform environment. Such providers do not receive your full personal profile and are contractually prohibited from using any received data for independent purposes.

6.4 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, subject to equivalent data protection commitments.

7 Cookies & Tracking Technologies

The 1111jl platform uses cookies and similar tracking technologies to operate core platform features, analyze usage, and improve the player experience. A cookie is a small text file placed on your device by the 1111jl web server when you visit the platform.

7.1 Types of Cookies Used

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from accessing the 1111jl platform, though some functional features may be affected. Strictly necessary and security cookies cannot be disabled as they are integral to the secure operation of the platform.

8 Data Retention

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

• Active Account Data: Retained for the duration of your account relationship with 1111jl and for a period thereafter as required for legal and regulatory compliance;
• Transaction and Financial Records: Retained for a minimum of five (5) years from the date of the transaction in compliance with PAGCOR AML requirements and BIR record-keeping obligations;
• KYC Documents: Retained for a minimum of five (5) years following account closure or the date of the last transaction, whichever is later, in compliance with the Anti-Money Laundering Act;
• Customer Support Records: Retained for a period of three (3) years following resolution of the relevant query or dispute;
• Marketing Consent Records: Retained for the duration of your consent and for a reasonable period thereafter as evidence of consent;
• Closed or Dormant Accounts: Data is retained for the legally required minimum period following account closure, after which it is securely deleted or anonymized.

Upon expiry of the applicable retention period, personal data is securely destroyed or irreversibly anonymized so that it can no longer be associated with any individual.

9 Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and 1111jl servers — the same standard used by Philippine banks and GCash;
• Encryption at rest for sensitive data including identity documents and financial records stored on 1111jl infrastructure;
• Access controls limiting personal data access to authorized 1111jl staff and service providers with a legitimate operational need;
• Password hashing — account passwords are never stored in readable form;
• Two-factor authentication (2FA) available to all players and required for administrative access;
• Regular security assessments and penetration testing of the platform infrastructure;
• Incident response procedures to detect, contain, and respond to data security incidents.

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 and affected data subjects in accordance with the timelines and requirements of the Data Privacy Act and NPC Circular 16-03.

10 Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights in relation to the personal data 1111jl holds about you:

To exercise any of these rights, contact the 1111jl Data Privacy Officer through the channels described in Section 15. 1111jl will respond to all valid requests within thirty (30) days. Some requests may require identity verification before processing to ensure we are responding to the correct data subject.

11 Children's Privacy and the 21+ Rule

The 1111jl platform is strictly intended for adults aged 21 years and older in accordance with PAGCOR regulations governing online gaming in the Philippines. 1111jl does not knowingly collect personal data from individuals under the age of 21.

12 International Data Transfers

1111jl's primary operations are based in the Philippines, and personal data is processed principally within the Philippines. However, certain third-party service providers — including cloud infrastructure providers, game providers, and technology vendors — may be located or operate servers in other countries.

Where personal data is transferred outside the Philippines, 1111jl ensures that such transfers are lawful and that the receiving party implements data protection standards equivalent to those required under R.A. 10173, through one or more of the following mechanisms:

• Contractual clauses that impose equivalent data protection obligations on the receiving party;
• The recipient country has been assessed as providing an adequate level of data protection;
• The transfer is necessary for the performance of the contract between 1111jl and the data subject.

Players who wish to obtain further information about the safeguards applicable to specific international data transfers may contact the 1111jl Data Privacy Officer.

13 AML Obligations & PAGCOR Reporting

As a PAGCOR-regulated gaming operator, 1111jl is subject to the Republic of the Philippines Anti-Money Laundering Act of 2001 (R.A. 9160) as amended by R.A. 10365 and R.A. 11521, and associated regulations issued by the Anti-Money Laundering Council (AMLC) and PAGCOR.

Under these obligations, 1111jl:

• Collects and verifies the identity of all registered players before approving withdrawals and for significant transactions;
• Maintains transaction monitoring systems that flag and escalate transactions exhibiting patterns consistent with money laundering or terrorist financing;
• Files Covered Transaction Reports (CTRs) and Suspicious Transaction Reports (STRs) with the AMLC as required by law;
• Retains transaction records for a minimum of five (5) years as required under AML regulations.

Players should be aware that AML reporting obligations may require 1111jl to disclose personal and financial information to the AMLC or other authorized government bodies without prior notification to the data subject, as permitted under Philippine law. These disclosures are legally mandated and not subject to data subject consent.

14 Changes to This Privacy Policy

1111jl reviews and updates this Privacy Policy periodically to reflect changes in our data processing practices, applicable law, PAGCOR or NPC guidance, or platform features.

When material changes are made to this Policy — changes that significantly affect how we collect, use, or share your personal data — we will provide notice to registered players via the platform notification system or the registered email address, where practicable, at least seven (7) days before the changes take effect.

Minor or clarificatory changes may be published without individual advance notice. The updated Effective Date at the top of this document will always reflect when the current version came into force. We recommend reviewing this Policy periodically. Your continued use of the 1111jl platform following publication of an updated Policy constitutes acceptance of the revised terms.

If you disagree with any material change to this Privacy Policy, you may request account closure in accordance with the account closure procedures described in the 1111jl Terms & Conditions.

15 Contact — Data Privacy Queries & Complaints

For all privacy-related enquiries, including requests to exercise your data subject rights, questions about data processing practices, or concerns about how your personal data has been handled, please contact the 1111jl Data Privacy Officer:

If you are not satisfied with how 1111jl has handled your personal data or responded to a rights request, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph. The NPC is the supervisory authority responsible for enforcing the Data Privacy Act of 2012 in the Philippines.

This Privacy Policy was last updated on 1 January 2026 and supersedes all previous versions. Copyright © 2026 1111jl. All rights reserved.