Privacy Policy – 11ph com

1. About This Policy

11ph com is committed to protecting the personal data of all users who access and use our online gaming platform. This Privacy Policy has been prepared in compliance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 of the Philippines, and its Implementing Rules and Regulations issued by the National Privacy Commission (NPC).

This policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal information. It applies to all data subjects — meaning any individual whose personal data is processed by 11ph com — including registered players, visitors to our website, and individuals who contact our support team.

We encourage you to read this Privacy Policy in full. If you have questions about any section, please contact our Data Protection Officer (DPO) using the details provided in Section 14.

2. Personal Data We Collect

Depending on how you interact with the 11ph com platform, we may collect the following categories of personal data:

2.1 Identity & Contact Information

• Full legal name as it appears on a government-issued ID;
• Date of birth (used to verify the 21+ age requirement);
• Nationality and country of residence;
• Email address and mobile phone number;
• Residential address (barangay, city/municipality, province, ZIP code).

2.2 Identity Verification (KYC) Documents

• Copies of government-issued photo identification (e.g., Philippine passport, PhilSys National ID, SSS ID, UMID, driver's license, PRC ID, voter's ID);
• Proof of address documents (e.g., utility bill, bank statement, barangay certificate);
• Selfie or liveness check images submitted during verification.

2.3 Financial Information

• Payment method details (e.g., GCash mobile number, PayMaya account reference, bank account name and number for BPI, BDO, or Metrobank);
• Transaction history including deposits, withdrawals, and bonus credits;
• Source of funds declarations where required by AML regulations.

2.4 Gaming Activity Data

• Game session logs, bet amounts, win/loss records, and game preferences;
• Responsible gaming settings including deposit limits and self-exclusion status;
• Bonus and promotion participation history.

2.5 Technical & Device Data

• IP address and approximate geolocation;
• Device type, operating system, and browser version;
• Session timestamps, page views, and click-stream data;
• Cookie identifiers and similar tracking technologies (see Section 7).

2.6 Communications Data

• Records of live chat conversations, email correspondence, and support tickets submitted to 11ph com;
• Feedback, survey responses, and promotional opt-in preferences.

3. How We Collect Your Data

11ph com collects personal data through the following means:

• Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or participate in a promotion;
• Automatically — through cookies, web beacons, and server logs when you browse or interact with the 11ph com website or mobile interface;
• From third parties — including identity verification service providers, payment processors (GCash, PayMaya, BPI, BDO, Metrobank), fraud detection services, and analytics providers, where permitted by law and necessary for the operation of the platform;
• From public sources — such as publicly available government databases, where necessary for AML compliance or fraud prevention.

4. How We Use Your Personal Data

11ph com uses the personal data we collect for the following purposes:

We do not use your personal data for automated decision-making that produces legal or similarly significant effects without human review, except where required by law or where you have given explicit consent.

5. Legal Basis for Processing

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

• Contractual necessity — processing required to fulfill 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 AML regulations, PAGCOR requirements, and NPC directives;
• Legitimate interests — processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where such interests are not overridden by your rights;
• Consent — processing for marketing communications and non-essential cookies, where you have provided clear and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing & Disclosure

11ph com does not sell, rent, or trade your personal data to third parties for their own marketing purposes. We may share your data with the following categories of recipients, strictly on a need-to-know basis:

• Identity verification providers — to conduct KYC checks as required by law;
• Payment processors — including GCash, PayMaya, BPI, BDO, and Metrobank, to process your financial transactions;
• Game software providers — who supply the games available on the 11ph com platform and may receive anonymized session data for technical purposes;
• Fraud prevention and security services — to detect and prevent unauthorized access, cheating, and financial crime;
• Regulatory and law enforcement authorities — including PAGCOR and the Anti-Money Laundering Council (AMLC), where disclosure is required by law or court order;
• Professional advisers — including lawyers, auditors, and accountants, under strict confidentiality obligations;
• Business successors — in the event of a merger, acquisition, or sale of assets, subject to the same privacy protections.

All third-party service providers engaged by 11ph com are contractually required to process personal data only in accordance with our instructions and applicable data protection law.

7. Cookies & Tracking Technologies

The 11ph com website uses cookies and similar tracking technologies to enhance your experience, maintain session security, and analyze platform usage. The types of cookies we use include:

• Strictly necessary cookies — essential for the platform to function, including session authentication and security tokens. These cannot be disabled;
• Functional cookies — used to remember your preferences such as language settings and responsible gaming limits;
• Analytics cookies — used to understand how players interact with the platform, helping us improve performance and user experience. Data collected is aggregated and anonymized where possible;
• Marketing cookies — used to deliver relevant promotional content. These are only set with your explicit consent.

8. Data Retention

11ph com retains your personal data only for as long as necessary to fulfill the purposes for which it was collected, or as required by applicable law. Our general retention periods are as follows:

• Account and KYC data — retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AML regulations;
• Transaction records — retained for a minimum of five (5) years from the date of the transaction;
• Gaming activity logs — retained for three (3) years from the date of the session;
• Support communications — retained for two (2) years from the date of the last interaction;
• Marketing consent records — retained until consent is withdrawn, plus one (1) year thereafter as evidence of consent.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymized in accordance with our data disposal procedures.

9. Data Security

11ph com 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:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers;
• Encryption of sensitive data at rest, including financial information and identity documents;
• Role-based access controls ensuring that only authorized personnel can access personal data on a need-to-know basis;
• Regular security audits, vulnerability assessments, and penetration testing;
• Multi-factor authentication (MFA) for internal system access;
• Incident response procedures to detect, contain, and report data breaches in accordance with NPC requirements.

While we take all reasonable steps to protect your data, no method of electronic transmission or storage is 100% secure. You are responsible for maintaining the confidentiality of your 11ph com login credentials and for notifying us immediately if you suspect unauthorized access to your account.

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 11ph com:

• Right to be informed — you have the right to know how your personal data is being collected and processed, which this Privacy Policy fulfills;
• Right of access — you may request a copy of the personal data we hold about you at any time;
• Right to rectification — you may request correction of inaccurate or incomplete personal data;
• Right to erasure — you may request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to our legal retention obligations;
• Right to object — you may object to processing based on legitimate interests or for direct marketing purposes;
• Right to data portability — you may request a copy of your data in a structured, commonly used, machine-readable format;
• Right to lodge a complaint — you have the right to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

11. Children's Privacy

The 11ph com platform is strictly intended for adults aged 21 years and above, in accordance with Philippine gaming regulations. We do not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been submitted by a person under 21, we will immediately suspend the associated account, delete the data, and report the incident as required by applicable law.

If you are a parent or guardian and believe that a minor has registered on the 11ph com platform, please contact us immediately using the details in Section 14 so we can take prompt action.

12. Third-Party Links

The 11ph com website may contain links to third-party game providers or payment service interfaces. Once you leave the 11ph com platform and access a third-party service, this Privacy Policy no longer applies. We encourage you to review the privacy policies of any third-party services you use in connection with your 11ph com account. 11ph com is not responsible for the privacy practices or content of third-party websites or services.

13. Changes to This Privacy Policy

11ph com reserves the right to update or modify this Privacy Policy at any time. When we make material changes, we will update the "Last Updated" date at the top of this page and, where appropriate, notify registered players via email or an in-platform notification.

Your continued use of the 11ph com platform after any changes to this Privacy Policy constitutes your acknowledgment of the updated policy. We recommend reviewing this page periodically to stay informed about how we protect your personal data.

14. Contact Us & Data Protection Officer

11ph com has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data, please contact us through the following channels:

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have not been adequately addressed by 11ph com.