fk111 Privacy Policy —
How We Protect Your Personal Data

For the purposes of the Data Privacy Act of the Philippines (Republic Act No. 10173, hereinafter "DPA") and its Implementing Rules and Regulations, the data controller responsible for personal data processed through the fk111 Platform is the operator of fk111.cam, a PAGCOR-regulated online gaming entity serving the Philippine market (hereinafter referred to as "fk111", "we", "us", or "our").

fk111 processes personal data as a personal information controller (PIC) as defined under Section 3(l) of RA 10173 — meaning we determine the purposes and means of processing your personal information. In certain operational contexts, fk111 may act as a personal information processor (PIP) under instruction from PAGCOR or other regulatory bodies in the performance of their regulatory functions.

fk111 collects personal data through three primary channels: information you provide directly during registration and account use, information generated automatically through your use of the Platform, and information received from third-party service providers in connection with payment processing and identity verification.

Information you provide directly:

• Full legal name as it appears on your government-issued ID.
• Date of birth (required for 21+ age verification).
• Philippine mobile number used as your primary account identifier.
• Email address for account communications and notifications.
• Home address (collected during KYC for high-value withdrawal verification).
• Government-issued ID documents (PhilSys National ID, Passport, Driver's License, SSS card, UMID, PRC ID, or Voter's ID) submitted during KYC.
• Financial account details for payment processing (GCash number, bank account name and number, PayMaya account).
• Communications submitted to fk111 via live chat, email, or support tickets.

Information collected automatically:

• IP address and approximate geolocation data derived from your IP address.
• Device type, operating system, browser type, and version.
• Session timestamps, login history, and session duration data.
• Full gameplay history including bets placed, games played, outcomes, and wagering activity across all game categories.
• Deposit and withdrawal transaction records, including amounts, timestamps, and payment method identifiers.
• Cookie and tracking technology data as described in Section 6 of this Policy.

Information received from third parties:

• Payment confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers.
• Identity verification results from third-party KYC service providers.
• Fraud risk indicators from payment processors and financial security services in connection with AML compliance obligations.

fk111 uses personal data for specific, legitimate purposes directly related to the provision of our gaming platform and our legal obligations as a PAGCOR-regulated operator. We do not use personal data for purposes incompatible with those stated below without obtaining your separate consent.

• Account creation and management: Creating and maintaining your fk111 Account, authenticating your identity on login, processing account settings changes, and communicating service updates relevant to your account.
• Age and identity verification (KYC): Verifying that you are at least 21 years of age and that your identity matches your registered account details, as required by PAGCOR regulations.
• Payment processing: Processing deposits, executing withdrawal requests, maintaining transaction records, and reconciling payment discrepancies with payment service providers.
• Regulatory compliance: Meeting fk111's obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (RA 9160), the Data Privacy Act (RA 10173), and other applicable Philippine laws.
• Fraud prevention and platform security: Detecting, investigating, and preventing fraudulent activity, multi-accounting, bonus abuse, unauthorized access, and other security threats to the Platform and our players.
• Responsible gaming enforcement: Monitoring gameplay patterns to identify potential problem gambling indicators, enforcing self-exclusion requests, and applying deposit or loss limits set by the player.
• Customer support: Responding to support inquiries, resolving disputes, and maintaining records of support interactions for quality and training purposes.
• Platform improvement: Analysing aggregated, anonymised usage data to improve Platform performance, game offerings, and user experience — this analysis does not involve individual profiling of specific players for marketing targeting.

fk111 processes personal data only where a valid legal basis exists under Section 12 and Section 13 of the Data Privacy Act of the Philippines. The applicable legal bases for fk111's processing activities are:

• Contractual necessity: Processing required to fulfil the agreement between you and fk111 — including account creation, payment processing, game access, and withdrawal execution.
• Legal obligation: Processing required to comply with PAGCOR licensing conditions, Anti-Money Laundering Act requirements, tax obligations, and other mandatory Philippine regulatory requirements.
• Legitimate interests: Processing carried out for fk111's legitimate interests where those interests are not overridden by your privacy rights — including fraud prevention, platform security monitoring, and anonymised analytics for service improvement.
• Consent: For processing not covered by the above bases — such as sending you promotional communications about fk111 offers — we rely on your explicit, informed, and freely given consent, which you may withdraw at any time without affecting the lawfulness of prior processing.

fk111 does not sell, rent, or trade personal data to third parties for commercial or marketing purposes. Personal data is shared only in the following limited and controlled circumstances:

• Payment service providers: GCash, PayMaya, BPI, BDO, Metrobank, and other payment processors receive the minimum data necessary to process your transactions. They are bound by their own regulatory obligations and are prohibited from using your data for purposes other than transaction execution.
• KYC and identity verification providers: Third-party identity verification services receive copies of your KYC documents solely for the purpose of identity verification. These providers operate under binding data processing agreements with fk111.
• Game software providers: Third-party game developers receive pseudonymised session data (player ID, bet amounts, game outcomes) for game delivery and RTP compliance purposes. They do not receive your personally identifiable information.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities may receive personal data as required by law, court order, or regulatory instruction.
• Professional advisors: Legal, accounting, and audit professionals engaged by fk111 may access personal data as strictly necessary in connection with their professional services, subject to professional confidentiality obligations.

fk111 uses cookies and similar tracking technologies to operate the Platform, maintain your login session, and analyse how the Platform is used. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies, security tokens, and load-balancing identifiers. These cookies cannot be disabled without impairing Platform functionality.
• Functional cookies: Remember your preferences such as language settings, display preferences, and last-used payment method to provide a more personalised experience on return visits.
• Analytics cookies: Collect anonymised data about how players interact with the Platform — pages visited, time spent, navigation paths — to identify usability improvements. This data is processed in aggregate and does not identify individual players.

