ph11 Privacy Policy

1. Who We Are

The ph11 Platform is operated by the entity holding the relevant PAGCOR online gaming licence and is accessible at ph11.lat. For the purposes of the Philippine Data Privacy Act of 2012 (RA 10173), ph11 is the Personal Information Controller (PIC) in respect of the personal data of all registered players and site visitors.

Our designated Data Protection Officer (DPO) can be contacted at the email address listed in Section 15 of this Policy.

2. Scope of This Policy

This Privacy Policy applies to all personal data collected by ph11 in connection with:

• Your use of the ph11 website at ph11.lat and all sub-pages;
• The registration and maintenance of a ph11 player Account;
• Deposits, withdrawals, and all financial transactions conducted through ph11;
• Participation in Games, promotions, tournaments, and bonus programmes;
• Communications with ph11 customer support via live chat or email;
• Any other service or feature made available by ph11.

This Policy does not apply to third-party websites or services that may be referenced on ph11 — for example, links to PAGCOR information pages. Those third parties have their own privacy policies for which ph11 bears no responsibility.

3. Personal Data We Collect

The table below summarises the categories of personal data ph11 collects, together with specific examples:

ph11 does not collect sensitive personal information as defined under RA 10173 (e.g., health data, biometric data, political opinions) except where expressly required by PAGCOR regulations or applicable law.

4. How We Collect Your Data

4.1 Directly from You

The majority of personal data ph11 holds is provided directly by you — during account registration, KYC document upload, deposit or withdrawal requests, when contacting support, or when opting in to promotions.

4.2 Automatically

When you access ph11.lat, certain technical data is collected automatically through cookies, server logs, and similar technologies. This includes your IP address, device and browser information, pages visited, session duration, and referral source. This data is used for security, fraud prevention, and platform performance analysis.

4.3 From Third Parties

ph11 may receive data from the following third-party sources in limited circumstances:

• Payment Processors (GCash, Maya, banks): Transaction confirmation data and masked payment identifiers for reconciliation and AML purposes.
• Identity Verification Services: Results of automated document authenticity checks conducted as part of KYC.
• PAGCOR's Exclusion Registry: Information confirming whether a prospective player is subject to a gaming exclusion order.

5. Purposes of Processing

ph11 processes your personal data for the following purposes:

1. Account management: Creating, maintaining, and administering your ph11 player Account, including password reset and security notifications.
2. KYC and age verification: Verifying your identity and confirming that you meet the 21-year age minimum required under PAGCOR regulations.
3. Payment processing: Facilitating deposits via GCash, Maya, or Philippine bank transfer, and processing withdrawal requests to your registered payment method.
4. Game operation: Recording game sessions, resolving disputes, and ensuring the integrity of game outcomes.
5. AML and fraud prevention: Monitoring transactions and gaming behaviour for signs of money laundering, fraud, or Terms violations, as required by PAGCOR and Philippine AML law.
6. Responsible gaming: Monitoring for problem gambling indicators and administering self-exclusion, deposit limit, and cooling-off requests.
7. Customer support: Responding to your inquiries, resolving complaints, and maintaining records of support interactions.
8. Marketing (with consent): Sending promotional offers, bonus notifications, and newsletters to players who have opted in to receive such communications.
9. Legal compliance: Complying with PAGCOR reporting obligations, court orders, and any other applicable legal requirements.

6. Legal Bases for Processing

Under RA 10173, ph11 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our contract with you — i.e., operating your Account, processing payments, and delivering Games.
• Legal obligation: Processing required to comply with PAGCOR regulations, AML laws, KYC requirements, and other applicable Philippine law.
• Legitimate interests: Processing necessary for fraud prevention, platform security, and responsible gaming monitoring, where these interests are not overridden by your rights.
• Consent: Processing for direct marketing communications, to which you have explicitly opted in. You may withdraw consent at any time without affecting the lawfulness of prior processing.

7. Sharing Your Personal Data

ph11 does not sell your personal data. ph11 shares personal data with third parties only in the following circumstances:

• Payment processors: GCash (G-Xchange Inc.), Maya (PayMaya Philippines Inc.), and participating Philippine banks receive transaction data necessary to process deposits and withdrawals.
• KYC and identity verification providers: Third-party document verification services receive identity document images for authenticity checking. These providers are contractually bound by confidentiality and data protection obligations.
• Game providers: Game software providers (such as JILI Technology) receive session and bet data necessary to operate their games and resolve disputes.
• PAGCOR and regulatory authorities: ph11 is obligated to share player data, transaction records, and gaming activity data with PAGCOR and other competent Philippine authorities upon lawful request or as required by our licence conditions.
• Law enforcement: Where required by a valid court order, warrant, or other lawful demand from Philippine law enforcement or judicial authorities.
• IT and infrastructure providers: Cloud hosting and security service providers that process data on ph11's behalf under strict data processing agreements and confidentiality obligations.

All third-party processors engaged by ph11 are contractually required to process personal data solely for the specified purpose, to maintain adequate security measures, and to comply with applicable Philippine data protection law.

