p111 Privacy Policy

p111 is a PAGCOR-regulated online casino and sports betting platform operated for Filipino players and accessible at p111.lat. For the purposes of the Data Privacy Act of 2012, p111 is the Personal Information Controller (PIC) in respect of all personal data collected through the p111 platform.

As a Personal Information Controller, p111 is responsible for determining the purposes for which, and the manner in which, your personal data is processed. p111 has appointed a Data Protection Officer (DPO) to oversee compliance with this policy and the Data Privacy Act. Contact details for the DPO are set out in Section 13 of this policy.

p111 is licensed and regulated by the Philippine Amusement and Gaming Corporation (PAGCOR). Our data processing practices are subject to both PAGCOR regulatory requirements and NPC oversight.

p111 collects personal data across the following categories. The collection of each category is proportionate to the purpose it serves:

• Identity Data: Full legal name, date of birth, nationality, government-issued ID type and number (e.g., Philippine National ID, passport, SSS/GSIS ID, driver's licence), and scanned or photographed copies of those documents for KYC verification.
• Contact Data: Email address, Philippine mobile phone number, and general address information (at minimum, city and province within the Philippines, e.g., Quezon City, Cebu, Davao, Makati).
• Financial Data: Payment method identifiers (GCash-registered mobile number, PayMaya account reference, BPI, BDO, or Metrobank account details as applicable), deposit and withdrawal transaction records, and account balance history.
• Gaming Activity Data: Records of all bets, games played (slots, live dealer, bingo, sports), session times, and win/loss outcomes associated with your p111 account.
• Technical & Usage Data: IP address, device identifiers, browser type, operating system, referring URLs, pages visited on p111.lat, time and duration of visits, and authentication session tokens.
• Responsible Gaming Data: Self-exclusion elections, deposit limit settings, session time reminder preferences, and any communications with our responsible gaming support team.
• Communications Data: Records of your correspondence with p111 support via live chat or email, including timestamps and content, retained for dispute resolution and quality assurance.

p111 does not intentionally collect sensitive personal information (as defined under the Data Privacy Act) unless specifically required for identity verification or mandated by PAGCOR or Philippine AML law. We do not collect data relating to racial or ethnic origin, political opinions, religious beliefs, or health information beyond what is strictly necessary for responsible gaming compliance.

p111 collects personal data through the following channels:

• Direct provision by you: When you register a p111 account, complete your KYC verification, make a deposit or withdrawal request, contact our support team, or update your account settings.
• Automated technical collection: Through cookies, web beacons, and server logs when you access or navigate the p111.lat website. See Section 6 for full details on our cookies and tracking practices.
• Payment service providers: Transaction confirmation data received from GCash, PayMaya, BPI, BDO, and Metrobank when you initiate a deposit or withdrawal.
• Game providers: Session and outcome data received from third-party game suppliers whose certified titles are hosted on the p111 platform.
• Regulatory and screening sources: p111 may verify your identity against PAGCOR self-exclusion registries and Philippine government identity databases as part of our KYC and AML obligations.

p111 uses your personal data only for the following specified and legitimate purposes:

• Account management: Creating, maintaining, and administering your p111 player account, including authentication and access control.
• KYC and age verification: Verifying that you meet the 21+ age requirement under Philippine law and confirming your identity in compliance with PAGCOR licensing conditions.
• Transaction processing: Processing PHP deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank, and maintaining accurate financial records.
• AML and fraud prevention: Monitoring transactions and gaming patterns to detect and prevent money laundering, fraud, and other financial crimes, in compliance with Republic Act No. 9160.
• Customer support: Responding to your enquiries, resolving disputes, and providing 24/7 live chat and email support in English.
• Responsible gaming: Monitoring your gaming activity to support responsible gaming tools, including deposit limits and self-exclusion, and fulfilling our obligations under PAGCOR's responsible gaming framework.
• Platform improvement: Analysing aggregated and anonymised usage data to improve the p111 platform, game selection, and user experience.
• Marketing (with consent): Sending you promotional offers, bonus notifications, and product updates where you have opted in. See Section 11 for how to manage your marketing preferences.
• Legal and regulatory compliance: Meeting our obligations to PAGCOR, the NPC, the Anti-Money Laundering Council (AMLC), and other Philippine government bodies.

