Privacy Policy

1Introduction and Identity of the Data Controller

1.1 This Privacy Policy is issued by 111taya ("111taya," "we," "us," or "our"), the operator of the online casino and sports betting platform accessible at 111taya.org. 111taya is a Philippine-incorporated entity operating under a valid license issued by the Philippine Amusement and Gaming Corporation (PAGCOR).

1.2 For the purposes of the Philippine Data Privacy Act of 2012 (Republic Act 10173) and its Implementing Rules and Regulations, 111taya is the Personal Information Controller in respect of all personal data collected and processed through the 111taya platform.

1.3 111taya has appointed a Data Protection Officer (DPO) to oversee compliance with data protection law. The DPO's contact details are set out in Section 15 of this Policy.

1.4 By registering an account on 111taya, or by continuing to use the platform after the effective date of this Policy, you acknowledge that you have read and understood this Policy and consent to the processing described herein to the extent that consent is the applicable legal basis.

2Scope of This Policy

2.1 This Policy applies to all personal data collected by 111taya from or about:

• Registered players who hold or have held an account on the 111taya platform;
• Prospective players who have commenced but not completed the registration process;
• Visitors to the 111taya.org website who have not registered an account;
• Any individual who communicates with 111taya through any channel including live chat, email, or social media.

2.2 This Policy does not apply to the data practices of third-party game providers, payment processors, or other external services that may be accessible through or linked to the 111taya platform. Those parties operate under their own privacy policies and 111taya does not control their data practices beyond contractual data processing obligations.

2.3 This Policy is to be read together with 111taya's Terms and Conditions available at /terms-conditions, which are incorporated by reference.

3Categories of Personal Data We Collect

3.1 The following table summarises the categories of personal data that 111taya may collect and process:

3.2 111taya does not collect special categories of personal data (sensitive personal information) such as health data, biometric data for identification purposes (beyond liveness verification during KYC), racial or ethnic origin, religious beliefs, or political opinions — except where explicitly required by a PAGCOR or NPC directive.

4How We Collect Your Personal Data

4.1 Directly from you when you:

• Complete the account registration form on 111taya.org;
• Submit KYC documents through the account verification portal;
• Make a deposit or withdrawal request;
• Contact 111taya through live chat, email, or any other support channel;
• Participate in promotions, surveys, or responsible gaming assessments;
• Update your account profile or preferences.

4.2 Automatically through the platform when you:

• Browse 111taya.org — technical and device data are collected via server logs and session analytics;
• Log in to your account — authentication data including IP address and device fingerprint are recorded;
• Play any game — session data including bet amounts, outcomes, and timestamps are generated and stored;
• Accept or use cookies on 111taya.org in accordance with Section 10.

4.3 From third parties including:

• KYC verification service providers used to validate government-issued identity documents;
• Payment processors (GCash, Maya, BPI, BDO, Metrobank) who confirm transaction completion;
• AML screening databases used for PEP and sanctions list checks;
• PAGCOR's national self-exclusion registry for account eligibility verification.

5Purposes of Processing and Legal Bases

5.1 111taya processes your personal data only for specified, legitimate purposes. The table below identifies each processing purpose and the applicable legal basis under the Philippine Data Privacy Act:

5.2 Where 111taya relies on consent as the legal basis (primarily for marketing communications), you may withdraw that consent at any time by updating your communication preferences in your Account Settings or by contacting the DPO. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

6Disclosure of Personal Data to Third Parties

6.1 111taya does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes — ever.

6.2 111taya shares personal data with third parties only in the following limited circumstances:

Regulated and Required Disclosures

• PAGCOR: As a licensed operator, 111taya is required to report certain player activity, compliance metrics, and suspicious transactions to PAGCOR as part of its licensing obligations.
• Anti-Money Laundering Council (AMLC): Under Republic Act 9160, as amended, 111taya is a covered entity and must file covered transaction reports (CTRs) and suspicious transaction reports (STRs) with the AMLC where thresholds or triggers are met.
• Law enforcement and judicial authorities: Where required by a valid court order, subpoena, or lawful directive from a Philippine government authority, 111taya will disclose personal data as required.

Service Providers (Data Processors)

• KYC and identity verification providers: Third-party services that verify government-issued identification documents submitted during the account verification process.
• Payment processors: GCash (Mynt), Maya (PayMaya Philippines), BPI, BDO, Metrobank, and other payment partners receive the minimum data necessary to process your transactions.
• Game providers: JILI Games, PG Soft, Pragmatic Play, Evolution Gaming, and other content providers receive session and stake data necessary to operate their game engines. They do not receive your full identity profile.
• Cloud infrastructure providers: 111taya uses reputable cloud hosting services. All such providers are contractually bound by data processing agreements that comply with NPC standards.
• Customer support platforms: The live chat tool used by 111taya's support team processes chat transcripts and may store conversation history for quality and training purposes.

6.3 All third-party service providers engaged by 111taya are bound by written data processing agreements that require them to process personal data only on 111taya's instructions, maintain appropriate security measures, and comply with applicable Philippine data protection law.

7International Data Transfers

7.1 Some of 111taya's service providers, including game providers and cloud infrastructure partners, may be located outside the Philippines. Where personal data is transferred to recipients in countries that have not been assessed as providing an adequate level of data protection under NPC standards, 111taya ensures that appropriate safeguards are in place, including:

• Standard contractual clauses approved by the National Privacy Commission (NPC);
• Binding corporate rules where applicable;
• Specific NPC authorisation for the transfer where required.

7.2 You may request information about the specific safeguards applicable to any international transfer of your personal data by contacting the DPO.