8. Cookies & Tracking Technologies

ph11.lat uses cookies and similar technologies to operate the Platform, maintain your login session, prevent fraud, and improve the user experience. The categories of cookies used are:

• Strictly Necessary Cookies: Essential for the Platform to function — session management, authentication tokens, security cookies. These cannot be disabled.
• Performance Cookies: Collect anonymous statistical data about how players interact with the Platform (page load times, error rates). Used to improve performance. No personally identifiable data is included.
• Functional Cookies: Remember your preferences such as language settings and game lobby filters to improve your experience on return visits.
• Security Cookies: Detect and prevent fraudulent account access, bot activity, and coordinated abuse of Platform features.

ph11 does not use third-party advertising cookies or cross-site tracking technologies for behavioural advertising purposes. You can manage cookie preferences through your browser settings, though disabling strictly necessary cookies may prevent the Platform from functioning correctly.

9. Data Retention

ph11 retains personal data for as long as is necessary for the purposes for which it was collected, subject to the following minimum retention periods driven by regulatory obligations:

• KYC and identity documents: Minimum 5 years from the date of Account closure, as required by PAGCOR AML regulations and applicable Philippine law.
• Financial transaction records: Minimum 5 years from the date of each transaction.
• Gaming activity records: Minimum 3 years from the date of each game session, or such longer period as PAGCOR may require.
• Customer support records: 2 years from the resolution of the relevant inquiry or complaint.
• Marketing preferences and opt-in records: For the duration of the marketing relationship plus 2 years after opt-out, for audit purposes.

Upon expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymised. Where data is anonymised, it may be retained indefinitely for statistical and analytical purposes.

10. Data Security

ph11 implements a layered security programme to protect personal data against unauthorised access, disclosure, alteration, and destruction. Key measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and ph11 servers;
• Encryption of sensitive data fields (including passwords and payment identifiers) at rest using industry-standard algorithms;
• Role-based access controls limiting employee access to personal data to those with a business need;
• Regular third-party penetration testing and security audits;
• Continuous 24/7 infrastructure monitoring with automated anomaly detection;
• Incident response procedures including mandatory breach notification to the National Privacy Commission (NPC) within 72 hours of discovery of a notifiable personal data breach.

While ph11 takes all reasonable precautions, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. You also have a responsibility to protect your Account credentials — use a strong password and enable two-factor OTP authentication.

11. Your Rights 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 ph11:

• Right to be Informed: The right to know what personal data ph11 collects and how it is processed — as described in this Policy.
• Right of Access: The right to request a copy of the personal data ph11 holds about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure / Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary, subject to ph11's legal retention obligations under PAGCOR regulations.
• Right to Object: The right to object to processing of your personal data for direct marketing purposes at any time, without charge.
• Right to Data Portability: The right to receive a structured, machine-readable copy of your personal data for transfer to another service provider where technically feasible.
• Right to Lodge a Complaint: The right to file a complaint with the Philippine National Privacy Commission (NPC) if you believe ph11 has processed your data in violation of RA 10173.

To exercise any of these rights, please contact ph11's Data Protection Officer using the details in Section 15. ph11 will respond to verified requests within 15 business days. Some requests may be subject to identity verification before processing.

12. Children's Privacy

ph11's services are strictly restricted to individuals aged 21 years and above. ph11 does not knowingly collect personal data from any person under 21 years of age. If ph11 discovers that personal data has been collected from an underage individual, the relevant Account will be immediately suspended and all collected personal data will be deleted, subject to any overriding regulatory retention obligation.

If you believe that ph11 may have inadvertently collected personal data from a person under 21, please contact the DPO immediately at the contact details in Section 15.

13. Cross-Border Data Transfers

ph11's primary data processing infrastructure is located within or proximate to the Philippines. Where personal data is transferred to service providers located outside the Philippines (for example, certain cloud infrastructure providers), ph11 ensures that such transfers are conducted in accordance with RA 10173's rules on cross-border data transfers, including ensuring that the receiving entity provides a level of protection at least equivalent to the standards required by Philippine law, through contractual clauses or other approved transfer mechanisms.

14. Changes to This Privacy Policy

ph11 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or PAGCOR requirements. When material changes are made, ph11 will update the "Last Updated" date at the top of this page and, where practicable, notify affected players via their registered email address or via a notice on the Platform at login.

Continued use of ph11 following the posting of an updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with any changes, you should stop using the Platform and request Account closure.

15. Contact & Data Protection Officer

For all privacy-related inquiries, data subject access requests, or to contact ph11's Data Protection Officer, please use the following channels:

• Data Protection Officer: ph11 DPO
• Email: support@ph11.lat — please use the subject line "Privacy / DPO Request"
• Live Chat: Available 24/7 at ph11.lat — ask to be connected to the data privacy team
• Response Time: ph11 targets a response to all privacy requests within 5 business days of receipt

If you are not satisfied with ph11's response to your privacy concern, you have the right to file a complaint directly with the National Privacy Commission of the Philippines (NPC) via its official channels.