Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 11JL ("we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("you" or "Player") who access or use the 11JL online gaming platform at 11jl.app and any associated mobile applications (collectively, the "Platform").

11JL is committed to protecting the privacy and personal data of all players in accordance with the Republic Act No. 10173, also known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations as administered by the National Privacy Commission (NPC).

By registering an account on 11JL, accessing the Platform, or otherwise providing us with your personal information, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must discontinue use of the Platform immediately.

This Policy should be read together with our Terms & Conditions, which govern your overall use of the 11JL Platform.

2. Personal Data We Collect

11JL collects the following categories of personal data from players and prospective players:

2.1 Identity & Contact Data

• Full legal name as it appears on your government-issued identification
• Date of birth (for age verification — 21+ requirement)
• Residential address (barangay, city/municipality, province)
• Email address
• Mobile phone number
• Nationality and country of residence

2.2 Identity Verification (KYC) Data

• Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, UMID, PhilSys national ID, driver's license)
• Proof of address documents ( e.g., utility bill, bank statement, barangay certificate)
• Selfie or facial image for identity matching, where required

2.3 Financial Data

• Payment method details (e.g., GCash account name and number, PayMaya account, BDO, BPI, or Metrobank account details)
• Deposit and withdrawal transaction history
• Account balance information
• Source of funds declarations where required by anti-money laundering regulations

2.4 Gaming Activity Data

• Game session history, including games played, wagers placed, and outcomes
• Bonus and promotion usage history
• Responsible gaming tool settings (deposit limits, session limits, self-exclusion status)

2.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Login timestamps and session duration
• Cookies and similar tracking technology data (see Section 7)

2.6 Communications Data

• Records of your communications with 11JL customer support (live chat transcripts, email correspondence)
• Survey responses and feedback submissions
• Marketing preferences and opt-in/opt-out records

3. How We Collect Your Data

11JL collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and device data collected automatically when you access the Platform, including through cookies, web beacons, and server logs.
• Third-party verification providers: Identity and address verification data obtained from licensed KYC and anti-money laundering service providers engaged by 11JL.
• Payment processors: Transaction confirmation and payment status data received from GCash, PayMaya, and partner banking institutions.
• Regulatory authorities: In limited circumstances, data may be received from Philippine regulatory or law enforcement authorities in connection with legal obligations.

4. How We Use Your Personal Data

11JL processes your personal data for the following specific purposes:

11JL 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.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 11JL processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions, including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with applicable Philippine laws, including anti-money laundering regulations, gaming regulations, and tax reporting requirements.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed, and freely given consent. You may withdraw consent at any time.

6. Sharing Your Personal Data

11JL 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, strictly on a need-to-know basis and subject to appropriate data protection agreements:

6.1 Service Providers

Third-party vendors engaged by 11JL to provide services on our behalf, including KYC and identity verification providers, payment processors (GCash, PayMaya, BDO, BPI, Metrobank), cloud hosting and infrastructure providers, customer support platform providers, and fraud detection and cybersecurity services. All service providers are contractually bound to process your data only on 11JL's instructions and in accordance with applicable data protection law.

6.2 Game Content Providers

Licensed game studios and content providers whose games are available on the 11JL Platform may receive limited technical data (such as session tokens and game result data) necessary to operate their games. These providers do not receive your full identity or financial data.

6.3 Regulatory and Law Enforcement Authorities

11JL may disclose personal data to Philippine government agencies, regulatory bodies, or law enforcement authorities where required by law, court order, or regulatory directive. This includes disclosures to the Anti-Money Laundering Council (AMLC) as required under Republic Act No. 9160 and its amendments.

6.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 11JL's assets, your personal data may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy. You will be notified of any such transfer in advance.

7. Cookies & Tracking Technologies

11JL 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:

• Essential cookies: Required for the Platform to function correctly, including session management, login authentication, and security features. These cannot be disabled without affecting Platform functionality.
• Analytics cookies: Used to collect aggregated, anonymized data about how players use the Platform, helping us identify areas for improvement. No personally identifiable information is included in analytics reports.
• Preference cookies: Store your Platform settings and preferences (such as language and display options) to personalize your experience.
• Marketing cookies: Used only with your explicit consent to deliver relevant promotional content. You may opt out of marketing cookies at any time through your account settings.

