Privacy Policy — Your Data, Protected.

This Privacy Policy ("Policy") describes how 11jl ("we," "us," "our," "the Company"), operator of the online gaming platform accessible at 11jl.asia, collects, processes, stores, shares, and protects the personal data of players and visitors ("you," "Data Subject") in connection with the use of the 11jl Platform and related services.

This Policy is issued in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR), as enforced by the National Privacy Commission (NPC) of the Philippines. It is also consistent with the operational requirements imposed by PAGCOR on licensed online gaming operators.

By registering a player account with 11jl, by logging in to the 11jl Platform, or by continuing to use the Platform after the effective date of this Policy, 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. If you do not consent, you must discontinue use of the Platform immediately.

This Policy forms part of the overall agreement between you and 11jl and should be read together with the 11jl Terms and Conditions.

11jl collects the following categories of personal data in connection with your use of the Platform. We collect only what is necessary for the purposes described in this Policy.

11jl does not collect sensitive personal information as defined under Section 3(l) of RA 10173 (including race, political opinions, health data, sexual orientation, or religious beliefs) except where required by PAGCOR-mandated responsible gaming assessments or anti-money laundering due diligence, and only to the minimum extent necessary for such specific legal purpose.

11jl processes your personal data for the following purposes:

• Account Management: Creating, maintaining, and administering your 11jl player account, including authentication, password recovery, and account security;
• KYC & Identity Verification: Verifying your identity and age (21+) to comply with PAGCOR regulations and to prevent underage gambling, identity fraud, and the use of false identities;
• Payment Processing: Processing deposits and withdrawals via GCash, PayMaya, BPI, BDO, and Metrobank; reconciling transactions; and investigating disputed transactions;
• Game Delivery: Delivering casino games, live dealer tables, slots, bingo, sports betting, and other Platform features; maintaining game session integrity; and resolving game disputes;
• Bonus Administration: Tracking wagering requirements, managing VIP loyalty tiers, and detecting and preventing bonus abuse;
• Regulatory Compliance: Meeting our obligations under PAGCOR licensing conditions, the Anti-Money Laundering Act (AMLA), and reporting requirements to regulatory authorities;
• Fraud Prevention & Security: Detecting and preventing unauthorized access, money laundering, collusion, cheating, and other prohibited activities;
• Responsible Gaming: Monitoring betting patterns to identify potentially problematic gambling behavior; administering deposit limits, self-exclusion, and cooling-off periods;
• Customer Support: Responding to inquiries, resolving disputes, and improving the quality of support interactions;
• Platform Improvement: Analyzing aggregated, anonymized usage data to identify technical issues, improve features, and optimize the user experience;
• Communications: Sending transactional notifications (deposit confirmations, withdrawal updates, security alerts) and, where you have opted in, promotional communications about 11jl offers and events.

Under the Data Privacy Act of 2012 and its IRR, 11jl processes your personal data on the following legal bases:

• Contractual Necessity: Processing required to perform the contract between you and 11jl — specifically, your account registration, game access, payment processing, and customer support. Without this processing, 11jl cannot deliver the Platform services you have agreed to in the Terms and Conditions.
• Legal Obligation: Processing required to comply with applicable Philippine law, including PAGCOR licensing conditions, Anti-Money Laundering Act obligations, tax reporting requirements, and law enforcement requests made through lawful process.
• Legitimate Interest: Processing for fraud prevention, platform security, abuse detection, and aggregated analytics, where such processing is proportionate and does not override your data protection rights.
• Consent: Processing for marketing communications and optional features, where we have obtained your explicit consent. You may withdraw consent for marketing at any time by updating your communication preferences in account settings or by contacting support.

