Privacy Policy

1 Who We Are

5111jl is an online casino and sportsbook platform operating at 5111jl.net, regulated by the Philippine Amusement and Gaming Corporation (PAGCOR) and serving Filipino players across the Philippines — from Manila, Cebu, and Davao to Iloilo, Cagayan de Oro, and beyond.

For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and its implementing rules and regulations, 5111jl acts as the Personal Information Controller (PIC) in respect of all personal data collected from players and platform visitors. Our designated Data Protection Officer (DPO) can be contacted at the details provided in Section 15 of this policy.

We are registered with the National Privacy Commission (NPC) of the Philippines as required under RA 10173, and all our data processing activities are conducted in accordance with the general privacy principles of transparency, legitimate purpose, and proportionality.

2 Personal Data We Collect

5111jl collects the following categories of personal data, depending on the nature of your interaction with the platform:

2.1 Registration & Account Data

• Full legal name as it appears on your government-issued Philippine ID
• Date of birth (to verify you are 21 years of age or older, as required by PAGCOR)
• Email address and Philippine mobile number
• Residential address within the Philippines
• Username and encrypted account password

2.2 Identity Verification (KYC) Data

• Scanned or photographed copies of government-issued Philippine photo ID (e.g., PhilSys National ID, passport, driver's license, Voter's ID, SSS/GSIS/Pag-IBIG ID)
• Selfie photographs taken for liveness verification purposes
• Proof of address documents (e.g., utility bill or bank statement dated within 90 days)
• Source of funds documentation where required by anti-money laundering rules

2.3 Financial & Transaction Data

• GCash or Maya mobile wallet account reference numbers
• Philippine bank account details (BPI, BDO, Metrobank) used for deposit or withdrawal
• Deposit and withdrawal transaction history, including amounts in Philippine Peso (PHP) and timestamps
• Bonus and promotional credit history

2.4 Gaming & Behavioural Data

• Game play history, including games played, bet amounts, wins and losses
• Session duration, login timestamps, and in-game activity logs
• Sports betting selections, live betting activity, and bet settlement records
• Responsible gaming settings, deposit limit preferences, and self-exclusion records

2.5 Technical & Device Data

• IP address and geolocation data (to verify Philippines-based access)
• Device type, operating system, and browser information
• Cookie identifiers and session tokens (see Section 7)
• Platform interaction logs for fraud detection and security monitoring purposes

2.6 Communications Data

• Customer support chat transcripts and email correspondence
• Survey responses and feedback submissions
• Marketing communication preferences and opt-in/opt-out records

3 How We Collect Your Data

5111jl collects personal data through the following channels and methods:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal request, contact our support team, or participate in a promotion.
• Automatically via the platform — through cookies, session tokens, and analytics tools that record your browsing behaviour, device information, and gaming activity when you use 5111jl.net.
• From payment processors — GCash, Maya, GrabPay, and Philippine bank partners may share transaction confirmation data with 5111jl to verify successful deposits and withdrawals.
• From KYC and identity verification providers — where 5111jl uses a licensed third-party KYC service to verify identity documents and perform liveness checks.
• From fraud prevention and AML compliance tools — third-party screening services may provide risk scores or sanction-list check results to support our anti-money laundering obligations under RA 9160.

4 Why We Use Your Personal Data

5111jl processes personal data only for specific, legitimate purposes. The table below outlines the primary purposes for which your data is used:

5 Legal Basis for Processing

Under the Data Privacy Act of 2012 (RA 10173), 5111jl processes your personal data on the following legal grounds:

• Contractual necessity — processing required to perform our obligations to you under the Terms & Conditions, including account creation, game access, and payment processing.
• Legal obligation — processing required to comply with PAGCOR regulations, the Anti-Money Laundering Act (RA 9160), RA 10173 itself, and any other applicable Philippine law.
• Legitimate interest — processing for fraud prevention, platform security, responsible gaming monitoring, and general platform analytics, where these interests are not overridden by your privacy rights.
• Your consent — processing for direct marketing communications, non-essential cookies, and any other purpose for which we explicitly request and you explicitly grant consent. You may withdraw consent at any time.