You may manage your cookie preferences through your browser settings. Please note that disabling essential cookies may impair your ability to use certain features of the 11JL Platform.

8. Data Retention

11JL retains your personal data for as long as your account remains active and for a period thereafter as required by applicable law and regulatory obligations. Specific retention periods are as follows:

• Account and identity data: Retained for a minimum of five (5) years following account closure, in compliance with anti-money laundering regulations.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction, as required by Philippine financial regulations.
• Gaming activity data: Retained for three (3) years following account closure for dispute resolution and regulatory audit purposes.
• Customer support communications: Retained for two (2) years from the date of the last interaction.
• Marketing preference records: Retained until you withdraw consent or request deletion, whichever occurs first.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 11JL's data disposal procedures.

9. Data Security

11JL implements a comprehensive set of technical and organizational security measures to protect your personal data against unauthorized access, disclosure, alteration, loss, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and 11JL servers
• AES-256 encryption for sensitive data stored at rest
• Multi-factor authentication options for player accounts
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis
• Regular security audits, vulnerability assessments, and penetration testing
• 24/7 intrusion detection and monitoring systems
• Secure data center facilities with physical access controls

Despite these measures, no method of electronic transmission or data storage is completely secure. In the event of a personal data breach that poses a risk to your rights and freedoms, 11JL will notify the National Privacy Commission and affected players in accordance with the requirements of the Data Privacy Act of 2012.

10. Your Data Privacy Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 11JL:

• Right to be informed: The right to know what personal data 11JL collects about you and how it is processed — which this Policy fulfills.
• Right of access: The right to request a copy of all personal data 11JL holds about you, including information on how it has been used and with whom it has been shared.
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data held about you.
• Right to erasure: The right to request deletion of your personal data, subject to 11JL's legal 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 legitimate interests.
• Right to data portability: The right to receive your personal data in a structured, commonly used, and machine-readable format.
• Right to lodge a complaint: The right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of the above rights, please contact the 11JL Data Privacy Officer through our customer support team. We will respond to all verified requests within thirty (30) calendar days. We may require you to verify your identity before processing your request.

11. Children's Privacy

The 11JL Platform is strictly intended for individuals aged 21 years and above. We do not knowingly collect personal data from persons under the age of 21. The 21+ age requirement is enforced through our KYC verification process at the time of account registration.

If 11JL becomes aware that personal data has been collected from a person under the age of 21, we will immediately close the associated account, delete the collected data, and return any deposited funds to the original payment source. If you believe that a minor has registered on the 11JL Platform, please contact our support team immediately.

12. Cross-Border Data Transfers

In certain circumstances, your personal data may be transferred to, stored in, or processed in countries outside the Philippines — for example, where 11JL engages cloud infrastructure providers or game content partners with servers located abroad.

Where such transfers occur, 11JL ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that required under Philippine law. These safeguards may include contractual data protection clauses, adequacy assessments, or other mechanisms recognized by the National Privacy Commission.

By using the 11JL Platform, you consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

13. Updates to This Privacy Policy

11JL reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or Platform features. When material changes are made, we will notify registered players via email or a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this page will always reflect the date of the most recent revision. We encourage you to review this Policy periodically to stay informed about how 11JL protects your personal data. Your continued use of the Platform following the publication of any revised Policy constitutes your acceptance of the updated terms.

14. Contact Our Data Privacy Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your personal data by 11JL, please contact our Data Privacy Officer (DPO). Our DPO is responsible for overseeing 11JL's compliance with the Data Privacy Act of 2012 and this Policy.

You may reach the 11JL Data Privacy Officer through our 24/7 live chat support on the Platform, or by email at: privacy@11jl.app

Please include your registered account username, a clear description of your request or concern, and any relevant details to help us respond promptly and accurately.

If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines. Information on how to file a complaint with the NPC is available through official Philippine government channels.