11jl shares personal data with third parties only in the circumstances described below, and only to the extent necessary for the stated purpose:

• Payment Service Providers: GCash (GXI), PayMaya (Voyager Innovations), BPI, BDO, and Metrobank, for the purpose of processing deposits and withdrawals. These providers are independently regulated financial institutions subject to Bangko Sentral ng Pilipinas (BSP) oversight.
• KYC & Identity Verification Providers: Certified third-party identity verification services engaged to process document verification and biometric checks as part of PAGCOR-mandated KYC procedures.
• Fraud Prevention & AML Services: Specialized platforms used to detect money laundering, suspicious betting patterns, and other fraudulent activities.
• PAGCOR: 11jl is required to provide player data and transaction records to PAGCOR upon request and in the format required by PAGCOR's reporting standards for licensed operators.
• Anti-Money Laundering Council (AMLC): In compliance with Republic Act No. 9160 (Anti-Money Laundering Act), 11jl may report covered and suspicious transactions to the AMLC as required by law.
• Law Enforcement: Where compelled by a valid court order, warrant, or other lawful legal process issued by a competent Philippine authority.
• Technology & Hosting Partners: Cloud infrastructure providers and software vendors who process data on 11jl's behalf under strict data processing agreements consistent with RA 10173 requirements.

All third parties with whom 11jl shares personal data are required to maintain appropriate technical and organizational security measures and to process such data only for the purposes for which it was shared. 11jl does not permit third-party processors to use your personal data for their own independent commercial purposes.

11jl uses cookies and similar browser technologies to operate the Platform and improve your experience. Cookies are small text files stored on your device by your browser when you visit 11jl.asia. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies that keep you logged in during your visit and security tokens that protect against cross-site request forgery. These cannot be disabled without rendering the Platform non-functional.
• Functional Cookies: Remember your preferences, such as selected game lobby view, currency display settings, and language selections. Disabling these cookies will not prevent Platform access but may affect your experience.
• Analytics Cookies: Collect anonymized, aggregated data about how players navigate the Platform — which pages are visited most, where users drop off, and how long sessions last. This data is used internally to improve the Platform. 11jl does not use third-party advertising analytics.
• Session Cookies: Temporary cookies that expire when you close your browser. Used to maintain the continuity of your game session and cart state during a single visit.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from logging in to your 11jl account and using most Platform features. 11jl does not use cookies for third-party cross-site advertising tracking or retargeting.

11jl retains personal data for the minimum period necessary to fulfill the purposes for which it was collected, taking into account legal obligations that require specific retention periods under Philippine law.

• Account Data (active accounts): Retained for the duration of the active account relationship and for a period of five (5) years after account closure, in compliance with AMLA record-keeping requirements applicable to covered persons.
• KYC Documents: Retained for a minimum of five (5) years from the date of KYC verification or account closure, whichever is later, as required under Republic Act 9160 and PAGCOR licensing conditions.
• Financial Transaction Records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA record-keeping rules.
• Game Session Logs: Retained for up to three (3) years for dispute resolution purposes and RTP audit compliance.
• Support Communications: Retained for up to two (2) years from the date of the most recent interaction, for quality assurance and dispute resolution.
• Marketing Consent Records: Retained for as long as the consent is active, plus one (1) year after consent is withdrawn, to demonstrate compliance with consent-based processing requirements.

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymized, unless a valid legal basis requires further retention. Players may request earlier deletion of certain categories of data subject to the limitations in Section 9.

11jl implements a layered security architecture to protect your personal data from unauthorized access, disclosure, alteration, and destruction. Security measures include but are not limited to:

• Transport Encryption: All data transmitted between your device and 11jl's servers uses TLS 1.3 with 256-bit AES encryption — the same standard applied by Philippine commercial banks for internet banking;
• Password Security: Player passwords are hashed using bcrypt with a cost factor sufficient to resist brute-force attacks. 11jl staff cannot view or recover plaintext passwords;
• Access Controls: Internal access to personal data is granted on a strict need-to-know basis, with role-based permissions and mandatory multi-factor authentication for all staff with system access;
• Infrastructure Security: Platform servers are hosted in data centers with physical access controls, 24/7 monitoring, and redundant power and network systems;
• Two-Factor Authentication (2FA): Available to all 11jl account holders and strongly recommended. When enabled, a one-time SMS OTP to your registered Philippine mobile number is required at each new login;
• Session Management: Sessions are automatically invalidated after a period of inactivity. Each session uses a unique, cryptographically random token;
• Security Monitoring: Continuous automated monitoring for unusual login behavior, suspicious transactions, and unauthorized access attempts, with incident response protocols in place.

