ji111 Privacy Policy

This Privacy Policy applies to all personal data processed by ji111 in connection with the provision of its online gaming Services at https://ji111.org, including the ji111 website, account registration and management system, game lobby, payment processing, customer support channels, and all promotional communications.

This Policy applies to all individuals who interact with ji111, including registered Players, individuals who have applied to register an account but have not completed the process, and any person who contacts ji111's customer support team regardless of account status.

Ji111 is the personal information controller for the purposes of Republic Act No. 10173, the Philippine Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR). By accessing the ji111 platform or providing personal data to us in any form, you acknowledge that you have read and understood this Privacy Policy.

Ji111 collects personal data that is necessary to provide you with the Services, comply with our regulatory obligations, and maintain the security of the platform. The categories of data we collect are described below.

Ji111 does not collect sensitive personal data (as defined under the DPA) unless specifically required for compliance purposes, in which case additional consent will be sought. Ji111 does not collect biometric data beyond optional device-level fingerprint or Face ID authentication, which is processed locally on your device and not transmitted to ji111 servers.

Ji111 collects personal data through the following means:

Data you provide to us directly when you register a ji111 account, complete KYC verification, submit a deposit or withdrawal request, contact support via live chat or email, or update your account profile settings.

Technical data collected automatically when you access the ji111 platform, including your IP address, browser information, device identifiers, and interaction logs. This data is collected via server logs and first-party cookies. See Section 7 (Cookies and Tracking Technologies) for full details.

Ji111 may receive personal data about you from the following third-party sources in limited, specific circumstances:

• Payment providers (e.g., GCash, Maya) — transaction confirmation references and masked payment account identifiers for deposit and withdrawal reconciliation;
• Identity verification services — results of automated document authenticity checks conducted during KYC, where such services are engaged;
• Fraud and AML screening services — watchlist screening results required under Philippine anti-money laundering obligations;
• Government databases — where required by law to verify identity or confirm regulatory compliance status.

Ji111 does not purchase personal data from commercial data brokers or social media platforms.

Ji111 processes your personal data for the following specific, explicit, and legitimate purposes:

• Account management — creating, verifying, maintaining, and securing your ji111 account;
• Service delivery — providing access to games, processing bets, crediting wins, and operating the game lobby;
• Payment processing — facilitating deposits and withdrawals via GCash, Maya, and other approved methods;
• KYC and age verification — verifying your identity and confirming you are at least 21 years of age as required under PAGCOR regulations;
• Legal and regulatory compliance — fulfilling obligations under the Philippine Data Privacy Act, PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA), and related laws;
• Fraud prevention and security — detecting and preventing unauthorized account access, fraudulent transactions, and abuse of promotions;
• Responsible gaming — monitoring gaming patterns to identify potential problem gambling behavior and applying responsible gaming tools where appropriate;
• Customer support — responding to your inquiries, resolving disputes, and improving support quality;
• Platform improvement — analyzing aggregated, anonymized usage data to improve platform performance, user experience, and game library curation;
• Marketing communications — sending you promotional offers and updates about ji111 via your registered email or mobile number, subject to your communication preferences and the right to opt out.

Ji111 processes your personal data on the following legal grounds as established under the Philippine Data Privacy Act of 2012:

• Contractual necessity — processing required to perform our obligations under the ji111 Terms and Conditions, including account creation, game access, and payment processing;
• Compliance with a legal obligation — processing required to comply with applicable Philippine laws, including PAGCOR regulations, the AMLA, and the DPA itself;
• Legitimate interests — processing necessary for ji111's legitimate interests in fraud prevention, platform security, responsible gaming enforcement, and service improvement, where such interests are not overridden by your rights;
• Consent — for processing activities that are not covered by the above grounds, such as certain marketing communications or optional profile features, where we rely on your freely given, informed, and specific consent. You have the right to withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

Ji111 does not sell your personal data. We share your data only in the limited circumstances described below, and only to the extent necessary for the stated purpose.

Ji111 engages trusted third-party service providers who process personal data on our behalf as personal information processors under strict contractual obligations aligned with the DPA. These include:

• Payment gateway providers (GCash, Maya, and other approved channels) — for deposit and withdrawal processing;
• Identity verification and KYC technology providers;
• Cloud hosting and infrastructure providers;
• Game software providers — who may receive anonymized session identifiers for game integrity purposes;
• Customer support technology platforms.

Ji111 will disclose personal data to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities where required by law, court order, or lawful regulatory direction. Ji111 will endeavor to notify you of such disclosure where legally permissible and practicable.

In the event of a merger, acquisition, restructuring, or sale of ji111's business or assets, your personal data may be transferred to the acquiring entity as part of that transaction, subject to the same privacy protections described in this Policy. You will be notified of any such transfer that materially affects your rights.

