Privacy Policy — 11ph.com Casino Platform

11ph.com ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all registered players and visitors to the 11ph.com online casino platform. This Privacy Policy has been prepared in accordance with the requirements of the Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the relevant issuances of the National Privacy Commission (NPC) of the Philippines.

This policy describes in detail the categories of personal data we collect from you, the purposes for which that data is processed, the legal bases on which we rely to process it, the circumstances under which we may share it with third parties, the period for which we retain it, and the rights you have in relation to your personal data. We encourage you to read this policy carefully and in full.

This Privacy Policy should be read alongside the 11ph.com Terms & Conditions, which govern your use of the Platform more broadly. In the event of any conflict between this Privacy Policy and the Terms & Conditions on a data privacy matter, this Privacy Policy shall prevail.

For the purposes of the Data Privacy Act of 2012 and its Implementing Rules and Regulations, 11ph.com is the Personal Information Controller in respect of the personal data collected and processed through the Platform. This means that 11ph.com determines the purposes and means of processing your personal data.

Where 11ph.com engages third-party service providers to process personal data on its behalf — for example, payment processors, identity verification providers, or analytics platforms — those third parties act as Personal Information Processors and are contractually bound to process your data only in accordance with 11ph.com's instructions and in compliance with applicable Philippine data protection law.

If you have any questions about how 11ph.com processes your personal data, or if you wish to exercise any of your data rights, please contact our Data Protection Officer using the details provided in Section 14 of this policy.

11ph.com collects the following categories of personal data from players and platform visitors. We collect only what is necessary for the purposes described in this policy.

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

• Directly from you: When you register an account on 11ph.com, complete identity verification, make a deposit or withdrawal, contact our support team, respond to a survey, or otherwise interact with the Platform, you provide personal data to us directly.
• Automatically: When you visit the 11ph.com website or use the Platform, certain technical and usage data is collected automatically through cookies, web beacons, server logs, and similar tracking technologies. This data helps us understand how the Platform is being used and to improve the user experience.
• From third parties: We may receive personal data about you from third-party identity verification providers, payment processors (such as GCash, Maya, or your bank), fraud prevention services, and analytics providers. We only receive data from third parties where we have a legitimate purpose for doing so and where the third party is authorized to share that data with us.
• From publicly available sources: In limited circumstances, we may supplement the data you provide with information from publicly available sources, such as public records or regulatory databases, for the purposes of identity verification or fraud prevention.

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

• Account Management: To create, maintain, and administer your 11ph.com player account, including processing your registration, verifying your identity, and managing your account settings and preferences.
• Service Delivery: To provide you with access to the games, features, and services available on the 11ph.com Platform, including processing deposits and withdrawals, crediting bonuses, and maintaining your gaming history.
• Identity Verification (KYC): To verify your identity and age in compliance with PAGCOR regulations and applicable anti-money laundering laws. This includes verifying that you are at least 21 years of age and that you are physically located in the Philippines.
• Fraud Prevention and Security: To detect, investigate, and prevent fraudulent transactions, money laundering, account takeovers, and other illegal or unauthorized activities on the Platform.
• Regulatory Compliance: To comply with our legal and regulatory obligations, including reporting requirements under Philippine anti-money laundering laws and PAGCOR licensing conditions.
• Customer Support: To respond to your inquiries, resolve complaints, and provide technical assistance through our live chat and email support channels.
• Responsible Gaming: To monitor gaming patterns and identify players who may be exhibiting signs of problem gambling, and to administer responsible gaming tools such as deposit limits, session reminders, and self-exclusion requests.
• Platform Improvement: To analyze usage patterns, conduct research, and improve the functionality, performance, and content of the 11ph.com Platform.
• Marketing Communications: To send you promotional offers, bonus notifications, and other marketing communications where you have consented to receive them. You may withdraw your consent to marketing communications at any time by contacting support or using the unsubscribe function in any marketing email.
• Legal Claims: To establish, exercise, or defend legal claims in connection with the Platform or your use of it.

Under the Data Privacy Act of 2012, 11ph.com must have a lawful basis for processing your personal data. The legal bases on which we rely are as follows:

• Contractual Necessity: Processing that is necessary for the performance of our contract with you — i.e., the Terms & Conditions — including account management, service delivery, and transaction processing.
• Legal Obligation: Processing that is required to comply with our legal and regulatory obligations, including KYC/AML requirements, PAGCOR licensing conditions, and tax reporting obligations.
• Legitimate Interests: Processing that is necessary for the legitimate interests of 11ph.com, provided those interests are not overridden by your rights and interests. This includes fraud prevention, platform security, responsible gaming monitoring, and platform improvement activities.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent. This applies primarily to marketing communications and the use of non-essential cookies. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before withdrawal.

11ph.com does not sell your personal data. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and only to the extent necessary for the stated purpose:

• Payment Processors: GCash, Maya, and Philippine banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) receive the financial data necessary to process your deposits and withdrawals. These providers are bound by their own privacy policies and applicable Philippine financial regulations.
• Identity Verification Providers: Third-party KYC and age verification service providers who assist us in verifying your identity and age in compliance with PAGCOR requirements and anti-money laundering regulations.
• Fraud Prevention Services: Specialist fraud detection and prevention providers who help us identify and prevent fraudulent activity on the Platform.
• IT and Infrastructure Providers: Cloud hosting, data storage, and cybersecurity service providers who support the technical operation of the 11ph.com Platform. These providers act as Personal Information Processors under our instruction and are contractually bound to maintain appropriate security standards.
• Regulatory and Law Enforcement Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or in response to a lawful request.
• Legal and Professional Advisors: Lawyers, auditors, and other professional advisors engaged by 11ph.com in connection with legal proceedings, regulatory matters, or business operations, subject to professional confidentiality obligations.