6 Data Sharing & Disclosure

5111jl does not sell, rent, or trade your personal data. We share personal data with third parties only where necessary and on a strictly limited basis, as described below:

6.1 Service Providers (Personal Information Processors)

5111jl engages carefully selected third-party service providers who process personal data on our behalf, under contractual obligations consistent with RA 10173. These include:

• Payment processors — GCash (Mynt), Maya Philippines, GrabPay Philippines, BPI, BDO, and Metrobank for deposit and withdrawal processing.
• KYC and identity verification providers — licensed third-party services for document verification and liveness detection.
• Game content providers — licensed casino game studios whose software is integrated into the 5111jl platform may receive anonymized session identifiers for game integrity purposes.
• Cloud infrastructure and hosting providers — data centre and cloud services providers that host 5111jl's platform infrastructure under strict data processing agreements.
• Customer support platform providers — helpdesk software services that process support ticket data on our behalf.
• Fraud and AML screening services — compliance technology providers that assist with sanctions screening and risk scoring under our PAGCOR-mandated AML programme.

6.2 Regulatory Authorities

5111jl is required by law to share certain player data with Philippine regulatory and law enforcement bodies, including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Bureau of Investigation (NBI), and other competent government agencies, where lawfully directed to do so.

6.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 5111jl's business, personal data held by 5111jl may be transferred to the acquiring entity as part of that transaction. Affected players will be notified as required by RA 10173 in such an event.

7 Cookies & Tracking Technologies

5111jl uses cookies and similar tracking technologies on the 5111jl.net website and player platform. Cookies are small text files placed on your device that help us deliver a functional and personalised experience.

7.1 Types of Cookies We Use

• Strictly necessary cookies — essential for platform functionality including maintaining your login session, remembering your language preference, and enabling secure page navigation. These cannot be disabled without affecting platform performance.
• Functional cookies — remember your preferences such as deposit limits you have set, responsible gaming settings, and display preferences to personalise your experience.
• Analytics cookies — collect aggregated, anonymised data about how players interact with the platform, which pages are visited most, and where technical issues occur. Used to improve platform performance.
• Security cookies — used for fraud detection, session integrity verification, and identification of suspicious login patterns to protect your account.

7.2 Managing Your Cookie Preferences

You can manage non-essential cookie preferences through your browser settings at any time. Please note that disabling strictly necessary cookies may impair your ability to use certain features of the 5111jl platform, including account login and payment processing. For detailed guidance on browser cookie management, refer to your browser's help documentation.

8 Data Retention

5111jl retains personal data only for as long as necessary to fulfil the purposes outlined in this policy, or as required by applicable Philippine law. The following retention guidelines apply:

• Active account data — retained for the duration of your account's active status plus a period of five (5) years following account closure, in line with PAGCOR record-keeping requirements.
• KYC and identity documents — retained for a minimum of five (5) years following account closure or the last transaction date, as required under RA 9160 (Anti-Money Laundering Act).
• Transaction records — retained for a minimum of five (5) years from the date of each transaction for AML compliance and regulatory audit purposes.
• Customer support records — retained for two (2) years from the date of the last support interaction, or longer if the matter relates to an unresolved dispute or regulatory investigation.
• Marketing consent records — retained for as long as you hold an active account and for a reasonable period thereafter to demonstrate compliance with consent obligations.
• Technical and device logs — retained for a rolling twelve (12) month period for fraud detection and security purposes, unless a specific incident requires longer retention.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification.

