Privacy Policy

At 111pub, we understand that trust is fundamental to the relationship between an online gaming platform and its players. Your personal data is entrusted to us when you register an account, make a deposit, play a game, or interact with any feature of our platform. We take this responsibility seriously and have implemented comprehensive policies, procedures, and technical safeguards to ensure that your information is handled lawfully, transparently, and securely.

This Privacy Policy explains in clear terms what personal data we collect, why we collect it, how we use it, who we share it with, how long we keep it, and what rights you have regarding your own data. We encourage you to read this Policy carefully and to contact us if you have any questions or concerns about how your personal information is managed on 111pub.

For the purposes of the Data Privacy Act of 2012, 111pub is the data controller responsible for the personal data you provide to us through the platform. As the data controller, 111pub determines the purposes and means of processing your personal information and is accountable for compliance with all applicable data protection laws in the Philippines.

111pub operates under a valid license issued by the Philippine Amusement and Gaming Corporation (PAGCOR), and our data processing activities are conducted in accordance with PAGCOR's regulatory requirements, including those related to Anti-Money Laundering (AML), Know Your Customer (KYC), and responsible gaming.

111pub collects and processes several categories of personal data to provide you with access to our gaming services, comply with legal obligations, and improve your user experience. The types of personal information we collect include:

3.1 Account Registration Information

When you create an account on 111pub, we collect:

• Full legal name (as it appears on your government-issued ID)
• Date of birth
• Gender
• Email address
• Philippine mobile phone number
• Residential address (barangay, city, province)
• Username and password (password is stored in encrypted form)

3.2 Identity Verification and KYC Documents

As required by PAGCOR and Philippine AML regulations, we collect:

• Government-issued photo identification (e.g., UMID, Driver's License, Passport, PhilSys National ID, SSS ID, Voter's ID)
• Proof of address documents (utility bills, bank statements, barangay certificates)
• Selfie or photograph for identity confirmation
• Source of funds documentation if requested under AML procedures

3.3 Financial and Transaction Data

To process deposits, withdrawals, and gaming activity, we collect:

• GCash, PayMaya, or bank account details (to the extent you provide them)
• Deposit and withdrawal transaction history
• Payment method verification details
• Bet history, win/loss records, and gaming account balance

3.4 Technical and Usage Data

When you access 111pub, we automatically collect:

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Login timestamps and session duration
• Pages viewed, games played, and clickstream data
• Cookies and similar tracking technologies (see Section 10)

3.5 Communication and Support Data

When you contact our customer support team, we may collect:

• Chat transcripts and email correspondence
• Complaint details and resolution records
• Feedback, reviews, and survey responses

111pub processes your personal data for the following purposes:

• Account Management: To register, maintain, and manage your 111pub account.
• Transaction Processing: To process deposits, withdrawals, and gaming transactions via GCash, PayMaya, or bank transfer.
• Identity Verification: To verify your identity and age (21+) in compliance with PAGCOR's KYC requirements.
• AML Compliance: To conduct Anti-Money Laundering checks and monitor transactions for suspicious activity as required under Philippine law.
• Game Provision: To enable access to Vivo Live casino, Fisher Game, Bingo, Slots, and all other gaming products offered on 111pub.
• Customer Support: To respond to your inquiries, resolve complaints, and provide technical assistance.
• Fraud Prevention: To detect, investigate, and prevent fraudulent activity, multi-accounting, bonus abuse, and other prohibited conduct.
• Responsible Gaming: To implement deposit limits, self-exclusion requests, and other responsible gaming tools as set by you or required by regulation.
• Marketing and Promotions: To send you information about bonuses, promotions, and new game releases (where you have consented to receive such communications).
• Legal Compliance: To comply with applicable laws, PAGCOR regulations, court orders, and law enforcement requests.
• Platform Improvement: To analyze usage patterns, improve website functionality, and enhance user experience.

Under the Data Privacy Act of 2012, 111pub processes your personal data on the following legal grounds:

• Consent: You have given explicit consent for us to process your personal data for one or more specific purposes (e.g., marketing communications).
• Contract Performance: Processing is necessary for the performance of our contract with you — specifically, the provision of gaming services under our Terms and Conditions.
• Legal Obligation: Processing is required to comply with Philippine law, including PAGCOR regulations, AML requirements, and tax reporting obligations.
• Legitimate Interests: Processing is necessary for our legitimate business interests, such as fraud prevention, platform security, and service improvement, provided such interests do not override your fundamental rights and freedoms.

111pub does not sell, rent, or lease your personal information to third parties for marketing purposes. We may, however, share your data with the following categories of recipients for the purposes described in this Policy:

• Game Providers: Third-party game developers and software providers (e.g., JILI Gaming, Pragmatic Play, Evolution Gaming) may process your gameplay data to deliver their games through the 111pub platform.
• Payment Processors: GCash, PayMaya, and banking partners process your financial data to facilitate deposits and withdrawals.
• Identity Verification Services: Third-party KYC and AML screening services may process your identification documents to verify your identity and compliance with regulatory requirements.
• Cloud and IT Service Providers: Hosting and infrastructure providers who store and secure the 111pub platform and database.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other government agencies as required by law.
• Legal and Professional Advisors: Lawyers, auditors, and consultants who assist us in legal compliance and business operations.
• Law Enforcement: We may disclose your data to law enforcement agencies in response to a valid court order, subpoena, or leg al request arising from your use of the platform.

