Privacy Policy

01 Introduction

fk111 is a PAGCOR-regulated online casino and sports betting platform serving Filipino players across the Philippines. We operate fk111.bio and all associated subdomains and mobile applications under this unified Privacy Policy.

This Policy is issued in compliance with the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations (IRR), and the applicable circulars of the National Privacy Commission (NPC). It also reflects our obligations under the PAGCOR Online Gaming Regulations and the Anti-Money Laundering Act (RA 9160, as amended).

fk111 acts as the Personal Information Controller (PIC) for all personal data collected through the platform. This means we determine the purpose and means of processing your personal information and are responsible for ensuring that such processing is carried out lawfully, fairly, and securely.

We take our responsibilities as a PIC seriously. Our Data Protection Officer (DPO) oversees all privacy-related matters and can be reached through the contact details provided in Section 14 of this Policy.

02 Personal Data We Collect

fk111 collects the following categories of personal data from players and site visitors:

2.1 Registration & Identity Data

• Full legal name as it appears on a government-issued Philippine ID
• Date of birth (used to verify the 21+ age requirement)
• Gender
• Registered email address
• Philippine mobile number
• Username and hashed password
• Residential address within the Philippines

2.2 KYC & Verification Data

• Scanned or photographed copy of a government-issued Philippine ID (e.g., passport, PhilSys National ID, UMID, SSS ID, driver's license, PhilHealth ID, Voter's ID)
• Selfie photograph holding the submitted ID
• Proof of payment method ownership (e.g., screenshot of GCash wallet showing name and mobile number)

2.3 Financial & Transaction Data

• Deposit and withdrawal transaction records including amounts, timestamps, and payment method identifiers
• GCash wallet number, Maya account details, bank account name and number (partial, for verification only)
• Bonus and promotional activity records
• Wagering history and game session logs

2.4 Technical & Usage Data

• IP address and approximate geolocation (used to verify Philippine residency)
• Device type, operating system, and browser version
• Login timestamps and session duration
• Pages visited, features used, and clickstream data
• Error logs and technical diagnostics

2.5 Communications Data

• Records of live chat conversations with fk111 support agents
• Email correspondence with fk111
• Responses to surveys, feedback forms, and promotions

03 How We Collect Your Data

fk111 collects personal data through the following channels:

fk111 does not collect personal data from third-party data brokers or purchase marketing lists. All personal data we hold is provided directly by you or generated automatically through your use of the platform.

04 How We Use Your Personal Data

fk111 uses the personal data we collect for the following specific purposes:

4.1 Account Management & Service Delivery

We use your registration data to create and maintain your fk111 account, authenticate your identity at login, process your deposits and withdrawals, and deliver the gaming services you have requested. This processing is necessary for the performance of our contract with you.

4.2 Identity Verification & KYC Compliance

fk111 is required by PAGCOR regulations to verify the identity of all players before processing withdrawals exceeding regulatory thresholds. KYC data — including government ID copies and selfies — is used exclusively for this purpose. We verify that you are who you say you are, that you are at least 21 years of age, and that your payment methods are registered in your own name.

4.3 Anti-Money Laundering (AML) Monitoring

Transaction data, gaming activity, and financial records are monitored for unusual patterns consistent with money laundering, terrorist financing, or fraud as required by the Anti-Money Laundering Act (RA 9160, as amended). Suspicious transactions are reported to the Anti-Money Laundering Council (AMLC) as required by law.

4.4 Responsible Gaming Safeguards

fk111 uses gameplay data, deposit patterns, and session information to identify signs of problem gambling behavior. This analysis enables us to deploy responsible gaming interventions such as reality checks, usage summaries, and — where warranted — proactive outreach to players who may benefit from self-exclusion or limit-setting tools.

4.5 Customer Support

Communications data is used to respond to your support inquiries, resolve disputes, and improve the quality of our customer service. Support interactions may be recorded for quality assurance purposes; you will be informed of this at the start of a recorded interaction.

