Privacy Policy – 11ph.com

1. Introduction

1.1 11ph.com is committed to protecting the privacy and personal data of all players who use our online casino platform. This Policy applies to all personal data collected through the 11ph.com website, mobile platform, and any related services offered under the 11phcom.net domain.

1.2 By registering an account on 11ph.com or by continuing to use our 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.

1.3 This Policy is intended to comply with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC) of the Philippines.

1.4 If you do not agree with the terms of this Privacy Policy, you should not register or continue to use the 11ph.com platform. You may contact our Data Protection Officer at any time with questions or concerns regarding this Policy.

2. Data Controller

2.1 For the purposes of the Philippine Data Privacy Act of 2012, 11ph.com (operated under 11phcom.net) is the personal information controller responsible for the personal data collected through the platform.

2.2 We have appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data privacy laws. You may contact our DPO using the contact details provided in Section 16 of this Policy.

3. Personal Data We Collect

3.1 11ph.com collects the following categories of personal data from players and platform visitors:

3.1 Identity and Registration Data

• Full legal name as it appears on your government-issued ID;
• Date of birth (used to verify that you meet the 21+ age requirement);
• Gender;
• Nationality and country of residence;
• Philippine government-issued ID details (e.g., driver's licence, passport, PhilSys National ID).

3.2 Contact Data

• Email address;
• Philippine mobile number;
• Residential address (including barangay, city/municipality, province).

3.3 Financial Data

• GCash or PayMaya account details (mobile number associated with the e-wallet);
• Bank account details for BPI, BDO, Metrobank, or other Philippine banks used for transactions;
• Partial card details (card type, last four digits) for Visa or Mastercard transactions;
• Transaction history, including deposits, withdrawals, and wager records.

3.4 Technical and Usage Data

• IP address and approximate geolocation;
• Device type, operating system, and browser information;
• Session data, including login timestamps and session duration;
• Pages visited, games played, and features accessed on the platform;
• Cookies and similar tracking technologies (see Section 10).

3.5 Communications Data

• Records of your communications with our customer support team via live chat or email;
• Feedback, complaints, and dispute records.

4. How We Collect Your Data

4.1 11ph.com collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated collection: Technical data collected automatically when you access the platform, including through cookies, web beacons, and server logs;
• Third-party sources: Identity verification data from KYC service providers; fraud prevention data from anti-fraud partners; payment data from payment processors such as GCash, PayMaya, and banking partners.

5. How We Use Your Personal Data

5.1 11ph.com uses your personal data for the following purposes:

5.2 11ph.com will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or as otherwise required by law.

6. Legal Basis for Processing

6.1 Under the Philippine Data Privacy Act of 2012, 11ph.com processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil our obligations under the Terms & Conditions you agreed to upon registration, including account management, payment processing, and game provision;
• Legal obligation: Processing required to comply with applicable Philippine laws, including the Data Privacy Act of 2012, Anti-Money Laundering Act, and PAGCOR regulatory requirements;
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving our services, where such interests are not overridden by your data privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw this consent at any time.

7. Data Sharing and Disclosure

7.1 11ph.com does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

7.1 Service Providers and Processors

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard partner processors, for the purpose of facilitating deposits and withdrawals in Philippine Peso;
• KYC and identity verification providers: Third-party services used to verify your identity and age in compliance with regulatory requirements;
• Fraud prevention and security partners: Services used to detect and prevent fraudulent activity on the platform;
• IT infrastructure and hosting providers: Cloud and server infrastructure providers who store and process data on our behalf under strict data processing agreements.

7.2 Regulatory and Law Enforcement Authorities

• PAGCOR (Philippine Amusement and Gaming Corporation), as required by our operating obligations;
• The Anti-Money Laundering Council (AMLC) of the Philippines, where required under the Anti-Money Laundering Act;
• The National Privacy Commission (NPC), in the event of a data breach or regulatory inquiry;
• Philippine law enforcement agencies, where required by a valid court order or legal process.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 11ph.com's business, your personal data may be transferred to the acquiring entity. You will be notified of any such transfer and the privacy terms applicable to your data following the transaction.

