Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by 111bestph ("we," "us," or "our") and applies to all personal data collected through the 111bestph website at 111bestph.org, including all games, features, and services offered therein (collectively, the "Platform").

111bestph is committed to protecting the privacy and security of all players who use our Platform. This Policy explains in plain language what personal data we collect, the purposes for which we use it, with whom we share it, and the rights available to you under applicable Philippine law.

By registering an account on 111bestph or by continuing to use the Platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. This Policy should be read together with our Terms & Conditions.

2. Personal Data We Collect

111bestph collects the following categories of personal data from players:

We collect only the personal data that is necessary for the purposes described in this Policy. We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where required by law (for example, in connection with responsible gaming self-exclusion requests).

3. How We Collect Your Data

111bestph collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the Platform, including through cookies, server logs, and similar tracking technologies.
• Third-party sources: Identity and fraud-check data received from payment processors (GCash, PayMaya, BPI, BDO, Metrobank), identity verification providers, and fraud prevention services.
• Regulatory sources: Data received from PAGCOR or other regulatory authorities in connection with licensing, compliance, or self-exclusion register checks.

4. How We Use Your Personal Data

111bestph uses your personal data for the following purposes:

• Account management: To create, maintain, and administer your 111bestph player account, including processing your 111bestph Login and verifying your identity.
• Transaction processing: To process deposits and withdrawals via GCash, PayMaya, and Philippine bank transfers, and to maintain accurate financial records.
• Legal and regulatory compliance: To comply with anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, PAGCOR licensing conditions, and other applicable Philippine laws and regulations.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct on the Platform.
• Responsible gaming: To monitor gaming behaviour, enforce deposit limits and self-exclusion requests, and identify players who may be at risk of problem gambling.
• Customer support: To respond to your enquiries, resolve disputes, and provide technical assistance.
• Platform improvement: To analyse usage patterns, conduct A/B testing, and improve the performance, security, and user experience of the 111bestph Platform.
• Marketing communications: To send you promotional offers, bonus notifications, and platform updates, where you have consented to receive such communications. You may opt out at any time.

111bestph will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your consent or as otherwise permitted by applicable law.

5. Sharing Your Personal Data

111bestph does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, to the extent necessary to process your financial transactions.
• Identity verification providers: Third-party KYC and AML service providers engaged to verify your identity and screen against sanctions and fraud databases.
• Technology service providers: Cloud hosting, data analytics, customer support software, and cybersecurity vendors who process data on our behalf under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where required by law or court order.
• Game providers: Third-party game studios and live dealer operators whose games are available on the 111bestph Platform, to the extent necessary to operate those games and resolve disputes.

All third parties with whom 111bestph shares personal data are required to maintain appropriate technical and organisational security measures and to process your data only in accordance with our instructions and applicable law.

6. Data Retention

111bestph retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in accordance with AML and KYC regulatory requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Technical and usage logs are retained for twelve (12) months from the date of collection, unless a longer retention period is required for security or legal purposes.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with our data disposal procedures.

7. Data Security

111bestph implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 111bestph Platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments.
• Multi-factor authentication for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 111bestph will notify the National Privacy Commission (NPC) and affected players in accordance with the requirements of the Philippine Data Privacy Act of 2012 (Republic Act No. 10173).

8. Cookies and Tracking Technologies

111bestph uses cookies and similar tracking technologies to operate and improve the Platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for the Platform to function. These include session cookies that maintain your logged-in state and security cookies that protect against cross-site request forgery . These cookies cannot be disabled.
• Functional cookies: Used to remember your preferences, such as your preferred language and display settings, so you do not need to re-enter them each time you visit.
• Analytics cookies: Used to collect anonymised information about how players use the Platform, including which pages are visited most frequently and how players navigate between pages. This data helps us improve the Platform's performance and usability.
• Security cookies: Used to detect and prevent fraudulent activity, including bot traffic and account takeover attempts.

111bestph does not use third-party advertising or behavioural tracking cookies. You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform.

9. Your Data Rights

As a data subject under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), you have the following rights with respect to your personal data held by 111bestph:

• Right to be informed: You have the right to be informed about how your personal data is collected, used, and shared, as set out in this Policy.
• Right of access: You have the right to request a copy of the personal data that 111bestph holds about you, along with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data held about you. You may update certain account details directly through your 111bestph account settings.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal and regulatory retention obligations.
• Right to object: You have the right to object to the processing of your personal data for direct marketing purposes at any time. You may also object to other forms of processing where we rely on legitimate interests as our legal basis.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, commonly used, and machine-readable format, and to request that it be transmitted to another data controller where technically feasible.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that 111bestph has processed your personal data in violation of applicable law.

To exercise any of the above rights, please contact the 111bestph Data Privacy Officer using the contact details provided in Section 13 of this Policy. We will respond to all verified requests within thirty (30) days of receipt, or within such other timeframe as required by applicable law.

Please note that certain rights are subject to limitations. For example, we may be unable to delete personal data that we are required to retain for regulatory or legal compliance purposes.

10. Minors and Age Restriction

The 111bestph Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law governing casino-style online gaming. 111bestph does not knowingly collect personal data from persons under the age of 21.

If you are a parent or guardian and believe that a minor has registered an account on 111bestph or provided us with personal data without your consent, please contact us immediately using the details in Section 13. We will promptly investigate and, where confirmed, close the account and delete all associated personal data.

111bestph employs age verification procedures during the registration process and reserves the right to request documentary proof of age at any time. Accounts where age eligibility cannot be confirmed will be suspended pending verification.

11. International Data Transfers

111bestph primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to and processed in countries outside the Philippines — for example, where we use cloud infrastructure or technology service providers with servers located abroad.

Where such transfers occur, 111bestph ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to maintain data protection standards equivalent to those required under Philippine law. By using the 111bestph Platform, you consent to such transfers where they are necessary for the provision of our services.

12. Changes to This Privacy Policy

111bestph reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players by email or through a prominent notice on the Platform at least seven (7) days before the changes take effect, where practicable.

The date of the most recent revision to this Policy is displayed at the top of this page. We encourage you to review this Policy periodically to stay informed about how 111bestph protects your personal data. Your continued use of the Platform following the effective date of any revised Policy constitutes your acceptance of the changes.

13. Contact Our Data Privacy Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 111bestph, please contact our Data Privacy Officer:

111bestph Data Privacy Officer
Email: [email protected]
General Support: [email protected]

We aim to respond to all privacy-related enquiries within fifteen (15) business days. For complex requests, we may require up to thirty (30) days and will notify you if an extension is necessary.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines (NPC) at privacy.gov.ph.