111taya Privacy Policy – How We Protect Your Personal Data

Intro Introduction and Scope

This Privacy Policy ("Policy") is issued by 111taya ("111taya," "we," "us," or "our"), the operator of the online gaming platform accessible at 111taya.app. This Policy describes how 111taya collects, uses, stores, shares, and protects personal data relating to registered players, website visitors, and any other individuals who interact with the 111taya platform ("you" or "Data Subject").

111taya is committed to full compliance with the Data Privacy Act of 2012 (Republic Act No. 10173) of the Philippines, its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC). Where applicable, 111taya also observes internationally recognised data protection principles consistent with those of the NPC.

This Policy applies to all personal data processed by 111taya in connection with your use of the 111taya website, mobile interface, games, payment services, customer support channels, and any promotional or marketing communications. It does not apply to third-party websites or services that may be linked from the 111taya platform — those third parties operate under their own privacy policies.

By registering an account or otherwise using the 111taya 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. If you do not agree with this Policy, please discontinue use of the 111taya platform and contact us to close your account.

1 Data Controller and Data Protection Officer

111taya acts as the Personal Information Controller (PIC) in respect of the personal data it collects and processes in connection with the 111taya platform, as defined under the Data Privacy Act of 2012.

111taya has designated a Data Protection Officer (DPO) responsible for overseeing compliance with this Policy and applicable data protection laws. If you have any questions, concerns, or requests relating to your personal data or this Policy, you may contact the 111taya DPO at:

111taya's privacy practices and this Policy are registered with and subject to the oversight of the National Privacy Commission of the Philippines.

2 Personal Data We Collect

111taya collects personal data that is necessary, adequate, and not excessive in relation to the purposes for which it is collected. The categories of personal data we collect include:

2.1 Data You Provide Directly

• Identity Data: Full legal name, date of birth, gender, nationality, and government-issued identification details (e.g., Philippine National ID, passport, driver's licence) provided during account registration and identity verification.
• Contact Data: Email address, Philippine mobile number, and residential address.
• Account Credentials: Username and encrypted password. We do not store your password in plain text.
• Financial Data: GCash account details, PayMaya / Maya account details, bank account information (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank), and debit card details necessary to process deposits and withdrawals. Full payment credentials are handled by our regulated payment processors and are not stored on 111taya servers.
• Communications Data: Records of your correspondence with 111taya support, including chat logs, emails, and support ticket content.
• Responsible Gaming Data: Self-exclusion requests, deposit limit settings, and session time preferences you configure on the platform.

2.2 Data Collected Automatically

• Technical Data: IP address, device type, operating system, browser type and version, screen resolution, and device identifiers.
• Usage Data: Pages visited, games played, session duration, click patterns, and navigation paths within the 111taya platform.
• Transaction Data: Records of all deposits, withdrawals, wagers, game results, bonus claims, and account balance changes.
• Location Data: General geographic location derived from your IP address, used to verify that you are accessing the platform from a permitted jurisdiction.
• Cookie and Tracking Data: Information collected via cookies, web beacons, and similar technologies as described in Section 8 of this Policy.

2.3 Data from Third Parties

• Identity verification data from KYC (Know Your Customer) service providers engaged by 111taya to verify your identity and age.
• Fraud detection and anti-money laundering (AML) screening data from compliance service providers.
• Payment confirmation data from GCash, PayMaya / Maya, and banking partners.

3 How We Use Your Personal Data

111taya processes your personal data only for specific, legitimate purposes and only to the extent necessary for those purposes. The table below summarises our primary processing activities:

111taya will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a separate lawful basis for processing.