11ph.com uses cookies and similar tracking technologies to operate the Platform, analyze usage, and deliver a personalized experience. A cookie is a small text file placed on your device when you visit a website. The following categories of cookies are used on 11ph.com:

• Strictly Necessary Cookies: These cookies are essential for the Platform to function correctly. They enable core features such as session management, security, and account authentication. These cookies cannot be disabled without significantly impairing your ability to use the Platform.
• Performance and Analytics Cookies: These cookies collect anonymized information about how visitors use the Platform — such as which pages are visited most frequently and whether error messages are received — to help us improve the Platform's performance and user experience.
• Functional Cookies: These cookies allow the Platform to remember your preferences and settings, such as your preferred language or display options, to provide a more personalized experience.
• Marketing Cookies: These cookies are used to deliver promotional content and offers that are relevant to your interests, based on your browsing and gaming activity on the Platform. Marketing cookies are only placed with your consent.

You can manage your cookie preferences through your browser settings. Please note that disabling certain categories of cookies may affect the functionality of the Platform. For more information on managing cookies, refer to your browser's help documentation.

11ph.com retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law and regulation. The following general retention periods apply:

• Account Data: Retained for the duration of your account and for a period of five (5) years following account closure, in accordance with PAGCOR licensing requirements and applicable anti-money laundering regulations.
• Transaction and Financial Data: Retained for a minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of 2001 (Republic Act No. 9160, as amended) and its implementing regulations.
• KYC and Identity Verification Documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction, whichever is later.
• Gaming History: Retained for five (5) years from the date of the relevant gaming activity, for regulatory compliance and dispute resolution purposes.
• Support Communications: Retained for two (2) years from the date of the communication, unless a longer retention period is required in connection with an ongoing dispute or legal proceeding.
• Marketing Data: Retained until you withdraw your consent to marketing communications, after which it will be deleted or anonymized within a reasonable period.

Upon expiry of the applicable retention period, personal data will be securely deleted or anonymized in accordance with 11ph.com's data disposal procedures. Where data is anonymized rather than deleted, the anonymized data may be retained indefinitely for statistical and analytical purposes, as it can no longer be linked to any identifiable individual.

Under the Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 11ph.com. These rights are subject to certain legal limitations and exceptions, which will be communicated to you if applicable when you make a request.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. We will respond to all valid data rights requests within fifteen (15) business days of receipt, in accordance with NPC guidelines. We may need to verify your identity before processing your request.

11ph.com implements a comprehensive set of technical and organizational security measures designed to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. These measures include, but are not limited to:

• Encryption: All data transmitted between your device and the 11ph.com Platform is encrypted using SSL/TLS protocols. Sensitive data stored on our servers is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data is strictly limited to authorized 11ph.com personnel and service providers who require it to perform their functions. All access is logged and subject to regular audit.
• Network Security: Our infrastructure is protected by firewalls, intrusion detection systems, and continuous security monitoring. We conduct regular vulnerability assessments and penetration testing.
• Incident Response: 11ph.com maintains a documented data breach response procedure. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, we will notify the National Privacy Commission and affected individuals in accordance with the timeframes prescribed by the Data Privacy Act.
• Staff Training: All 11ph.com personnel with access to personal data receive regular data protection training and are bound by confidentiality obligations.

While 11ph.com takes all reasonable steps to protect your personal data, no method of transmission over the internet or method of electronic storage is completely secure. You also play an important role in keeping your data safe — please ensure that your 11ph.com login credentials are kept confidential and that you use a strong, unique password for your account.

The 11ph.com Platform is strictly intended for adults aged 21 years and above, in accordance with Philippine law and PAGCOR regulations. 11ph.com does not knowingly collect personal data from individuals under the age of 21.

If we become aware that we have inadvertently collected personal data from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. All balances in any account found to belong to an underage individual will be forfeited in accordance with our Terms & Conditions.

If you are a parent or guardian and believe that your child under the age of 21 has registered an account on 11ph.com or provided personal data to us, please contact our support team immediately so that we can take appropriate action.

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. When we make material changes to this policy, we will notify registered players by email and/or by posting a prominent notice on the Platform prior to the changes taking effect.

The "Last Updated" date at the top of this policy indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically to stay informed about how 11ph.com is protecting your personal data. Your continued use of the Platform following the effective date of any changes constitutes your acknowledgment of the revised policy.

If you do not agree with any changes to this Privacy Policy, you should discontinue your use of the Platform and may request account closure by contacting our support team.

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 11ph.com processes your personal data, please contact our Data Protection Officer through the following channels:

• Email: privacy@11phcom.org — for data rights requests, privacy inquiries, and formal data protection complaints.
• General Support Email: support@11phcom.org
• Live Chat: Available 24/7 directly on the 11ph.com Platform for general privacy questions and account-related data requests.

We will acknowledge all privacy-related inquiries within three (3) business days and aim to resolve them fully within fifteen (15) business days. For complex requests, we may require additional time, in which case we will keep you informed of progress.

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines. The NPC is the independent regulatory body responsible for enforcing the Data Privacy Act of 2012. Information on how to file a complaint with the NPC is available on the NPC's official website.