11php Privacy Policy

1.1 Data Controller: 11php ("11php," "we," "us," "our") is the data controller responsible for the personal information collected through the 11php online gaming platform, accessible at 11php.org and any related subdomain, mobile browser interface, or associated service.

1.2 11php operates its online gaming platform for the Philippine market under PAGCOR-guided compliance. 11php takes its obligations under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173) seriously and has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with data protection obligations.

1.3 Questions or concerns about your personal data may be directed to our DPO at any time. Contact details for the DPO are provided in Section 15 of this Privacy Policy.

11php collects the following categories of personal data from players and platform visitors:

11php collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal request, contacting our support team, or responding to surveys or promotions.
• Automated collection: Technical data (IP address, device identifiers, browser type, session data) collected automatically when you access or interact with the 11php platform via cookies and similar tracking technologies (see Section 7 for details).
• Third-party sources: Identity verification data received from licensed KYC verification service providers; payment confirmation data received from GCash, Maya, and other authorised payment processors; fraud screening data from licensed fraud prevention service providers.
• Platform activity: Game logs, transaction records, and account activity data generated automatically through your use of the 11php platform.

4.1 Account Management

We use your identity and contact data to create and maintain your 11php account, authenticate your identity at login, process password resets and security verifications, and communicate with you about your account status.

4.2 Payment Processing

Financial data is used to process deposits via GCash, Maya, and other accepted Philippine payment channels, to authenticate withdrawal requests, and to ensure that payments are made to the correct verified account. Payment data is also used to comply with anti-money-laundering (AML) obligations under Philippine law.

4.3 Legal and Regulatory Compliance

11php is legally required to collect and retain certain personal data to comply with: the Philippine Anti-Money Laundering Act (AMLA) and its amendments; PAGCOR licensing conditions and guidelines; the Philippine Data Privacy Act of 2012; and applicable tax and financial reporting obligations. Compliance-related data processing is mandatory and cannot be opted out of while your account remains active.

4.4 Security and Fraud Prevention

Technical data and gaming activity data are processed to detect and prevent unauthorised account access, identify suspicious transaction patterns, prevent money laundering and fraud, enforce our one-account-per-player policy, and protect the integrity of games and promotional programs.

4.5 Responsible Gaming

Gaming activity data, including session duration, frequency of play, deposit patterns, and use of responsible gaming tools, is monitored to identify potentially problematic gambling behaviour and to allow 11php to intervene proactively. See Section 12 for more detail on responsible gaming data processing.

4.6 Platform Improvement and Analytics

Aggregated and anonymised data derived from platform usage is used to improve game performance, optimise the user interface, and develop new features. This processing uses data that cannot be used to identify individual players.

4.7 Marketing Communications

Where you have opted in to marketing communications, 11php may use your contact data to send promotional offers, bonus notifications, and game updates via SMS or email. You may withdraw your marketing consent at any time through your account notification settings or by contacting support.

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

• Contractual necessity: Processing required to perform our obligations to you under the Terms & Conditions — including account management, payment processing, and game provision.
• Legal obligation: Processing required to comply with Philippine law, including AML/KYC obligations under AMLA, PAGCOR regulatory requirements, and tax reporting obligations.
• Legitimate interests: Processing for fraud prevention, platform security, responsible gaming monitoring, and aggregated analytics, where such interests are not overridden by your data protection rights.
• Consent: Processing for optional marketing communications, where you have provided explicit, freely given consent. Consent may be withdrawn at any time without affecting the lawfulness of processing prior to withdrawal.

11php does not sell your personal data. We share your data only with the following categories of recipients, and only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash (Globe Fintech Innovations), Maya (Voyager Innovations), and other licensed Philippine payment service providers — for the purpose of processing deposits and withdrawals.
• KYC and identity verification providers: Licensed identity verification service providers engaged by 11php to perform AML-compliant KYC checks on player accounts prior to withdrawal processing.
• Fraud prevention and security providers: Third-party fraud screening services used to detect suspicious account activity and protect the integrity of the platform.
• Game software providers: Where game providers operate their own servers, technical session data necessary to deliver game functionality may be transmitted to the relevant provider. Game providers operate under data processing agreements with 11php.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where 11php is legally required to disclose information.
• Professional advisers: Lawyers, auditors, and compliance consultants engaged by 11php under strict confidentiality obligations.

7.1 11php uses cookies and similar tracking technologies (including local storage and session tokens) to operate the platform, maintain your login session, remember your preferences, and analyse platform usage.

7.2 The following categories of cookies are used on 11php:

• Strictly necessary cookies: Essential for platform functionality, including authentication session cookies that keep you logged in. These cannot be disabled while using the platform.
• Functional cookies: Used to remember your preferences, such as language settings and responsible gaming configurations. These improve your experience but are not essential.
• Analytics cookies: Used to collect aggregated, anonymised data about how players use the platform, helping 11php identify areas for improvement. Analytics data is not linked to individual player identities.
• Security cookies: Used to detect and prevent fraudulent activity, including CSRF tokens and device fingerprinting data for login anomaly detection.

