Privacy Policy

1. Introduction

11jili ("the Company", "we", "us", "our") is committed to protecting the privacy and personal data of all users of the 11jili online gaming platform. This Privacy Policy describes how we collect, use, store, share, and protect personal information in connection with your use of the 11jili website and services.

This Privacy Policy is issued in compliance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) and its Implementing Rules and Regulations, as administered by the National Privacy Commission (NPC) of the Philippines. It also reflects our obligations under applicable anti-money laundering regulations and PAGCOR licensing requirements.

We encourage all 11jili players to read this policy carefully. If you have questions about how your data is handled, our Data Protection Officer can be reached via the contact details provided in Section 14 of this policy.

2. Personal Data We Collect

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

2.1 Identity and Contact Information

• Full legal name
• Date of birth
• Gender
• Nationality
• Email address
• Philippine mobile number
• Residential address (including city, province, and postal code)

2.2 Identity Verification Documents

• Government-issued identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence, UMID)
• Proof of address documents
• Selfie or facial image for identity verification purposes
• Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account)

2.3 Financial Information

• Payment method details (GCash number, PayMaya number, bank account details)
• Transaction history (deposits, withdrawals, wagers, winnings)
• Source of funds declarations where required by anti-money laundering regulations

2.4 Gaming Activity Data

• Game history and session logs
• Betting patterns and wagering behaviour
• Bonus and promotion usage
• Responsible gaming tool settings (deposit limits, self-exclusion status)

2.5 Technical and Device Data

• IP address and approximate geolocation
• Device type, operating system, and browser information
• Session timestamps and duration
• Cookie identifiers and similar tracking technologies
• Referring URL and navigation path within the 11jili platform

2.6 Communications Data

• Records of your communications with 11jili customer support (live chat transcripts, email correspondence)
• Feedback, complaints, and dispute records
• Marketing preferences and opt-in/opt-out records

3. How We Collect Your Data

11jili collects personal data through the following means:

• Direct submission: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in promotions.
• Automated collection: Technical and device data collected automatically when you access the 11jili platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from accredited KYC and anti-fraud service providers; payment data from payment processors such as GCash, PayMaya, BPI, BDO, and Metrobank; fraud and risk data from industry databases where permitted by law.
• Regulatory sources: Information received from PAGCOR or other regulatory authorities in connection with our licensing obligations.

4. How We Use Your Personal Data

11jili uses the personal data we collect for the following purposes:

Purpose	Data Used
Account registration and management	Identity, contact, and verification data
Processing deposits and withdrawals	Financial and identity data
Providing gaming services	Gaming activity and technical data
Identity verification (KYC)	Identity documents and facial images
Anti-money laundering compliance	Financial and identity data
Fraud detection and prevention	Technical, financial, and gaming data
Responsible gaming monitoring	Gaming activity and account data
Customer support	Communications and account data
Marketing communications (with consent)	Contact and preference data
Platform improvement and analytics	Technical and gaming activity data (anonymised where possible)
Legal and regulatory compliance	All categories as required

11jili 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 permitted by applicable law.

5. Legal Basis for Processing

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

• Contractual necessity: Processing required to fulfil our obligations under the player account agreement, including account management, payment processing, and provision of gaming services.
• Legal obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering obligations, PAGCOR licensing requirements, and tax reporting obligations.
• Legitimate interests: Processing necessary for fraud prevention, platform security, responsible gaming monitoring, and improving our services, where these interests are not overridden by your rights and freedoms.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit, informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Sharing Your Personal Data

11jili does not sell, rent, or trade your personal data to third parties. We may share your data with the following categories of recipients only where necessary and in accordance with applicable law:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers, solely to process your deposits and withdrawals.
• Identity verification providers: Accredited KYC and anti-fraud service providers engaged to verify your identity and prevent fraud.
• Game software providers: Third-party game developers and live casino operators whose games are available on the 11jili platform, to the extent necessary to provide those games.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities, where required by law or regulatory obligation.
• Legal and professional advisers: Lawyers, auditors, and other professional advisers engaged by 11jili, subject to strict confidentiality obligations.
• Law enforcement: Philippine law enforcement agencies where required by a valid legal order or where disclosure is necessary to prevent or investigate criminal activity.