4 Sharing and Disclosure of Personal Data

111taya does not sell, rent, or trade your personal data to any third party for commercial purposes. We may share your personal data only in the following limited circumstances:

• Payment Processors: GCash, PayMaya / Maya, and our banking partners receive the financial data necessary to process your transactions. These providers are bound by their own data protection obligations and applicable Philippine financial regulations.
• Identity Verification Providers: Third-party KYC and AML service providers engaged by 111taya to verify your identity and screen for financial crime risk. These providers process your data under strict contractual data processing agreements.
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government authorities, where disclosure is required by law, court order, or regulatory directive.
• IT and Infrastructure Providers: Cloud hosting, database, and cybersecurity service providers who process data on 111taya's behalf under data processing agreements that require them to maintain confidentiality and security standards equivalent to those of 111taya.
• Professional Advisers: Lawyers, auditors, and accountants who require access to personal data in the course of providing professional services to 111taya, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of 111taya's business, your personal data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third parties with whom 111taya shares personal data are required to handle that data in accordance with applicable Philippine data protection law and 111taya's data protection standards.

5 Data Retention

111taya retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and regulatory obligations. Our general retention periods are as follows:

• Account and Identity Data: Retained for the duration of your account and for a minimum of five (5) years following account closure, in accordance with PAGCOR and AMLC record-keeping requirements.
• Transaction Data: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine anti-money laundering regulations.
• Communications Data: Support correspondence retained for three (3) years from the date of the last interaction.
• Marketing Data: Retained until you withdraw your consent to receive marketing communications, after which it will be deleted or anonymised within 30 days.
• Technical and Usage Data: Retained for up to two (2) years for security, fraud prevention, and platform improvement purposes.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymised so that it can no longer be associated with you as an individual.

6 Your Data Privacy Rights

Under the Data Privacy Act of 2012 and its Implementing Rules and Regulations , you have the following rights in relation to your personal data held by 111taya:

• Right to be Informed: You have the right to be informed of how your personal data is collected, used, and processed — which is the primary purpose of this Privacy Policy.
• Right of Access: You may request a copy of the personal data 111taya holds about you, along with information about how it is being processed.
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you. You may also update certain information directly through your account settings.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 111taya's legal and regulatory retention obligations.
• Right to Object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to 111taya's overriding legitimate grounds.
• Right to Data Portability: You may request that 111taya provide your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to Lodge a Complaint: If you believe 111taya has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission of the Philippines.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected]. We will respond to all verified requests within 15 business days. We may require you to verify your identity before processing your request.

7 Cookies and Tracking Technologies

111taya uses cookies and similar tracking technologies to operate and improve the platform, personalise your experience, and analyse usage patterns. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the platform to function. These include session authentication cookies and security tokens. They cannot be disabled without affecting platform functionality.
• Functional Cookies: Remember your preferences such as language settings, display options, and responsible gaming configurations.
• Analytics Cookies: Collect anonymised data about how players use the 111taya platform, helping us identify areas for improvement. Data collected is aggregated and does not identify individual users.
• Marketing Cookies: Used only with your consent to deliver relevant promotional content about 111taya games and offers. You may withdraw consent at any time.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the 111taya platform. A full cookie preference centre is accessible from the footer of the 111taya platform.

8 Data Security

111taya implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and 111taya servers.
• Encryption of sensitive data at rest, including financial information 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 accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 111taya will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected individuals without undue delay, as required by the Data Privacy Act of 2012.

While 111taya takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for keeping your account credentials confidential and for notifying 111taya immediately if you suspect unauthorised access to your account.

9 Minors and Age Restriction

The 111taya platform is strictly for individuals aged 21 years and above, in accordance with PAGCOR regulations and Philippine law. 111taya does not knowingly collect personal data from individuals under the age of 21.

If 111taya becomes aware that personal data has been collected from a person under 21 years of age, that account will be immediately suspended, the data will be deleted, and the matter will be reported to the relevant authorities. If you believe a minor has registered on the 111taya platform, please contact us immediately at [email protected].

10 Changes to This Privacy Policy

111taya may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes, we will notify registered players via email or in-platform notification at least 14 days before the changes take effect.

The effective date at the top of this Policy indicates when it was last updated. We encourage you to review this Policy periodically. Continued use of the 111taya platform after the effective date of any updated Policy constitutes your acceptance of the changes.

Previous versions of this Privacy Policy are available upon request by contacting our Data Protection Officer.

11 Contact and Complaints

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

If you are not satisfied with 111taya's response to your privacy concern, you have the right to escalate your complaint to the National Privacy Commission of the Philippines through the NPC's official complaint channels.