4.6 Platform Improvement & Analytics

Technical and usage data is analyzed in aggregate to understand how players interact with fk111, identify areas for improvement, troubleshoot technical issues, and optimize the user experience. This analysis does not result in decisions that individually affect you without human review.

4.7 Marketing Communications

With your consent, fk111 may send you promotional communications about new games, bonuses, and platform features via email or SMS. You can withdraw your consent and unsubscribe at any time by following the unsubscribe link in any marketing email, updating your communication preferences in your account settings, or contacting our support team.

05 Legal Basis for Processing

Under the Data Privacy Act of 2012, fk111 processes your personal data on the following legal bases:

• Contractual Necessity: Processing your registration data, transaction records, and account activity is necessary to perform the contract between you and fk111 — namely, to provide you with access to the gaming platform and process your financial transactions.
• Legal Obligation: KYC verification, AML monitoring, and regulatory reporting are required by PAGCOR regulations, the Anti-Money Laundering Act, and the Data Privacy Act itself. fk111 has no discretion to decline this processing.
• Legitimate Interests: Technical data collection for security monitoring, fraud prevention, and platform analytics is processed on the basis of fk111's legitimate interest in maintaining a safe, fair, and functional gaming environment, balanced against your privacy interests.
• Consent: Marketing communications and non-essential cookie placement are conducted only on the basis of your freely given, specific, and informed consent. You may withdraw this consent at any time without affecting the lawfulness of prior processing.

06 Data Sharing & Disclosure

fk111 does not sell your personal data. We share personal data only in the following limited circumstances:

6.1 Service Providers & Technology Partners

fk111 engages trusted third-party service providers to help operate the platform. These include KYC identity verification providers, payment processors (GCash, Maya, BPI, BDO, Metrobank, InstaPay), cloud hosting providers, customer support software vendors, and analytics platforms. These providers are contractually bound to process your data only for the specific purposes instructed by fk111 and are prohibited from using your data for their own purposes.

6.2 Regulatory Authorities

fk111 is required by law to share certain player data with regulatory and law enforcement authorities, including PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and the Bureau of Internal Revenue (BIR), where applicable. All such disclosures are made strictly in compliance with legal requirements and only to the extent necessary to fulfill our regulatory obligations.

6.3 Corporate Transactions

In the event of a merger, acquisition, or sale of substantially all of fk111's 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 via your registered email address.

6.4 Consent-Based Sharing

fk111 will not share your personal data with any other third party without your explicit prior consent, except as described above.

07 Cookies & Tracking Technologies

fk111 uses cookies — small text files stored on your device — and similar tracking technologies to enhance your experience on the platform. We use the following categories of cookies:

You can manage or delete cookies at any time through your browser settings. Please note that disabling strictly necessary cookies may prevent some features of fk111 from functioning correctly. For more information on managing cookies, refer to your browser's help documentation.

08 Data Retention

fk111 retains personal data only for as long as necessary to fulfil the purposes described in this Policy, comply with our legal obligations, resolve disputes, and enforce our agreements.

• Active Account Data: Retained for the full duration of your account's active status on fk111.
• Transaction & Financial Records: Retained for a minimum of five (5) years following the transaction date, as required by PAGCOR regulations and the Anti-Money Laundering Act.
• KYC Documents: Retained for a minimum of five (5) years following account closure or the most recent KYC update, whichever is later, as required by AMLC regulations.
• Customer Support Records: Retained for three (3) years following the close of the relevant support interaction.
• Marketing Consent Records: Retained for the duration of your consent plus three (3) years, to demonstrate compliance with consent requirements.
• Technical & Usage Logs: Retained for up to twelve (12) months for security and analytics purposes, then anonymized or deleted.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized so that it can no longer be attributed to an identified individual. fk111 conducts annual data retention reviews to ensure compliance with this schedule.

09 Data Security

fk111 implements a comprehensive set of technical, organizational, and physical security measures to protect your personal data against unauthorized access, disclosure, alteration, and destruction.