p111 does not use your personal data for automated decision-making that produces significant legal effects on you without human oversight, except where required for fraud prevention or AML compliance and subject to your right to request human review.

p111 does not sell, rent, or trade your personal data. We share your data only in the following limited circumstances:

• Service providers (processors): p111 engages third-party service providers — including KYC verification services, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), game platform providers, IT infrastructure suppliers, and customer support tools — who process personal data solely on p111's instructions under strict data processing agreements that require them to maintain confidentiality and security standards consistent with this policy.
• Regulatory authorities: p111 is obligated to share data with PAGCOR, the AMLC, the NPC, and other Philippine government authorities when required by law, court order, or regulatory directive.
• Self-exclusion registries: p111 shares self- exclusion status with PAGCOR's centralised self-exclusion registry to prevent excluded players from accessing other licensed platforms.
• Business transfers: In the event of a merger, acquisition, or transfer of p111's business or assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this policy. You will be notified of any such change.
• Legal proceedings: p111 may disclose personal data where necessary to establish, exercise, or defend legal claims in any Philippine court or arbitration proceeding.

p111 uses cookies and similar tracking technologies on the p111.lat website. Cookies are small text files stored on your device that help us deliver a functional, secure, and personalised experience.

The following types of cookies are used on p111.lat:

• Strictly necessary cookies: Essential for the operation of the p111 platform. These include authentication session cookies, security tokens, and load-balancing cookies. These cannot be disabled without breaking core platform functionality.
• Functional cookies: Remember your preferences such as language selection, last-visited game category, and responsible gaming settings so you do not have to re-enter them each session.
• Analytical cookies: Collect anonymised data about how visitors use p111.lat — which pages are visited most, where users navigate from, and what device types are used — to help p111 improve the platform experience.
• Security cookies: Used to detect and prevent fraudulent logins, bot activity, and other security threats, including device fingerprinting for session integrity.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies may affect certain features but will not prevent you from accessing your p111 account. p111 does not use third-party advertising cookies or cross-site tracking technologies for the purpose of behavioural advertising.

p111 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. Key security measures in place include:

• Encryption: All personal data stored by p111 is encrypted at rest using AES-256. All data transmitted between your device and p111 servers uses TLS 1.2 or higher.
• Access controls: Access to personal data is restricted on a strict need-to-know basis. p111 staff with access to personal data undergo regular security training and are bound by confidentiality obligations.
• Two-factor authentication: p111 supports and encourages the use of two-factor authentication (2FA) on all player accounts to reduce unauthorised access risk.
• Regular security audits: p111 conducts periodic vulnerability assessments and penetration testing of the platform infrastructure to identify and remediate security weaknesses.
• Incident response: p111 maintains a formal data breach response plan. In the event of a security incident affecting personal data, the DPO will oversee notification to affected players and the NPC as required by the Data Privacy Act.

p111 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The key retention periods are as follows:

• Identity and KYC data is retained for a minimum of five (5) years from the date of account closure, in compliance with PAGCOR licensing conditions and AML record-keeping requirements.
• Financial transaction records are retained for seven (7) years from the date of the transaction, as required by Republic Act No. 9160 (Anti-Money Laundering Act) and its amendments.
• Gaming activity records are retained for five (5) years from the date of the last activity for dispute resolution and regulatory audit purposes.
• Technical and usage data is retained on a rolling 12-month basis, after which it is anonymised or securely deleted.
• Self-exclusion records are retained permanently to prevent circumvention of responsible gaming protections and to comply with PAGCOR's self-exclusion registry obligations.
• Support communications are retained for three (3) years for quality assurance and dispute resolution, after which they are securely deleted.

At the end of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Retention periods may be extended where data is the subject of an active legal proceeding or regulatory investigation.

