PH111 Privacy Policy

01Who We Are and Who This Policy Covers

PH111 ("we," "us," "our," or "the Platform") operates ph111.vu, an online gaming and sports betting platform serving players in the Philippines. This Privacy Policy describes how PH111 collects, processes, stores, and protects personal data belonging to:

• Visitors who browse ph111.vu without registering
• Registered Members who have created a PH111 account
• Users who access PH111 through the Android APK or the mobile browser experience

When we say "personal data," we mean any information that identifies you or that can be used to identify you, directly or in combination with other data. This includes your name, contact details, government ID information, and device and usage data collected while you use the Platform.

02What Personal Data We Collect

We collect personal data in several ways depending on how you interact with PH111. The categories of data we may collect include:

• Registration data: Full name, date of birth, email address, mobile number, and chosen username and password when you create an account.
• Identity verification (KYC) data: Government-issued ID (such as a Philippine passport, SSS, UMID, or driver's licence), selfie or photo verification, and proof of address when required for KYC compliance.
• Financial data: Details of deposits and withdrawals in PHP, payment method type (such as GCash, Maya, or bank transfer), and transaction history. We do not store full payment account credentials on our servers.
• Account activity data: Betting history, game session records, login times, IP addresses, and device identifiers.
• Communication data: Messages, emails, and chat records exchanged with our support team.
• Technical data: Browser type, operating system, mobile device model, screen resolution, and referring URL collected via cookies and similar technologies.

We collect only the data that is necessary to operate the Platform, comply with our legal obligations, and provide a safe and fair gaming environment. We do not collect sensitive personal categories of data such as racial or ethnic origin, political opinions, or health information unless specifically required by law and with your explicit consent.

03How We Collect Your Data

Your data is collected through the following channels:

• Directly from you: When you register, complete KYC, make a deposit or withdrawal, contact support, or update your account profile.
• Automatically: When you visit ph111.vu or use the PH111 app, we automatically collect technical and usage data via cookies, server logs, and similar tracking technologies.
• From third-party payment providers: When you deposit or withdraw using a local payment channel, the provider may share transaction confirmation data with us for reconciliation purposes.
• From identity verification partners: Where we engage third-party KYC service providers, they may process your identity documents on our behalf and return verification results to us.

We do not purchase or source personal data from data brokers, list providers, or other third parties for marketing or profiling purposes.

04How We Use Your Personal Data

The table below outlines the main purposes for which we use your personal data and the legal basis that applies to each:

We do not use automated decision-making or profiling in ways that produce legal or similarly significant effects on you without your knowledge.

05Cookies and Tracking Technologies

PH111 uses cookies and similar technologies to operate the Platform effectively and to improve your experience. Cookies are small text files placed on your device by your browser when you visit ph111.vu.

We use the following types of cookies:

• Essential cookies: Required for the Platform to function. These include session management, login state, and security tokens. The Platform cannot operate without these.
• Functional cookies: Remember your preferences such as language settings, display preferences, and previously entered information to reduce repetitive input.
• Analytics cookies: Collect anonymised data about how visitors interact with the Platform — such as pages visited and time spent — to help us identify areas for improvement.
• Security cookies: Support fraud detection, account security verification, and OTP-related session handling.

You can manage cookie preferences through your browser settings. Disabling essential cookies may prevent certain Platform features from working correctly. We do not currently use third-party advertising or retargeting cookies.

06How We Share Your Data

PH111 does not sell, rent, or trade your personal data. We may share your data with third parties only in the following limited circumstances:

• Payment processors: Local payment providers such as GCash and Maya, and bank transfer partners, receive the minimum data required to process your PHP transactions.
• KYC verification partners: Identity verification service providers may process your documents on our behalf under strict data processing agreements.
• IT and platform infrastructure providers: Cloud hosting, database, and security service providers who support the operation of ph111.vu and the PH111 app under contractual data protection obligations.
• Legal and regulatory authorities: Where required by applicable Philippine law, court order, or legitimate government request, we may disclose data to law enforcement or regulatory bodies.
• Business transfers: In the event of a merger, acquisition, or sale of assets, personal data may be transferred to the successor entity, with notice provided to affected Members where required by law.

All third parties who process data on our behalf are required to handle it securely, use it only for the specified purpose, and comply with applicable data protection requirements.

07Data Storage and Security

Your personal data is stored on secure servers protected by industry-standard security measures. Key protections include:

• SSL/TLS encryption for all data transmitted between your device and our servers.
• At-rest encryption for sensitive stored data including identity documents and financial records.
• Access controls that restrict internal access to personal data to authorised personnel only, on a need-to-know basis.
• OTP (One-Time Password) authentication for sensitive account actions including withdrawals and password changes.
• Regular security assessments and vulnerability monitoring of platform infrastructure.