Ji111 does not share your personal data with any third party for their own direct marketing or advertising purposes. This prohibition is unconditional and applies regardless of any commercial arrangement.

Ji111 uses cookies and similar tracking technologies on the platform for the following purposes:

Ji111 does not use third-party advertising cookies or behavioral tracking cookies that build advertising profiles. Essential and security cookies cannot be disabled as they are technically required for the platform to function. Analytics and preference cookies may be disabled via your browser settings; however, disabling certain cookies may affect the performance or functionality of the ji111 platform.

Ji111 implements technical and organizational security measures appropriate to the risk level of the personal data we process. These measures include:

• Encryption in transit — all data transmitted between your device and ji111 servers is protected by TLS 1.2+ (256-bit SSL);
• Encryption at rest — sensitive personal data fields (including KYC document references and financial identifiers) are stored in encrypted form in our databases;
• Access controls — access to personal data within ji111's internal systems is restricted to authorized personnel on a need-to-know basis, with role-based access controls and audit logging;
• Two-factor authentication — SMS OTP verification is required for account logins from new devices and for withdrawal requests;
• Penetration testing and security audits — ji111 conducts periodic security assessments of its platform infrastructure;
• Staff training — personnel with access to personal data receive regular training on data privacy obligations and security practices.

While ji111 takes all reasonable precautions to protect your data, no internet transmission or electronic storage system is completely secure. You are advised to maintain the security of your own account credentials and to report any suspected unauthorized access to [email protected] immediately.

Ji111 retains personal data for the periods set out below, after which data is securely deleted, anonymized, or disposed of in accordance with our data retention and disposal procedures.

Where ji111 is required to retain data beyond the periods above due to an active legal dispute, regulatory investigation, or court order, data will be retained until resolution of that matter.

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ji111. These rights may be exercised by contacting our Data Protection Officer as described in Section 14.

Ji111 will respond to all data subject rights requests within fifteen (15) business days of receipt, in accordance with NPC requirements. We may request identity verification before fulfilling any rights request to protect against fraudulent requests. Some rights requests may be declined where a legal exemption applies, in which case we will explain the basis for the refusal.

If ji111 becomes aware that personal data has been collected from a person under 21 years of age without appropriate parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you are a parent or guardian and believe your child has provided personal data to ji111, please contact our Data Protection Officer immediately at [email protected].

Age verification through KYC documentation is a mandatory step before ji111 processes any withdrawal from a Player's account. This requirement exists to enforce the 21+ age restriction in compliance with PAGCOR regulations and Philippine law.

Ji111 primarily processes and stores personal data within the Philippines. However, certain service providers engaged by ji111 — including cloud infrastructure providers and game software companies — may be located or operate servers outside the Philippines, which may result in your personal data being transferred to and processed in other jurisdictions.

Where such cross-border transfers occur, ji111 ensures that appropriate safeguards are in place to protect your personal data in accordance with the standards required by the Philippine Data Privacy Act. These safeguards include:

• Contractual data processing agreements with receiving parties that impose DPA-equivalent privacy obligations;
• Transfers only to countries or entities that the NPC has determined to provide an adequate level of protection;
• Binding corporate rules or standard contractual clauses where applicable.

You may contact our Data Protection Officer to request information about specific cross-border transfer arrangements that apply to your personal data.

Ji111 reserves the right to update, revise, or replace this Privacy Policy at any time to reflect changes in our data processing practices, applicable laws, or regulatory requirements. The effective date at the top of this Policy reflects the date of the most recent revision.

Material changes to this Privacy Policy — those that significantly affect your rights or how your data is processed — will be communicated to registered Players by email to their registered address and/or by a prominent notice displayed on the ji111 platform at the next login following the change.

Your continued use of the ji111 platform following the effective date of a revised Privacy Policy constitutes your acknowledgment of the updated terms. If you do not agree with any change to this Policy, you have the right to request account closure and deletion of your personal data, subject to applicable legal retention requirements.

Ji111 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. You may contact the ji111 DPO to:

• Exercise any of your data subject rights as described in Section 10;
• Submit a privacy-related complaint or concern;
• Request information about how your personal data is processed;
• Report a suspected personal data breach involving your ji111 account;
• Withdraw consent for any specific processing activity;
• Request account closure and data deletion.

Contact channels:

• Email (DPO): [email protected] — subject line: "Privacy / DPO Request"
• Live Chat: Available 24/7 on the ji111 platform — average response under 5 minutes
• Messenger & Viber: Check the official ji111 platform for verified account details

All privacy-related requests will receive a substantive response within fifteen (15) business days of verified receipt. Identity verification may be required before processing any request relating to specific personal data.

If you are not satisfied with ji111's response to your privacy concern, you have the right to file a complaint with the National Privacy Commission of the Philippines (NPC). Information about the NPC complaint process is available through the NPC's official government channels.