11jll Privacy Policy – How We Handle Your Personal Data

1. Introduction

This Privacy Policy describes how 11jll ("we", "us", "the Platform") collects, uses, stores, and protects personal data relating to registered members and visitors to the 11jll website and app ("you"). The Platform operates as an online gaming service for users in the Philippines.

By registering an account or using the 11jll platform, you acknowledge that you have read and understood this Privacy Policy and that you consent to the collection and use of your data as described here. If you do not agree, you should not use the platform.

This policy applies to all personal data collected through your use of 11jll, including registration, account activity, deposits, withdrawals, gameplay, and any communications with our support team.

2. Data We Collect

The types of personal data 11jll may collect include:

We do not collect sensitive personal data beyond what is required for identity verification and compliance. We do not store complete payment card numbers.

3. How We Use Your Data

11jll uses your personal data for the following purposes:

• To create and manage your account, including identity verification (KYC) and ongoing account security.
• To process deposits and withdrawals in Philippine Peso via your selected payment method.
• To operate game functions, record results, and calculate winnings accurately.
• To administer the VIP Club and any applicable bonus or promotion offers.
• To provide customer support and respond to your queries.
• To detect and prevent fraud, money laundering, and other prohibited activities.
• To comply with applicable laws, regulations, and reporting obligations.
• To send account-related notifications such as transaction confirmations, security alerts, and policy updates.
• To send promotional communications where you have given consent — you can withdraw this consent at any time.
• To analyse platform usage and improve the member experience over time.

We do not use your personal data for automated decision-making that produces significant legal effects without human review.

4. Legal Basis for Processing

Where required, our processing of your personal data is based on one or more of the following grounds:

• Contract performance — processing necessary to provide the services you signed up for, including account management, gameplay, and payments.
• Legal obligation — processing required to comply with applicable laws, including identity verification, anti-money laundering checks, and record-keeping requirements.
• Legitimate interests — processing for fraud prevention, platform security, and improving our services, where these interests are not overridden by your rights.
• Consent — where you have given explicit consent, such as for receiving promotional communications.

5. Sharing Your Data

11jll does not sell your personal data to third parties. We may share your data in the following limited circumstances:

• Payment processors — to facilitate deposits and withdrawals through your chosen Philippine payment method, including local bank transfer and e-wallet providers.
• Identity verification providers — to complete KYC checks required for account verification and withdrawal processing.
• Technology service providers — companies that provide infrastructure, hosting, security, or analytics services to 11jll, under strict data processing agreements.
• Legal and regulatory authorities — where required by applicable law, court order, or regulatory directive.

All third parties who process data on our behalf are required to handle it securely and only for the purposes for which it was shared.

6. Data Retention

We retain your personal data for as long as your account is active and for a period thereafter as required by applicable legal and regulatory obligations. Transaction and identity records are typically retained for a minimum period after account closure to comply with financial record-keeping requirements.

When data is no longer required for the purposes for which it was collected and retention is not required by law, it is securely deleted or anonymised.

If you request account closure, your account will be deactivated. Certain records will be retained for the legally required retention period even after closure.

7. Security

11jll implements technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or loss. These measures include:

• SSL/TLS encryption for all data transmitted between your device and the 11jll platform.
• OTP (one-time password) authentication for sensitive account actions.
• Access controls restricting personal data to authorised 11jll personnel with a legitimate need.
• Regular security assessments of platform infrastructure.

While we take these measures seriously, no online platform can guarantee absolute security. You are responsible for keeping your login credentials confidential and for notifying us immediately if you suspect unauthorised access to your account.

8. Cookies and Similar Technologies

11jll uses cookies and similar tracking technologies when you access the platform. Cookies are small data files stored on your device that help the platform function correctly and help us understand how you use it.

The types of cookies used include:

• Essential cookies — required for the platform to operate. These enable session management, login authentication, and security functions. They cannot be disabled without affecting platform functionality.
• Performance cookies — collect anonymised data about how members use the platform, such as pages visited and error messages. This helps us identify areas for improvement.
• Functional cookies — remember your preferences, such as language settings and game display options, to improve your experience on return visits.

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect how the platform works for you.

9. Your Data Rights

As a 11jll member, you have the following rights in relation to your personal data:

• Access — request a copy of the personal data we hold about you.
• Correction — request correction of inaccurate or incomplete information.
• Deletion — request erasure of your personal data, subject to legal retention requirements.
• Restriction — request that we limit processing of your data in certain circumstances.
• Objection — object to processing based on legitimate interests, including direct marketing.
• Portability — request your data in a structured, machine-readable format where technically feasible.
• Consent withdrawal — withdraw consent for processing based on consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, contact the 11jll support team. We will respond to verified requests within a reasonable timeframe. Identity verification may be required before processing certain requests.

10. Minors

The 11jll platform is strictly for persons aged 21 and above. We do not knowingly collect personal data from individuals under 21 years of age. If we become aware that data has been collected from a person under 21, that account will be immediately suspended and the data will be deleted.

If you believe a minor has registered on the platform, please contact support immediately so we can take appropriate action.

11. Changes to This Policy

11jll may update this Privacy Policy from time to time to reflect changes in our practices, platform features, or applicable law. Updates will be published on this page with a revised effective date. Where changes are material, we may notify you via your registered email address or through a platform notification.

Your continued use of the 11jll platform after any update constitutes your acceptance of the revised Privacy Policy.

12. Contact

If you have questions about this Privacy Policy, want to exercise a data right, or have a concern about how your data has been handled, please contact the 11jll support team. You can reach us through the live chat feature on the platform or by email at [email protected].

For general account and responsible gaming queries, see the FAQ and Responsible Gaming pages.