9 Data Security

5111jl implements a comprehensive suite of technical and organisational security measures designed to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 5111jl platform
• AES-256 encryption for sensitive personal and financial data stored at rest
• Strict role-based access controls, ensuring that only authorised 5111jl staff can access personal data on a need-to-know basis
• Multi-factor authentication (MFA) for all internal system access by 5111jl personnel
• Continuous security monitoring, intrusion detection systems, and regular third-party penetration testing
• Regular staff training on data privacy obligations under RA 10173 and security best practices
• Incident response procedures aligned with NPC breach notification requirements under RA 10173

10 Your Data Subject Rights

Under Republic Act No. 10173, the Data Privacy Act of 2012, you have the following rights in respect of your personal data held by 5111jl. You may exercise any of these rights free of charge by contacting our Data Protection Officer at the details in Section 15.

5111jl will respond to data subject rights requests within thirty (30) days of receipt. Where a request is complex or we receive a high volume of requests, we may extend this period by a further thirty (30) days, of which you will be notified.

11 International Data Transfers

5111jl's primary data processing operations are conducted within the Philippines. However, some of our third-party service providers — including cloud infrastructure providers and certain game content studios — may process data in other jurisdictions.

Where personal data is transferred outside the Philippines, 5111jl ensures that such transfers are subject to appropriate safeguards consistent with the requirements of RA 10173 and NPC guidance, including:

• Contractual clauses that bind the receiving party to data protection standards equivalent to those under RA 10173
• Transfer only to jurisdictions that have been assessed as providing adequate data protection, or where specific safeguards are in place
• Limiting transferred data to the minimum necessary for the specific service being provided

You may request details of the safeguards in place for any specific international data transfer by contacting our DPO.

12 Children & Minors

The 5111jl platform is strictly intended for adults aged twenty-one (21) years and above, as required by PAGCOR regulations governing online casino gaming in the Philippines. 5111jl does not knowingly collect or process personal data from individuals under the age of 21.

Age verification is conducted during the registration process and as part of the KYC procedure. Any account found to have been registered by or on behalf of a person under the age of 21 will be immediately closed, and all associated data will be deleted in accordance with applicable law.

If you are a parent or guardian and believe that a minor in your care has registered or attempted to register with 5111jl, please contact us immediately at the details provided in Section 15 so that we can investigate and take appropriate action.

13 Third-Party Services & Links

The 5111jl platform may contain references to or integrations with third-party services, including game providers, payment gateways such as GCash and Maya, and analytics tools. Each of these third-party services operates under its own privacy policy and data handling practices, for which 5111jl is not responsible.

5111jl does not control the privacy practices of its game content providers or payment processors beyond the contractual data processing agreements in place. We encourage you to review the privacy policies of any third-party services you interact with in connection with your 5111jl account.

Links to the privacy policies of major payment partners can be found within the relevant payment provider's application or website. 5111jl does not include external links in this document in accordance with our internal link policy.

14 Amendments to This Policy

5111jl reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulatory requirements, or NPC guidance. The "Last Updated" date at the top of this policy will be revised accordingly whenever a material change is made.

Where changes to this policy are material — meaning they significantly affect how we process your personal data or the rights available to you — 5111jl will notify registered players by email to the address on file and/or via a prominent notice on the platform prior to the changes taking effect. Continued use of the 5111jl platform following the effective date of any revised policy constitutes your acceptance of the updated terms.

We recommend that you review this Privacy Policy periodically to stay informed about how 5111jl protects your personal data. Archived versions of previous policies are available upon request from our Data Protection Officer.

15 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 5111jl processes your personal data, please contact our Data Protection Officer using the details below. All communications relating to data subject rights requests, privacy complaints, or data breach notifications should be directed to the DPO.

• Platform: 5111jl — 5111jl.net
• Role: Personal Information Controller (PIC)
• DPO Email: support@5111jl.net
• Operating Jurisdiction: Republic of the Philippines
• Regulatory Body: Philippine Amusement and Gaming Corporation (PAGCOR)
• Data Privacy Regulator: National Privacy Commission (NPC) of the Philippines