9.1 Technical Measures

• TLS 1.3 encryption for all data transmitted between your browser and fk111 servers
• AES-256 encryption for all personally identifiable data stored at rest
• Multi-factor authentication (MFA) required for all fk111 administrative system access
• Regular automated vulnerability scanning and penetration testing by independent security firms
• Web Application Firewall (WAF) and DDoS protection on all platform endpoints

9.2 Organizational Measures

• Role-based access controls ensuring staff can only access personal data necessary for their specific job function
• Mandatory annual data privacy and security training for all fk111 employees
• Binding confidentiality agreements for all staff and contractors who handle personal data
• A documented Data Breach Response Plan that is tested and reviewed annually

Despite these measures, no internet-based system is completely immune to security risks. In the event of a personal data breach that is likely to result in harm to data subjects, fk111 will notify the National Privacy Commission within 72 hours and affected players as soon as practicable, as required by 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 fk111:

• Right to be Informed: You have the right to know what personal data fk111 collects, why it is collected, and how it is used — which is the primary purpose of this Privacy Policy.
• Right of Access: You may request a copy of all personal data fk111 holds about you, including the categories of data, the purposes for which it is processed, and the recipients with whom it has been shared.
• Right to Rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected promptly. You can update many details directly in your fk111 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, where you have withdrawn consent, or where processing is unlawful. Note that this right is subject to fk111's legal obligation to retain certain records under PAGCOR and AMLC regulations.
• Right to Data Portability: Where technically feasible, you may request that fk111 provide your personal data in a structured, commonly used, and machine-readable format so that it can be transferred to another service provider.
• 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 processing based on legitimate interests, subject to fk111's demonstrating compelling legitimate grounds.
• Right to Lodge a Complaint: If you believe that fk111 has not handled your personal data in accordance with the Data Privacy Act of 2012, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request." We will respond to all verified requests within thirty (30) days of receipt. We may ask you to verify your identity before fulfilling a request to protect against unauthorized access to your data.

11 Children & Minors

Our registration process includes a mandatory date of birth field, and our KYC verification process independently confirms each player's age through government-issued ID documents. Any account found to belong to an individual under 21 years of age will be immediately and permanently closed, all funds forfeited, and the matter reported to the relevant authorities.

If you are a parent or guardian and believe that your child under the age of 21 has registered an fk111 account or submitted personal data to fk111, please contact us immediately at [email protected]. We will investigate and take appropriate action, including deleting all personal data associated with the underage account, within 72 hours.

12 International Data Transfers

fk111 is a Philippines-based platform and primarily processes personal data within the Philippines. However, some of our third-party service providers — including cloud hosting infrastructure, KYC verification partners, and analytics platforms — may process data on servers located outside the Philippines.

Where personal data is transferred outside the Philippines, fk111 ensures that such transfers are subject to appropriate safeguards, including:

• Contractual clauses that require overseas recipients to apply data protection standards equivalent to those required under RA 10173
• Transfers only to countries or recipients that the National Privacy Commission has determined provide an adequate level of data protection
• Your explicit consent, where required for a specific transfer

fk111 does not transfer your personal data to jurisdictions that lack adequate data protection frameworks without first implementing appropriate contractual or technical safeguards. A list of the countries in which our key service providers operate is available upon request from our Data Protection Officer.

13 Changes to This Privacy Policy

fk111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, new regulatory requirements, or improvements to our platform. When we make material changes to this Policy, we will:

• Post the updated Policy on this page with a revised "Last Updated" date
• Send a notification to your registered email address at least fourteen (14) days before the changes take effect
• Display a prominent notice on the fk111.bio homepage for a minimum of thirty (30) days following the update

Your continued use of fk111 after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Policy, you may close your account by contacting our support team before the effective date of the changes.

We encourage you to review this Privacy Policy periodically to stay informed about how fk111 protects your personal data. Previous versions of this Policy are archived and available upon request.

14 Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way fk111 handles your personal data, please contact our Data Protection Officer (DPO) through the following channels:

We aim to respond to all privacy-related inquiries within five (5) business days. For formal Data Subject Rights Requests, please include "Data Subject Rights Request" in the subject line of your email and provide sufficient information to verify your identity so we can process your request securely.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. The NPC's contact details and complaint procedures are available at their official website.