8. International Data Transfers

8.1 Some of 11ph.com's service providers and technology partners may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection to that afforded under Philippine law, 11ph.com will implement appropriate safeguards to protect your data, including contractual clauses approved by the National Privacy Commission.

8.2 By using the 11ph.com platform, you acknowledge and consent to the transfer of your personal data to countries outside the Philippines where necessary for the provision of our services, subject to the safeguards described in this section.

9. Data Retention

9.1 11ph.com retains your personal data for as long as your account remains active and for a period thereafter as required by applicable Philippine law and regulatory obligations. Specifically:

• Account and identity data: Retained for a minimum of five (5) years following account closure, as required under Philippine anti-money laundering regulations;
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction;
• Communications data: Retained for up to three (3) years from the date of the communication, or longer if relevant to an ongoing dispute or regulatory matter;
• Technical and usage data: Retained for up to two (2) years, after which it is anonymised or deleted.

9.2 Where personal data is no longer required for the purposes for which it was collected and no legal retention obligation applies, 11ph.com will securely delete or anonymise the data.

10. Cookies and Tracking Technologies

10.1 11ph.com uses cookies and similar tracking technologies to enhance your experience on the platform, maintain session security, and gather analytics data. The following types of cookies are used:

• Strictly necessary cookies: Essential for the platform to function correctly. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to personalise your experience on 11ph.com.
• Analytics cookies: Used to collect anonymised data about how players use the platform, including pages visited and features accessed. This data helps us improve the platform experience.
• Marketing cookies: Used to deliver relevant promotional content based on your activity on the platform. These are only set with your consent.

10.2 You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 11ph.com platform. Strictly necessary cookies cannot be disabled as they are essential to the platform's operation.

10.3 11ph.com does not use third-party advertising cookies or allow external advertising networks to place cookies on the platform without your explicit consent.

11. Your Data Privacy Rights

11.1 Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 11ph.com:

• Right to be informed: The right to be informed about how your personal data is collected, used, and processed, as described in this Policy;
• Right of access: The right to request a copy of the personal data we hold about you;
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data we hold about you;
• Right to erasure: The right to request deletion of your personal data, subject to our legal and regulatory retention obligations;
• Right to object: The right to 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: The right to receive your personal data in a structured, commonly used format where technically feasible;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.

11.2 To exercise any of the rights listed above, please contact our Data Protection Officer using the contact details in Section 16. We will respond to all verified requests within thirty (30) days, as required under Philippine law.

12. Children's Privacy

12.1 The 11ph.com platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

12.2 If you are a parent or guardian and believe that your child has registered on 11ph.com or provided personal data to us, please contact our support team immediately so that we can take appropriate action.

13. Security Measures

13.1 11ph.com implements a range of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 11ph.com platform;
• Encryption of sensitive data at rest, including identity documents and financial information;
• Role-based access controls limiting access to personal data to authorised personnel only;
• Regular security audits and vulnerability assessments of our platform infrastructure;
• Two-factor authentication options for player accounts;
• Continuous monitoring for suspicious activity and potential data breaches.

13.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 11ph.com will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected players without undue delay, as required under the Philippine Data Privacy Act.

13.3 While 11ph.com takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately of any suspected unauthorised access to your account.

14. Third-Party Links

14.1 The 11ph.com platform may contain links to third-party websites or services. This Privacy Policy applies solely to data collected by 11ph.com and does not cover the privacy practices of any third-party websites. We encourage you to review the privacy policies of any third-party sites you visit.

14.2 11ph.com is not responsible for the privacy practices or content of third-party websites linked from our platform.

15. Updates to This Privacy Policy

15.1 11ph.com reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. The date of the most recent revision is indicated at the top of this Policy.

15.2 Where changes to this Policy are material, we will notify registered players via email or through a prominent notice on the platform prior to the changes taking effect. Your continued use of the 11ph.com platform following notification of any amendment constitutes your acceptance of the revised Policy.

15.3 We encourage you to review this Privacy Policy periodically to stay informed about how 11ph.com protects your personal data.

16. Contact Us

16.1 If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by 11ph.com, please contact our Data Protection Officer:

16.2 If you are not satisfied with our response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the supervisory authority responsible for enforcing the Data Privacy Act of 2012.