7.3 You may control non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 11php platform.

8.1 11php retains personal data for as long as is necessary to fulfil the purposes described in this Privacy Policy or as required by applicable Philippine law. The following retention periods apply as a general guide:

• Account data and KYC documents: Retained for a minimum of five (5) years from the date of account closure, as required by the Philippine Anti-Money Laundering Act.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction, in compliance with AMLA requirements.
• Gaming activity logs: Retained for three (3) years from the date of the activity, for the purposes of dispute resolution and responsible gaming monitoring.
• Technical and security logs: Retained for twelve (12) months from the date of generation, unless a security incident requires extended retention.
• Marketing consent records: Retained for the duration of your marketing opt-in status, plus one (1) year following any withdrawal of consent, for compliance evidence purposes.

8.2 Upon the expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with 11php's data disposal procedures.

9.1 11php implements a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, loss, destruction, or disclosure. Key security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and 11php's servers;
• AES-256 encryption for sensitive data at rest, including KYC documents and financial data;
• Multi-factor authentication for all 11php staff accessing player data in administrative systems;
• Role-based access controls limiting employee access to personal data to those with a specific operational need;
• Regular penetration testing and security audits of the 11php platform;
• Intrusion detection systems and 24/7 security monitoring;
• Secure, encrypted backup systems with geographic redundancy.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 11php will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay, as required by the Philippine Data Privacy Act.

As a data subject under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 11php. All rights requests should be submitted to our Data Protection Officer (see Section 15):

11php will respond to all rights requests within thirty (30) calendar days of receipt. Complex requests may require an extension, in which case you will be notified within the initial 30-day period.

11.1 The 11php platform is strictly intended for individuals aged 21 years and older. 11php does not knowingly collect personal data from individuals under the age of 21.

11.2 If 11php becomes aware that personal data has been collected from a person under the age of 21 without verifiable parental or guardian consent, that account will be immediately closed, all associated personal data will be deleted or anonymised in accordance with applicable law, and any balance will be handled per applicable regulatory procedures.

11.3 If you are a parent or guardian and believe that a minor in your care has registered an account on 11php, please contact our Data Protection Officer immediately using the details in Section 15 so that appropriate action can be taken without delay.

12.1 As part of its commitment to responsible gaming, 11php processes gaming activity data — including session length, frequency of play, deposit patterns, and use of responsible gaming tools — to identify indicators of potentially problematic gambling behaviour.

12.2 This processing is carried out in 11php's legitimate interest of protecting player welfare and complying with responsible gaming obligations under PAGCOR guidelines. Where problematic behaviour indicators are detected, 11php may take proactive steps including: contacting the player to offer support; temporarily restricting account activity; or applying cooling-off periods.

12.3 Self-exclusion requests and responsible gaming limit settings are recorded and stored to ensure that they are correctly enforced. Self-exclusion data is retained for the full duration of the exclusion period plus five (5) years following its expiry.

12.4 For full details on the responsible gaming tools available to 11php players, please visit our Responsible Gaming page.

13.1 Where 11php engages service providers (such as game software providers or cloud infrastructure providers) that process data outside the Philippines, 11php ensures that appropriate safeguards are in place in accordance with the Philippine Data Privacy Act and National Privacy Commission guidelines on cross-border data transfers.

13.2 Such safeguards include: contractual data processing agreements incorporating standard data protection clauses; ensuring that recipient countries provide an adequate level of protection for personal data as determined by the NPC; or obtaining your explicit consent where required.

13.3 Your core account data — including identity, financial, and KYC data — is stored on servers located in facilities serving the Philippine market. Where any transfer of such data outside the Philippines is necessary, you will be notified in advance.

14.1 11php may update this Privacy Policy from time to time to reflect changes in our data practices, updates to Philippine law, or changes to the 11php platform. The updated Policy will be published on this page with a revised effective date.

14.2 Where changes to this Privacy Policy are material — meaning they affect how we process your data in a way that may impact your rights — 11php will notify active players via email or via an on-platform notification prior to the changes taking effect.

14.3 Your continued use of the 11php platform following the publication of an updated Privacy Policy constitutes your acceptance of the updated version. If you do not accept the updated Policy, you must stop using the platform and request account closure.

If you wish to exercise any of your data rights, have questions about how 11php processes your personal data, or wish to make a privacy-related complaint, please contact our Data Protection Officer (DPO) using the following details:

• Data Protection Officer, 11php
• Email: [email protected] — use the subject line "Data Privacy Request" for all rights requests and privacy queries.
• Live Chat: Available 24/7 via the live chat function on the 11php platform. For formal DPO requests, please confirm your identity during the chat session.
• Response Time: 11php will acknowledge all DPO requests within 3 business days and will provide a substantive response within 30 calendar days.

If you are not satisfied with 11php's response to your data privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information on how to file a complaint is available on the NPC's official website.