16jl111 Privacy Policy

1. Introduction

16jl111 ("16jl111," "we," "us," "our") operates the online gaming platform accessible at https://16jl111.net (the "Platform"). We are committed to protecting the privacy and personal data of all users ("Player," "you," "your") who access or use the Platform.

This Privacy Policy describes how 16jl111 collects, uses, stores, shares, and protects your personal information in connection with your use of the Platform. It also explains the rights available to you under Republic Act No. 10173, the Data Privacy Act of 2012 ("DPA"), and its Implementing Rules and Regulations ("IRR"), as enforced by the National Privacy Commission ("NPC") of the Philippines.

By registering an account on 16jl111 or otherwise using 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. If you do not agree, please discontinue use of the Platform immediately.

This Privacy Policy should be read together with our Terms & Conditions, which govern your use of the 16jl111 Platform.

2. Personal Data We Collect

16jl111 collects the following categories of personal data:

2.1 Registration and Identity Data

• Full legal name;
• Date of birth (to verify the 21-year age requirement);
• Gender;
• Nationality and country of residence;
• Government-issued identification number (e.g., PhilSys ID, SSS, UMID, passport number);
• Email address;
• Mobile phone number;
• Residential address (including barangay, city/municipality, province).

2.2 Financial and Transaction Data

• Payment method details (e.g., GCash mobile number, Maya account reference, bank account details for BPI, BDO, Metrobank, UnionBank, and other Philippine banks);
• Deposit and withdrawal history;
• Transaction amounts in Philippine Peso (PHP);
• Bonus and promotional credit history.

2.3 Gaming and Activity Data

• Game session logs, including games played, wagers placed, and outcomes;
• Login timestamps and session durations;
• Responsible gaming tool usage (deposit limits, self-exclusion requests);
• Customer support interaction records.

2.4 Technical and Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Mobile network operator (e.g., Globe, Smart, DITO);
• Cookies and similar tracking technology data (see Section 7).

3. How We Collect Your Data

16jl111 collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions;
• Automatically — through cookies, web beacons, and server logs when you access and interact with the Platform;
• From third parties — including identity verification providers, payment processors, and fraud prevention services, where necessary to verify your identity or process transactions.

4. How We Use Your Personal Data

16jl111 uses your personal data for the following purposes:

• Account Management: To create, maintain, and administer your 16jl111 account, including verifying your identity and age;
• Service Delivery: To provide access to games, process deposits and withdrawals, and deliver customer support;
• Legal Compliance: To comply with PAGCOR regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and other applicable Philippine laws;
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent activity, cheating, money laundering, and other prohibited conduct;
• Responsible Gaming: To monitor gaming behavior and apply responsible gaming tools, including deposit limits and self-exclusion, where appropriate;
• Platform Improvement: To analyze usage patterns, troubleshoot technical issues, and improve the performance and features of the 16jl111 Platform;
• Marketing Communications: To send you promotional offers, bonuses, and platform updates, where you have consented to receive such communications. You may opt out at any time by contacting support.

5. Legal Basis for Processing

16jl111 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you have agreed to;
• Legal Obligation: Processing is required to comply with applicable Philippine laws and regulations, including PAGCOR licensing requirements and AMLA obligations;
• Legitimate Interests: Processing is necessary for our legitimate interests in operating a secure, fair, and compliant gaming platform, provided such interests are not overridden by your rights;
• Consent: For certain processing activities, such as marketing communications, we rely on your explicit consent, which you may withdraw at any time.

6. Data Sharing and Disclosure

16jl111 does not sell your personal data. We may share your information with the following categories of recipients, strictly on a need-to-know basis:

• Payment Processors: GCash, Maya, and Philippine banking partners, to process deposits and withdrawals;
• Identity Verification Providers: Third-party KYC and AML screening services used to verify your identity and comply with regulatory requirements;
• Game Providers: Software providers whose games are hosted on the 16jl111 Platform, to the extent necessary to deliver game services;
• Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government bodies, where required by law or court order;
• IT and Security Service Providers: Cloud hosting, cybersecurity, and fraud detection vendors who process data on our behalf under strict data processing agreements;
• Professional Advisers: Lawyers, auditors, and accountants, where necessary for legal or compliance purposes.

All third parties with whom 16jl111 shares personal data are contractually required to implement appropriate data protection measures consistent with the DPA and its IRR.

