Privacy Policy — 111pk

1. Who We Are

111pk is an online gaming platform accessible at https://111pk.pro, operated under PAGCOR authorization and directed at players physically located in the Philippines. For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act 10173), 111pk is the Personal Information Controller responsible for the personal data you provide when registering and using our platform.

Our designated Data Protection Officer (DPO) oversees all data privacy compliance matters and can be contacted at the details provided in Section 14 of this Policy. We are registered with and accountable to the National Privacy Commission (NPC) of the Philippines.

2. Data We Collect

111pk collects personal data from you through several channels. The categories of data we collect, and the specific data points within each category, are described in the table below:

2.1 Data You Provide Directly

The majority of personal data 111pk holds about you is data you have provided directly — through the registration form, KYC document upload, payment method verification, or by communicating with our support team. Providing accurate and complete information is a condition of your account agreement with 111pk.

2.2 Data Collected Automatically

When you access the 111pk platform, certain technical data is collected automatically through cookies, server logs, and similar tracking technologies. This data is primarily used for platform security, fraud prevention, and improving the gaming experience. See Section 5 for full details on our cookie practices.

2.3 Data from Third Parties

111pk may receive limited personal data from third-party payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank) to confirm the status and ownership of payment methods linked to your account. This data is used exclusively for transaction verification and anti-fraud purposes.

3. How We Use Your Data

111pk processes your personal data for the following specific purposes. We do not use your data for any purpose not listed here without first obtaining your separate and explicit consent:

• Account Creation and Management: To register your 111pk player account, maintain your account profile, and authenticate your identity each time you log in.
• KYC and Age Verification: To verify that you are at least 21 years of age as required by Philippine gaming regulations, and to confirm your identity before processing withdrawals.
• Payment Processing: To process deposits to your 111pk account and withdrawals to your verified Philippine payment method (GCash, PayMaya, BPI, BDO, or Metrobank), and to maintain accurate financial records.
• PAGCOR and Legal Compliance: To comply with PAGCOR reporting obligations, the Anti-Money Laundering Act (AMLA), the Philippine Data Privacy Act, and any other applicable Philippine laws and regulations.
• Fraud Prevention and Platform Security: To detect and prevent fraudulent activity, unauthorized account access, bonus abuse, collusion, and other conduct prohibited under our Terms and Conditions.
• Customer Support: To respond to your queries, resolve disputes, process responsible gaming requests (deposit limits, cooling-off, self-exclusion), and manage account-related communications.
• Platform Improvement: To analyze aggregated, anonymized usage data for the purpose of improving the 111pk gaming experience, fixing technical issues, and developing new features.
• Marketing Communications: To send you promotional offers, bonus notifications, and news about 111pk — only where you have opted in to receive such communications and only through the channels you have authorized.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 111pk processes your personal data on the following lawful bases:

• Contractual Necessity: Processing required to fulfill our obligations under your player account agreement — including account management, payment processing, KYC verification, and customer support.
• Legal Obligation: Processing required by Philippine law, including PAGCOR regulatory reporting, AMLA transaction monitoring, and NPC compliance obligations.
• Legitimate Interests: Processing for fraud prevention, platform security, abuse detection, and aggregated analytics, where these interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where your freely given, specific, and informed consent has been obtained. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Cookies and Tracking Technologies

5.1 What Are Cookies

Cookies are small text files placed on your device when you visit the 111pk platform. They help us recognize your browser, maintain your session, remember your preferences, and analyze how our platform is used. 111pk uses both first-party cookies (set by 111pk directly) and limited third-party cookies (set by our analytics and security service providers).

5.2 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies that keep you logged in during your gaming session. These cannot be disabled without breaking core platform functionality.
• Performance and Analytics Cookies: Used to understand how players navigate the platform — which pages are visited most, where errors occur, and how load times can be improved. Data is aggregated and anonymized.
• Functionality Cookies: Remember your preferences such as preferred language, notification settings, and responsible gaming tool configurations.
• Security Cookies: Used for fraud detection and to identify unusual login patterns or access from unfamiliar devices or IP addresses.

5.3 Managing Cookies

You may control non-essential cookies through your browser settings or through the 111pk cookie preference centre accessible from the platform footer. Please note that disabling strictly necessary cookies will prevent you from accessing your account and using the platform's gaming features.

6. Sharing Your Personal Data

111pk does not sell, rent, or trade your personal data. We share your data only in the circumstances described below, and only to the minimum extent necessary for each purpose:

• Payment Processors: GCash, PayMaya, BPI, BDO, and Metrobank receive the transaction data necessary to process your deposits and withdrawals. These providers have their own privacy policies and are independently regulated.
• Identity Verification Providers: Third-party KYC service providers who assist 111pk in verifying government-issued ID documents and confirming player identity before withdrawal processing.
• PAGCOR and Philippine Regulatory Authorities: 111pk is legally obligated to provide player data and transaction records to PAGCOR and other competent Philippine authorities upon lawful request or as required by our operating authorization.
• Anti-Money Laundering Council (AMLC): 111pk reports suspicious transactions and provides transaction data to the AMLC as required under the Philippine Anti-Money Laundering Act and its implementing regulations.
• IT and Platform Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on 111pk's behalf under strict data processing agreements and confidentiality obligations.
• Legal and Professional Advisors: In connection with legal proceedings, regulatory investigations, or professional advice, where disclosure is required and limited to what is strictly necessary.

