123ji Privacy Policy

§1 Data Controller

1.1 For the purposes of the Data Privacy Act of 2012 (Republic Act No. 10173) and applicable data protection regulations, 123ji (operating at 123ji.net) is the data controller responsible for the personal information collected through the 123ji platform.

1.2 As data controller, 123ji determines the purposes and means of processing your personal data. We are committed to processing your data lawfully, fairly, and transparently in accordance with Philippine law.

1.3 For all data privacy inquiries, requests, or complaints, you may contact our Data Protection Officer at: [email protected]

§2 Data We Collect

2.1 123ji collects personal data that you provide directly, data generated through your use of the platform, and data received from third-party verification services. The categories of data we collect include:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (for age verification purposes);
• Residential address (including barangay, city, province);
• Email address and mobile number;
• Government-issued ID details (SSS, UMID, PhilHealth, passport, or driver's license number).

2.2 Financial Data

• GCash or PayMaya account details used for deposits and withdrawals;
• Bank account details (BPI, BDO, Metrobank) where applicable;
• Transaction history, including deposit amounts, withdrawal amounts, and dates;
• Source of funds documentation where required for enhanced due diligence.

2.3 Technical & Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Login timestamps and session duration;
• Game history, betting patterns, and platform interaction logs;
• Cookie identifiers and similar tracking technologies.

2.4 Communications Data

• Records of communications with 123ji's customer support team;
• Responses to surveys, promotions, or feedback requests;
• Email and in-platform notification interaction data.

§3 How We Use Your Data

3.1 123ji processes your personal data for the following purposes:

§4 Legal Basis for Processing

4.1 123ji processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to upon registration, including account management and payment processing;
• Legal Obligation: Processing required to comply with Philippine law, PAGCOR regulations, and anti-money laundering obligations;
• Legitimate Interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your data protection rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time by contacting support.

§5 Data Sharing

5.1 123ji does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data only in the following limited circumstances:

• Payment Processors: GCash, PayMaya, BPI, BDO, Metrobank, 7-Eleven, and Cebuana, solely to process your financial transactions;
• Identity Verification Providers: Third-party KYC (Know Your Customer) service providers engaged to verify your identity and age in compliance with regulatory requirements;
• Game Providers: Software providers whose games are hosted on the 123ji platform, to the extent necessary to deliver game services and maintain game integrity;
• Regulatory Authorities: PAGCOR, the National Privacy Commission, the Anti-Money Laundering Council (AMLC), and other Philippine government agencies, where required by law or court order;
• Professional Advisors: Legal counsel, auditors, and other professional advisors engaged by 123ji, subject to strict confidentiality obligations.

5.2 All third parties with whom 123ji shares personal data are required to process such data in accordance with applicable Philippine data protection law and are prohibited from using it for any purpose other than the specific service they provide to 123ji.

§6 Data Retention

6.1 123ji retains your personal data for as long as your account remains active and for a period thereafter as required by law or legitimate business necessity. Specific 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 compliance with Philippine AML regulations;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by the Anti-Money Laundering Act;
• Customer support records: Retained for three (3) years from the date of the last interaction;
• Marketing preferences: Retained until you withdraw consent or close your account;
• Technical and usage logs: Retained for twelve (12) months from the date of generation.

6.2 Upon expiry of the applicable retention period, 123ji will securely delete or anonymize your personal data in accordance with industry best practices.

§7 Data Security

7.1 The security measures implemented by 123ji include, but are not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and 123ji's servers;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Multi-factor authentication options for player account access;
• Regular security audits and penetration testing by independent third-party security firms;
• Strict access controls limiting employee access to personal data on a need-to-know basis;
• Comprehensive data breach response procedures, including notification to the National Privacy Commission within 72 hours of discovering a breach that poses a real risk to data subjects.

7.2 While 123ji takes all reasonable steps to protect your data, no internet transmission or electronic storage system is 100% secure. Players are encouraged to use strong, unique passwords for their 123ji accounts and to enable all available security features.

§8 Cookies & Tracking Technologies

8.1 123ji uses cookies and similar tracking technologies to operate and improve the platform. The types of cookies we use are:

8.2 123ji does not use third-party advertising or retargeting cookies. You can manage or disable non-essential cookies through your browser settings at any time. Note that disabling essential cookies may affect the functionality of the 123ji platform.

§9 Your Rights

9.1 Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 123ji:

• Right to be Informed: The right to know what personal data 123ji collects about you and how it is used;
• Right of Access: The right to request a copy of the personal data 123ji holds about you;
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data;
• Right to Erasure: The right to request deletion of your personal data, subject to legal retention obligations;
• Right to Data Portability: The right to receive your personal data in a structured, commonly used format;
• Right to Object: The right to object to processing of your personal data for direct marketing purposes;
• Right to Lodge a Complaint: The right to file a complaint with the National Privacy Commission of the Philippines if you believe your data rights have been violated.

9.2 To exercise any of the above rights, please contact 123ji's Data Protection Officer at [email protected]. We will respond to all verified requests within thirty (30) calendar days.

§10 Minors & Age Restriction

10.1 If 123ji discovers that personal data has been collected from an individual under the age of 21, we will immediately delete such data and close the associated account. Any funds in such an account will be handled in accordance with applicable Philippine law.

10.2 If you believe that a minor has registered on the 123ji platform, please notify us immediately at [email protected] so that we can take prompt action.

§11 International Data Transfers

11.1 In certain circumstances, 123ji may transfer your personal data to service providers or partners located outside the Philippines, such as cloud infrastructure providers or game software vendors.

11.2 Where such transfers occur, 123ji ensures that appropriate safeguards are in place to protect your data, including contractual data protection clauses that meet the standards required by the National Privacy Commission of the Philippines.

11.3 By using the 123ji platform, you consent to the transfer of your personal data outside the Philippines where necessary for the provision of our services, subject to the safeguards described in this section.

§12 Policy Amendments

12.1 123ji reserves the right to update or amend this Privacy Policy at any time. The most current version will always be available on this page, with the "Last Updated" date reflecting the date of the most recent revision.

12.2 Where changes are material, 123ji will notify registered players via email or an in-platform notification prior to the changes taking effect. Continued use of the 123ji platform following such notification constitutes acceptance of the revised Privacy Policy.

12.3 For any questions or concerns regarding this Privacy Policy or 123ji's data practices, please contact our Data Protection Officer: [email protected]