As a data subject under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by p111:

• Right to be informed: You have the right to be told how your personal data is being collected and used — which is the purpose of this Privacy Policy.
• Right to access: You may request a copy of the personal data p111 holds about you. p111 will respond to access requests within a reasonable time and in a portable, commonly used format where technically feasible.
• Right to correction: You may request that inaccurate or incomplete personal data be corrected or updated. You can update most account details directly in your p111 account settings. Changes to KYC identity data require re-verification.
• Right to erasure: You may request that p111 delete your personal data where it is no longer necessary for the purposes for which it was collected, or where you have withdrawn consent and there is no other legal basis for processing. Note that erasure requests may be declined where retention is required by law (e.g., AML and PAGCOR record-keeping obligations).
• Right to object: You may object to processing of your personal data for direct marketing purposes at any time. You may also object to other processing based on legitimate interest grounds, subject to p111's overriding legal obligations.
• Right to data portability: Where technically feasible and where processing is based on your consent or on a contract with you, you may request that p111 transmit your personal data to another service provider in a structured, commonly used, machine-readable format.
• Right to lodge a complaint: If you believe that p111 has processed your personal data in breach of the Data Privacy Act, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 13. p111 will respond to all valid data subject requests within thirty (30) calendar days of receipt, or within such other period as required by applicable law.

p111 is strictly an adults-only platform. Under Philippine law and PAGCOR regulations, participation in online casino and sports betting activities is limited to individuals who are 21 years of age or older. p111 does not knowingly collect personal data from individuals under the age of 21.

All new p111 accounts are subject to mandatory age verification as part of the KYC process. Where p111 has reasonable grounds to believe that a registered account belongs to a person under 21 years of age, the account will be suspended pending identity verification, and any funds will be handled in accordance with applicable regulatory guidance.

If you are a parent or guardian and you believe that your child has registered a p111 account, please contact our support team immediately. p111 will take prompt action to investigate and, where confirmed, close the account and arrange the return of any deposited funds in accordance with applicable law.

p111 will only send you promotional and marketing communications — including bonus offers, game announcements, and platform news — where you have given your explicit consent to receive them at the time of account registration or through your account settings.

You may withdraw your consent to marketing communications at any time by:

• Updating your communication preferences in your p111 account settings under "Notifications & Marketing";
• Clicking the "unsubscribe" link included in any marketing email sent by p111; or
• Contacting our support team via live chat or by emailing our DPO at the address in Section 13.

Withdrawing marketing consent will not affect the lawfulness of any processing carried out prior to the withdrawal. You will continue to receive essential transactional communications (e.g., deposit confirmations, withdrawal notifications, security alerts, and responsible gaming messages) regardless of your marketing preferences, as these are necessary for the operation of your account.

p111 may update this Privacy Policy from time to time to reflect changes in our data practices, applicable Philippine law, or PAGCOR regulatory requirements. When we make material changes to this policy, we will:

• Post the updated Privacy Policy on p111.lat/privacy-policy with a revised effective date prominently displayed at the top of the page;
• Notify registered p111 players of material changes via email or in-platform notification at least fourteen (14) days before the changes take effect, where practicable; and
• Where required by the Data Privacy Act, obtain fresh consent from players where changes involve new processing purposes that require consent as a legal basis.

Your continued use of the p111 platform after the effective date of any updated Privacy Policy constitutes your acknowledgement of the changes. We encourage you to review this page periodically so you are always aware of how p111 handles your personal data.

If you have any questions, concerns, or requests relating to this Privacy Policy or p111's data processing practices, you may contact our Data Protection Officer (DPO) or our general support team through the following channels:

• Email (plain text — not a link): [email protected]
• Live Chat: Available 24/7 via the p111.lat platform, Philippine Standard Time (PST, UTC+8).

For formal data subject rights requests (access, correction, erasure, portability, objection), please clearly state "Data Subject Rights Request" in your message subject line so our DPO can prioritise your request appropriately.

If you are not satisfied with p111's response to a privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines, the independent supervisory authority responsible for enforcing the Data Privacy Act of 2012.