8Data Retention

8.1 111taya retains personal data for as long as is necessary for the purposes for which it was collected, subject to the following minimum retention periods imposed by Philippine law:

8.2 Upon expiry of the applicable retention period, personal data is either securely deleted or anonymised such that it can no longer be linked to any identifiable individual. Anonymised, aggregated data may be retained indefinitely for platform analytics purposes.

9Security Measures

9.1 111taya implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• Encryption in transit: All data transmitted between your device and 111taya's servers is encrypted using TLS 1.2 or higher (256-bit SSL). The platform's HTTPS certificate is verified and renewed continuously.
• Encryption at rest: Sensitive data including payment details, identity document images, and KYC data are encrypted at rest using AES-256.
• Access controls: Internal access to player personal data is restricted on a need-to-know basis. All staff with data access receive data privacy training and are bound by confidentiality obligations.
• Multi-factor authentication: Internal systems containing player data require multi-factor authentication for all staff access. Player-facing 2FA is available to all registered players.
• Penetration testing: 111taya engages independent security firms to conduct regular penetration testing of the platform and data infrastructure.
• Breach response plan: 111taya maintains a formal data breach response plan. In the event of a personal data breach that poses a real risk to data subjects, 111taya will notify the National Privacy Commission within 72 hours of becoming aware of the breach and notify affected players promptly.

9.2 Notwithstanding the above, no system can guarantee absolute security. You are responsible for maintaining the security of your account credentials as described in the Terms and Conditions.

10Cookies and Tracking Technologies

10.1 111taya uses cookies and similar tracking technologies on the 111taya.org website. Cookies are small text files stored on your device that help the platform function correctly and allow us to understand how it is used.

10.2 The following categories of cookies are used:

• Strictly Necessary Cookies: These are essential for the platform to operate. They enable functions such as maintaining your logged-in session, remembering your preferences, and preventing fraud. These cookies cannot be disabled without breaking core platform functionality.
• Analytics Cookies: Used to collect anonymised, aggregated data about how visitors use 111taya.org — which pages are visited, how long sessions last, and where traffic originates. This data is used to improve the platform. You may opt out of analytics cookies through the cookie preference centre.
• Functional Cookies: These remember your preferences such as preferred language, responsible gaming settings, and game display options to provide a more personalised experience.

10.3 No third-party advertising cookies are used on 111taya.org. We do not allow advertising networks or data brokers to place tracking pixels or cookies on our platform.

10.4 You can manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may affect platform functionality. A persistent cookie preference banner is available on your first visit to 111taya.org.

11Your Rights as a Data Subject

11.1 Under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by 111taya. To exercise any of these rights, please contact the DPO using the details in Section 15.

11.2 111taya will verify your identity before acting on any data subject request to prevent unauthorised access to another person's data. We may ask you to provide your registered mobile number, KYC-verified name, and a copy of your ID for this purpose.

11.3 Requests are processed free of charge. If requests are manifestly unfounded, repetitive, or excessive, 111taya may charge a reasonable administrative fee or decline to act, with reasons provided.

12Responsible Gaming and Personal Data

12.1 As part of its PAGCOR-mandated responsible gaming obligations, 111taya processes gaming activity data — including session duration, bet frequency, deposit patterns, and net loss metrics — to:

• Monitor for behavioural patterns associated with problem gambling;
• Enforce player-set deposit limits, loss limits, and session time limits;
• Honour self-exclusion requests and cross-reference against the PAGCOR self-exclusion registry;
• Send responsible gaming prompts and resources to players exhibiting at-risk behaviour.

12.2 Self-exclusion records are maintained for the duration of the exclusion period plus five years, as required by PAGCOR. A self-excluded player's name and mobile number are matched against new registration attempts to prevent re-registration during the exclusion period.

12.3 Responsible gaming data is not shared with marketing teams or used to influence promotional targeting decisions. It is maintained in a restricted-access environment and reviewed only by compliance and support personnel.

13Minors and Age Verification

13.1 The 111taya platform is strictly restricted to individuals aged 21 years and older as required by PAGCOR. 111taya does not knowingly collect personal data from any person under the age of 21.

13.2 Age verification is conducted as part of the KYC process. Where 111taya discovers that an account has been registered by or for a person under 21 years of age, the account will be immediately suspended, all balances held pending investigation, and the personal data retained only to the extent required for regulatory reporting and prevention of re-registration.

13.3 If you believe that a person under the age of 21 has registered an account on 111taya, please notify us immediately at [email protected] or via live chat. We will investigate and act promptly.

14Changes to This Privacy Policy

14.1 111taya may update this Privacy Policy from time to time to reflect changes in our data practices, applicable law, or PAGCOR regulatory requirements. The updated Policy will be published at 111taya.org/privacy-policy with a revised Effective Date.

14.2 For material changes — those that significantly affect how we process your personal data or your rights — 111taya will provide advance notice by email to your registered address and/or by a notice on the platform homepage at least seven (7) calendar days before the changes take effect.

14.3 Changes required for immediate legal or regulatory compliance may take effect with shorter or no advance notice. We will notify you of such changes as soon as practicable.

14.4 Continued use of the 111taya platform after the Effective Date of an updated Privacy Policy constitutes your acknowledgment of the updated Policy. If you do not agree with material changes, you may request account closure in accordance with the Terms and Conditions before the changes take effect.

15Contact Information and Data Protection Officer

15.1 For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 111taya, please contact our Data Protection Officer:

15.2 If you are not satisfied with 111taya's response to a data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines (NPC), the independent supervisory authority for data protection in the Philippines. The NPC can be reached through official NPC government channels.

15.3 For regulatory matters involving 111taya's gaming license, you may also contact PAGCOR through official PAGCOR channels.