Despite our best efforts, no system is completely immune to security threats. If you suspect that your PH111 account has been compromised, please contact our support team immediately. Members in Manila, Quezon City, Cebu, Davao, and across the Philippines can reach us through the contact details published in the Footer of this page.

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify you and relevant authorities as required by applicable law.

08How Long We Keep Your Data

We retain your personal data for as long as necessary to fulfil the purposes described in this Policy, unless a longer retention period is required or permitted by law. In practice, this means:

• Active account data is retained for the duration of your membership and for a reasonable period following account closure to allow for dispute resolution and legal compliance.
• KYC and identity documents are retained for the period required by applicable anti-money laundering and financial regulations.
• Transaction records are retained for the period required to meet financial record-keeping obligations under Philippine law.
• Support communications are retained for a period sufficient to resolve any follow-up queries and to maintain a service history.
• Analytics and technical data in anonymised or aggregated form may be retained indefinitely as it no longer identifies any individual.

When data is no longer needed, we securely delete or anonymise it in accordance with our data retention schedule.

09Your Rights Over Your Personal Data

As a PH111 member, you have the following rights with respect to your personal data. To exercise any of these rights, contact our support team using the details in the Footer:

• Right to access: You can request a copy of the personal data we hold about you.
• Right to rectification: You can ask us to correct personal data that is inaccurate or incomplete.
• Right to erasure: You can request deletion of your personal data where there is no compelling reason for us to continue processing it, subject to our legal retention obligations.
• Right to restrict processing: You can ask us to pause processing of your data in certain circumstances, such as while a rectification request is under review.
• Right to data portability: Where processing is based on your consent or contract performance and is carried out by automated means, you may request your data in a structured, commonly used format.
• Right to withdraw consent: Where we rely on consent as the legal basis for processing (such as for promotional communications), you can withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to object: You can object to processing carried out on the basis of legitimate interests, including any profiling related to that processing.

We will respond to valid requests within a reasonable timeframe. We may need to verify your identity before processing a request. In some cases, legal or regulatory obligations may limit our ability to fully comply with certain requests.

10Children and Minors

PH111 is strictly for players who are 21 years of age or older. We do not knowingly collect personal data from any person under the age of 21. Age verification is conducted at registration and reinforced through the KYC process.

If we become aware that personal data has been collected from a person under 21, we will delete that data immediately and close the associated account. If you believe that a minor may have accessed PH111 using false information, please contact our support team so we can investigate and take appropriate action.

11Marketing and Communications

If you opt in to receive promotional communications during registration or through your account settings, we may send you information about PH111 promotions, new games, sports betting updates, and platform news via email or SMS to your registered Philippine mobile number.

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

• Updating your communication preferences in your account settings.
• Contacting our support team and requesting removal from marketing lists.

Opting out of marketing communications will not affect essential service messages related to your account, transactions, security alerts, or KYC notifications, which we are required to send regardless of your marketing preferences.

12Links to Other Pages and Third-Party Services

The PH111 platform is a self-contained environment. Where the Platform integrates third-party services — such as live casino game studio feeds or payment gateways — those third parties operate under their own privacy policies. PH111 is not responsible for the data practices of third-party service providers beyond the contractual data processing obligations we place on them.

We do not embed external social media widgets, third-party advertising trackers, or external analytics platforms that collect identifiable user data independently. Any analytics tools used on PH111 are configured to collect data in an anonymised or aggregated manner.

13Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our data practices, the services we offer, or applicable legal requirements. When we make material changes, we will update the "Last updated" date at the top of this page and, where appropriate, notify active Members via their registered email address or through a notice on the Platform.

We encourage you to review this Policy periodically to stay informed about how we protect your information. Continued use of PH111 after a Policy update constitutes acceptance of the revised terms.

14How to Contact Us

If you have questions, concerns, or requests relating to this Privacy Policy or the way PH111 handles your personal data, please get in touch with our support team. Our contact details are published in the Footer of every page on ph111.vu.

For matters related to responsible gaming and self-management tools, please visit our Responsible Gaming page. For general account queries including KYC and transactions, our support team is available around the clock.

We take all privacy-related queries seriously and will acknowledge your message and provide a substantive response within a reasonable period. If your concern relates to a potential data breach or security incident, please mark your message as urgent so we can prioritise it accordingly.