All third parties with whom 11jili shares personal data are required to handle that data in accordance with applicable privacy laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

7. Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device when you visit the 11jili website. They allow the platform to recognise your device, remember your preferences, and provide a more personalised experience. 11jili also uses similar technologies such as web beacons, pixel tags, and local storage objects.

7.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the operation of the 11jili platform, including maintaining your login session and enabling secure transactions. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and responsible gaming tool configurations.
• Analytics cookies: Collect anonymised data about how players use the 11jili platform to help us improve performance and user experience.
• Marketing cookies: Used to deliver relevant promotional content to you, with your consent. You may opt out of marketing cookies at any time through your account settings.

7.3 Managing Cookies

You can control non-essential cookies through your browser settings or through the cookie preference centre available on the 11jili platform. Please note that disabling certain cookies may affect the functionality of the platform.

8. Data Retention

11jili retains personal data for the following periods, after which data is securely deleted or irreversibly anonymised:

• Account data: For the duration of your account and for a minimum of five (5) years following account closure, in accordance with anti-money laundering regulations.
• Transaction records: A minimum of five (5) years from the date of the transaction, as required by the Anti-Money Laundering Act of the Philippines.
• KYC documents: For the duration of your account and five (5) years after closure, or longer if required by a regulatory investigation.
• Customer support records: Three (3) years from the date of the last interaction, unless a longer period is required for dispute resolution or legal proceedings.
• Marketing data: Until you withdraw consent or opt out of marketing communications, whichever is earlier.
• Technical logs: Up to twelve (12) months, unless retained longer for security investigation purposes.

Where 11jili is required by law to retain data for a longer period, the statutory retention period will apply. We will notify you if a change in law affects the retention of your personal data.

9. Data Security

11jili implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 11jili platform;
• Encryption at rest for sensitive personal and financial data stored on our servers;
• Two-factor authentication (2FA) available for all player accounts;
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis;
• Regular security audits and penetration testing conducted by independent third-party security specialists;
• Intrusion detection systems and 24/7 security monitoring;
• Staff training on data protection and privacy obligations.

Despite these measures, no online platform can guarantee absolute security. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 11jili 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 Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 11jili:

• Right to be informed: The right to know what personal data 11jili collects about you and how it is used — which is the purpose of this Privacy Policy.
• Right of access: The right to request a copy of the personal data 11jili holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our 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, machine-readable format.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. We will respond to all valid requests within thirty (30) days. In complex cases, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reason for it.

Please note that certain rights are subject to limitations. For example, we may be unable to delete data that we are legally required to retain, or data that is necessary to defend against a legal claim.

11. Children's Privacy

If 11jili becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account on the 11jili platform, please contact our support team immediately.

Parents and guardians are encouraged to use parental control tools and to monitor the online activities of minors in their care to prevent access to gambling platforms.

12. International Data Transfers

The 11jili platform primarily processes and stores personal data within the Philippines. In certain circumstances, personal data may be transferred to or accessed from locations outside the Philippines — for example, where we use cloud infrastructure providers or game software partners with servers in other jurisdictions.

Where such transfers occur, 11jili ensures that appropriate safeguards are in place to protect your personal data, including contractual data protection clauses that meet the standards required by the Philippine Data Privacy Act of 2012. We will not transfer your personal data to a jurisdiction that does not provide an adequate level of data protection without first implementing appropriate safeguards and, where required, obtaining your consent.

13. Updates to This Privacy Policy

11jili may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes, we will notify registered players by email or through an on-platform notification, and we will update the effective date at the top of this page.

We encourage you to review this Privacy Policy periodically. Your continued use of the 11jili platform after the effective date of any update constitutes your acceptance of the revised policy. If you do not agree with the updated policy, you should cease using the platform and may request closure of your account.

14. Contact Our Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 11jili, please contact our Data Protection Officer:

• Live Chat: Available 24/7 via the 11jili platform — the fastest way to reach us
• Email: [email protected]
• Response Time: We aim to respond to all privacy-related enquiries within 5 business days

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about how to do so is available on the NPC's official website.