While 11jl employs industry-standard security practices, no internet-based platform can guarantee absolute security. You are responsible for maintaining the security of your own login credentials and device. If you suspect a security breach related to your 11jl account, contact support immediately via live chat.

As a data subject under the Philippine Data Privacy Act of 2012, you are entitled to the following rights with respect to your personal data held by 11jl. These rights are enforceable in accordance with the DPA's implementing rules and subject to the limitations described below.

To exercise any of these rights, submit a written request to 11jl's Data Protection Officer by emailing [email protected] with the subject line "Data Subject Rights Request — [Your Account Username]." Include your full name and the specific right you wish to exercise. 11jl will acknowledge receipt within five (5) business days and respond within thirty (30) calendar days. Identity verification may be required before your request is processed.

The 11jl Platform is strictly intended for adults aged 21 years or older, consistent with PAGCOR regulations governing real-money gambling in the Philippines. 11jl does not knowingly collect personal data from individuals under the age of 21 and does not permit persons under 21 to create or use a player account.

Age verification is conducted during account registration and is a prerequisite for withdrawal processing. If 11jl discovers or has reasonable grounds to believe that a player is under 21 years of age, the account will be immediately suspended, all gaming activities voided, and the account terminated. Any verified real-money deposits will be returned to the deposit source after required regulatory notifications are made.

If a parent or guardian has reason to believe their child under 21 has accessed the 11jl Platform, they should contact us immediately at [email protected]. 11jl will investigate and take all appropriate action, including notification to relevant authorities where required by law.

The 11jl Platform is operated primarily for the Philippine market. However, some of our third-party technology partners (hosting infrastructure, KYC providers, fraud detection services) may process data in data centers located outside the Philippines.

Where personal data is transferred to processors located outside the Philippines, 11jl takes all reasonable steps to ensure that such transfers comply with the requirements of the Data Privacy Act, including ensuring that recipient processors provide an adequate level of data protection through contractual safeguards consistent with NPC standards.

All international data processing arrangements are documented and maintained in 11jl's data processing register, which is available to the NPC upon request. If you have questions about specific international transfers involving your personal data, contact the Data Protection Officer.

11jl reserves the right to update this Privacy Policy from time to time to reflect changes in our data processing practices, legal obligations, or regulatory requirements. The effective date of the current version is displayed at the top of this page.

Material changes to this Policy — particularly those that affect your rights or the categories of data we collect — will be communicated to registered players via email to the address on record or through a prominent notice on the Platform at least fourteen (14) days before the changes take effect. Changes required immediately by law may be made without advance notice, in which case 11jl will notify players as promptly as possible.

Your continued use of the 11jl Platform after the effective date of any revised Privacy Policy constitutes your acknowledgement and, where applicable, your consent to the updated terms. If you do not accept any revised Policy, you may request account closure under Section 11.2 of the Terms and Conditions.

For any privacy-related inquiries, data subject rights requests, concerns about data processing, or reports of suspected data breaches, please contact 11jl's designated Data Protection Officer (DPO) through the following channels:

• Email (DPO): [email protected] — Subject line: "Privacy / DPO Inquiry"
• Live Chat: 24/7 Filipino-speaking support, accessible from within your 11jl account
• Response SLA: Acknowledgement within 5 business days; substantive response within 30 calendar days

If you are not satisfied with 11jl's response to a privacy inquiry or data rights request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines, the regulatory body responsible for enforcing the Data Privacy Act. The NPC accepts complaints through its official website and designated complaint channels.