You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies will prevent you from logging in and using fk111 services. Disabling functional or analytics cookies will not prevent access but may reduce the quality of your experience.

fk111 retains personal data for no longer than is necessary for the purposes for which it was collected, subject to the following retention standards:

• Active account data: Retained for the duration of your fk111 account and for a period of five (5) years following account closure, in compliance with PAGCOR record-keeping requirements.
• Financial transaction records: Retained for a minimum of ten (10) years from the date of each transaction in compliance with the Anti-Money Laundering Act (RA 9160) and AMLC regulatory requirements.
• KYC documentation: Retained for five (5) years after account closure or for the period required by PAGCOR, whichever is longer.
• Support communications: Retained for three (3) years from the date of the support interaction for quality and dispute resolution purposes.
• Analytics data: Anonymised analytics data does not contain personal identifiers and is not subject to personal data retention limits.

Upon expiry of applicable retention periods, personal data is securely and irreversibly deleted or anonymised in accordance with fk111's data disposal procedures.

fk111 implements a comprehensive set of technical and organisational security measures to protect personal data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include:

• 256-bit TLS/SSL encryption for all data in transit between your device and fk111's servers.
• Encryption at rest for personal data stored in fk111's database systems.
• Industry-standard password hashing algorithms (bcrypt or equivalent) ensuring passwords are never stored in recoverable form.
• Multi-factor authentication (OTP via SMS) for player account access from new or unrecognised devices.
• Role-based access controls ensuring fk111 staff can only access personal data strictly necessary for their job function.
• Regular independent security audits and penetration testing of fk111's platform infrastructure.
• Incident response procedures including mandatory breach notification obligations to the National Privacy Commission within 72 hours of discovering a personal data breach as required by NPC Circular 16-03.

While fk111 employs robust security measures, no internet-based service can guarantee absolute security. You play an important role in protecting your own data — particularly by maintaining the confidentiality of your fk111 password and OTP codes. fk111 will never ask for your password or OTP via live chat, email, or social media.

As a data subject under the Data Privacy Act of the Philippines, you have the following rights with respect to your personal data held by fk111. These rights are not absolute — they are subject to applicable exceptions under RA 10173 and its IRR, including exceptions for regulatory compliance and fraud prevention purposes.

Certain third-party service providers engaged by fk111 — including game software providers and technology infrastructure partners — may process personal data in jurisdictions outside the Philippines. Where such transfers occur, fk111 ensures they are conducted in compliance with Section 21 of RA 10173, which requires that the recipient country or organisation provides a level of protection equivalent to that mandated by Philippine law.

Cross-border transfers are governed by standard contractual clauses incorporated into fk111's agreements with third-party processors, obligating those processors to maintain data protection standards consistent with RA 10173. fk111 conducts due diligence on the data protection practices of all cross-border data recipients prior to engagement and on a periodic review basis thereafter.

fk111's KYC process is specifically designed to verify age compliance before any withdrawal is processed. Where fk111 discovers or has reasonable grounds to suspect that an Account holder is under 21 years of age, we will immediately suspend the Account, conduct identity verification, and if confirmed, permanently close the Account. Any deposits made will be returned and any winnings will be voided in accordance with our Terms and Conditions and PAGCOR regulatory requirements.

If you are a parent or guardian and believe a minor has created an fk111 Account, please contact our support team immediately via live chat or at [email protected]. We will prioritise the investigation and take appropriate action.

fk111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal requirements, or regulatory obligations. Material changes — those that significantly affect your rights or how we process your personal data — will be communicated to registered Players via the email address on file and/or via a prominent notice on the Platform at least fourteen (14) days prior to taking effect.

Non-material changes (such as typographical corrections, clarifications of existing practices, or updated contact information) may be made without prior notice, though the Policy's "Last Updated" date will always reflect the date of the most recent revision. We encourage you to review this Policy periodically. Your continued use of the fk111 Platform following the effective date of any updated Policy constitutes your acknowledgment of the changes.

fk111 has designated a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of the Philippines and this Privacy Policy. You may contact the fk111 DPO for any of the following purposes:

• Exercising any of your data subject rights described in Section 9.
• Raising a concern or complaint about fk111's personal data handling practices.
• Requesting clarification about any aspect of this Privacy Policy.
• Reporting a suspected personal data breach or privacy incident.

DPO Contact Channels:

• Live Chat: Available 24/7 inside your fk111 Account. State "Data Privacy Request" at the start of your chat session for routing to our privacy team.
• Email: [email protected] — include "Data Privacy Request" in the subject line. Written requests are acknowledged within 2 business hours and fully addressed within 15 business days as required by NPC regulations.

This Privacy Policy was last updated on 1 January 2026. For all prior versions, please contact the fk111 DPO. The current version supersedes all prior Privacy Policy documents published by fk111.