7. International Data Transfers

The 111pk platform is primarily hosted on servers located within or legally accessible from the Philippines. Where operational necessity requires that personal data be transferred to a service provider operating outside the Philippines — for example, a cloud infrastructure provider or a licensed gaming software vendor — 111pk ensures that such transfers are conducted in compliance with Section 21 of the Philippine Data Privacy Act, which requires that the receiving party provides a level of data protection substantially equivalent to Philippine standards.

Transfers outside the Philippines are subject to contractual safeguards, including standard data processing agreements that impose obligations on the recipient equivalent to those applicable under Philippine law. You may request information about the safeguards applied to any specific international transfer by contacting our Data Protection Officer.

8. Data Retention

111pk retains your personal data for the periods set out below, after which data is securely deleted or irreversibly anonymized unless a longer retention period is required by law:

• Account and Identity Data: Retained for the duration of your active account, plus five (5) years following account closure, in compliance with Philippine AMLA record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, as mandated by AMLA and PAGCOR regulations.
• KYC Documents: Retained for five (5) years following account closure or the completion of the last transaction, whichever is later.
• Customer Support Communications: Retained for three (3) years from the date of the communication, to allow for dispute resolution and quality assurance review.
• Technical and Log Data: Retained for twelve (12) months from collection, after which it is aggregated and anonymized for statistical analysis purposes.
• Marketing Consent Records: Retained for the duration of your account, or until you withdraw consent, plus three (3) years thereafter for compliance documentation purposes.

9. Your Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 111pk. To exercise any of these rights, contact our Data Protection Officer using the details in Section 14:

• Right to be Informed: The right to know that your personal data is being collected, the purposes for which it is being processed, and how long it will be retained — all of which are set out in this Privacy Policy.
• Right to Access: The right to request a copy of the personal data 111pk holds about you, together with information about how it is being processed. We will respond to access requests within thirty (30) days.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update basic account details directly in your account settings; for KYC data corrections, contact our support team.
• Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to 111pk's legal retention obligations under AMLA and PAGCOR regulations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. You may exercise this right at any time by updating your communication preferences in account settings.
• Right to Data Portability: The right to receive a structured, commonly used, and machine-readable copy of the personal data you have provided to 111pk, for the purpose of transmitting it to another controller.
• Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe 111pk has violated your data privacy rights. NPC contact information is available at privacy.gov.ph.

10. Children's Privacy

The 111pk platform is strictly prohibited for use by individuals under the age of 21 years, in accordance with Philippine gaming laws and PAGCOR regulations. 111pk does not knowingly collect personal data from individuals under 21 years of age.

If 111pk becomes aware that a player is under 21, or that personal data has been collected from an individual who was under 21 at the time of registration, that account will be immediately suspended and all associated personal data will be deleted, subject to any legal retention obligations that may apply.

If you are a parent or guardian and believe that a person under 21 in your care has registered on 111pk, please contact our support team immediately at [email protected].

11. Marketing Communications

111pk may send you marketing communications — including bonus offers, promotional notifications, and platform news — where you have opted in to receive such communications during registration or via your account communication preferences. We currently communicate via email and SMS to your registered Philippine mobile number.

You may opt out of marketing communications at any time by:

• Clicking the "unsubscribe" link in any marketing email from 111pk
• Replying "STOP" to any marketing SMS from 111pk
• Updating your notification preferences in the Account Settings section of the platform
• Contacting our support team and requesting removal from marketing lists

Opting out of marketing communications will not affect transactional communications such as deposit confirmations, withdrawal notifications, KYC status updates, or responsible gaming alerts, which are sent regardless of marketing preferences as they relate directly to your account and legal obligations.

12. Security Measures

111pk implements appropriate technical and organisational measures to protect your personal data against unauthorized access, accidental loss, destruction, or disclosure. Our security framework includes:

• Transport Layer Security (TLS 1.3): All data transmitted between your browser or app and the 111pk platform is encrypted in transit.
• AES-256 Encryption at Rest: Personal data, financial records, and KYC documents stored on 111pk servers are encrypted at rest.
• Multi-Factor Authentication: Account login is protected by OTP-based verification sent to your registered Philippine mobile number.
• Access Controls: Internal access to personal data is restricted on a strict need-to-know basis. 111pk staff access to player data is logged and regularly audited.
• Penetration Testing: The 111pk platform undergoes regular third-party penetration testing and vulnerability assessments to identify and remediate security risks before they can be exploited.
• Incident Response Plan: 111pk maintains a documented data breach response plan, including NPC notification procedures, to ensure rapid and compliant response to any security incident.

While 111pk takes all reasonable steps to protect your personal data, no internet-based platform can guarantee absolute security. You are responsible for keeping your 111pk login credentials confidential and for notifying us promptly if you suspect unauthorized access to your account.

13. Changes to This Privacy Policy

111pk reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or the features of the platform. The "Last Updated" date at the top of this page will be revised each time a material change is made.

For material changes — those that significantly affect how we collect, use, or share your personal data, or that reduce your rights — 111pk will notify you via email to your registered address at least seven (7) days before the changes take effect. For minor editorial or clarification updates, the revised Policy will be published on this page without advance notice.

Your continued use of the 111pk platform after the effective date of a revised Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree with any material change, you must discontinue use and contact our support team to close your account.

14. Contact Our Data Protection Officer

For any privacy-related queries, data rights requests, or concerns about how 111pk processes your personal data, please contact our designated Data Protection Officer using the details below:

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