7. Cookies and Tracking Technologies

16jl111 uses cookies and similar technologies (including web beacons and local storage) to enhance your experience on the Platform. The types of cookies we use include:

• Essential Cookies: Required for the Platform to function, including session management and security features. These cannot be disabled;
• Functional Cookies: Remember your preferences, such as language settings and login status;
• Analytics Cookies: Help us understand how players use the Platform so we can improve performance and user experience;
• Marketing Cookies: Used to deliver relevant promotional content to you on the Platform, based on your activity.

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 16jl111 Platform.

8. Data Retention

16jl111 retains your personal data for as long as your account is active and for a period thereafter as required by applicable law. Specifically:

• Account and identity data is retained for a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements;
• Transaction records are retained for a minimum of five (5) years from the date of the transaction;
• Customer support records are retained for three (3) years from the date of the interaction;
• Marketing consent records are retained for as long as necessary to demonstrate compliance with consent requirements.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 16jl111's data disposal procedures.

9. Data Security

16jl111 implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and the 16jl111 Platform is encrypted using Transport Layer Security (TLS). Sensitive data at rest is encrypted using industry-standard algorithms;
• Access Controls: Access to personal data is restricted to authorized personnel on a strict need-to-know basis. All staff with access to personal data are subject to confidentiality obligations;
• Firewalls and Intrusion Detection: The Platform is protected by enterprise-grade firewalls and continuous intrusion detection and prevention systems;
• Regular Security Audits: 16jl111 conducts periodic security assessments and vulnerability testing to identify and remediate potential risks;
• Two-Factor Authentication: Players are encouraged to enable two-factor authentication (2FA) on their accounts for an additional layer of security.

While 16jl111 takes all reasonable steps to protect your data, no system is completely immune to security risks. In the event of a data breach that is likely to result in a risk to your rights and freedoms, 16jl111 will notify you and the National Privacy Commission (NPC) in accordance with the requirements of the Data Privacy Act of 2012.

10. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 16jl111:

• Right to Be Informed: You have the right to be informed of how your personal data is being collected and processed, as set out in this Privacy Policy;
• Right of Access: You may request a copy of the personal data that 16jl111 holds about you, along with information about how it is being used;
• Right to Rectification: You may request correction of any inaccurate or incomplete personal data we hold about you;
• 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 our legal retention obligations;
• Right to Object: You may object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests;
• Right to Data Portability: You may request that we provide your personal data in a structured, commonly used, and machine-readable format;
• Right to Lodge a Complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe that your data protection rights have been violated.

To exercise any of the above rights, please contact our Data Protection Officer using the contact details provided in Section 14. We will respond to your request within thirty (30) days, as required by the DPA and its IRR.

11. Children's Privacy and Age Restriction

The 16jl111 Platform is strictly intended for individuals who are at least twenty-one (21) years of age, in accordance with Philippine gaming regulations. 16jl111 does not knowingly collect personal data from persons under the age of 21.

If we become aware that personal data has been collected from a person under 21 years of age, we will take immediate steps to delete such data and close the associated account. If you believe that a minor has registered on the Platform, please contact us immediately at the details provided in Section 14.

12. International Data Transfers

16jl111 primarily stores and processes your personal data within the Philippines. In certain circumstances, your data may be transferred to or processed by service providers located outside the Philippines — for example, cloud infrastructure providers or international fraud screening services.

Where such transfers occur, 16jl111 ensures that appropriate safeguards are in place to protect your personal data, including contractual clauses that require the recipient to apply data protection standards equivalent to those required under the Data Privacy Act of 2012. By using the 16jl111 Platform, you consent to such transfers where they are necessary for the provision of our services.

13. Updates to This Privacy Policy

16jl111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When we make material changes, we will post the updated Privacy Policy on this page with a revised "Last Updated" date and, where appropriate, notify you via email or an in-platform notification.

Your continued use of the 16jl111 Platform following the posting of any updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically to stay informed about how we protect your data.

14. Contact Us and Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by 16jl111, please contact our Data Protection Officer (DPO):

• Email: [email protected]
• Live Chat: Available 24/7 on the 16jl111 Platform
• Response Time: We aim to respond to all data-related inquiries within thirty (30) calendar days.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines through its official channels.