All third-party service providers with whom we share your data are contractually obligated to maintain the confidentiality and security of your information and to process it only for the purposes we specify.

111pub employs industry-standard security measures to protect your personal information from unauthorized access, disclosure, alteration, or destruction. Our security practices include:

• Encryption: All data transmitted between your device and our servers is encrypted using SSL/TLS protocols. Sensitive data stored in our databases (including passwords and financial information) is encrypted at rest.
• Access Controls: Access to personal data is restricted to authorized 111pub personnel who require such access to perform their job functions. All staff are bound by confidentiality obligations.
• Firewall and Intrusion Detection: Our infrastructure is protected by firewalls, intrusion detection systems, and regular security monitoring.
• Regular Audits: We conduct regular security audits and vulnerability assessments to identify and address potential security risks.
• Secure Data Centers: Our data is stored in secure, certified data centers with physical and environmental security controls.

While we take all reasonable measures to protect your data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect unauthorized access to your account.

111pub retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Active Accounts: Personal data for active accounts is retained for the duration of your account relationship with 111pub.
• Closed Accounts: After account closure, we retain identification documents and transaction records for a minimum of five (5) years as required by PAGCOR and Philippine AML regulations.
• Transaction Records: Financial transaction data, bet history, and gaming records are retained for five (5) years from the date of the transaction.
• Marketing Data: If you have consented to receive marketing communications, your contact information is retained until you withdraw consent or the account is closed.
• Technical Data: Log files, IP addresses, and session data are typically retained for up to 12 months for security and fraud prevention purposes.

After the applicable retention period expires, we will securely delete or anonymize your personal data in accordance with our data destruction policies.

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data processed by 111pub:

• Right to be Informed: You have the right to be informed about the collection and processing of your personal data — which is the purpose of this Privacy Policy.
• Right of Access: You have the right to request a copy of the personal data we hold about you. You may submit an access request by contacting our Data Protection Officer (see Section 15).
• Right to Rectification: You have the right to correct inaccurate or incomplete personal data. You can update most of your account information directly through your 111pub account settings.
• Right to Erasure: You have the right to request deletion of your personal data in certain circumstances. However, we may be required by law to retain certain data (such as transaction records) even after you request deletion.
• Right to Object: You have the right to object to certain types of processing, such as direct marketing communications. You can opt out of marketing emails by clicking the unsubscribe link or contacting support.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another controller.
• Right to Lodge a Complaint: If you believe 111pub has violated your privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of these rights, please contact our support team at [email protected] or use the live chat function. We will respond to your request within the timeframe required by Philippine law.

111pub uses cookies, web beacons, and similar tracking technologies to enhance your user experience, analyze platform usage, and deliver personalized content. A cookie is a small text file stored on your device that allows us to recognize you on subsequent visits.

We use the following types of cookies:

• Essential Cookies: Required for the platform to function properly, including login authentication and session management.
• Performance Cookies: Collect anonymous data about how you use the platform to help us improve functionality and performance.
• Functional Cookies: Remember your preferences (such as language and currency settings) to provide a more personalized experience.
• Advertising Cookies: Used to deliver relevant promotional content and measure the effectiveness of our marketing campaigns (only with your consent).

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may limit your ability to use some features of the 111pub platform.

The 111pub platform may contain links to third-party websites, services, or payment providers (such as GCash or PayMaya). This Privacy Policy applies only to 111pub. We are not responsible for the privacy practices or content of any third-party sites. We encourage you to review the privacy policies of any third-party services you access through our platform.

111pub is strictly intended for individuals who are at least 21 years of age, as required by PAGCOR regulations governing online gaming in the Philippines. We do not knowingly collect personal information from individuals under the age of 21.

All accounts are subject to KYC verification to confirm the age and identity of the account holder. If we discover that we have inadvertently collected personal data from an individual under 21 years of age, we will immediately suspend the account, delete the data, and return any deposits in accordance with our policies.

111pub primarily operates within the Philippines and stores your personal data on servers located within the Philippines or in jurisdictions with adequate data protection standards. In some cases, your data may be transferred to, stored, or processed by service providers located outside the Philippines (such as cloud hosting providers or game developers).

When we transfer your personal data internationally, we ensure that appropriate safeguards are in place to protect your information in accordance with the Data Privacy Act of 2012. These safeguards may include:

• Ensuring the recipient country has been recognized by the National Privacy Commission as providing adequate data protection;
• Implementing standard contractual clauses or data transfer agreements with third-party processors;
• Obtaining your explicit consent for the transfer where required by law.

111pub reserves the right to update or modify this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. When we make material changes to this Policy, we will notify you by:

• Posting a prominent notice on the 111pub platform;
• Sending an email notification to the address associated with your account; and/or
• Updating the "Last Updated" date at the top of this Policy.

Your continued use of the 111pub platform after any such changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your personal information.

If you have any questions, concerns, or requests regarding this Privacy Policy or how 111pub processes your personal data, please contact us using the following channels:

• Support Email: [email protected]
• Live Chat: Available 24/7 via the 111pub platform dashboard
• Business Hours: 8:00 AM – 12:00 AM Philippine Standard Time (PST)
• Coverage: Serving all Philippine regions — Manila, Cebu, Davao, Quezon City, Makati, and beyond

For formal data protection inquiries or to exercise your privacy rights under the Data Privacy Act of 2012, you may address your request to our Data Protection Officer via the email address above.

You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your privacy rights have been violated. Contact information for the NPC is available at their official website.