Privacy Policy

1. Introduction and Scope

This Privacy Policy describes how 11ph2 ("we," "us," "our," or "the Operator") collects, uses, processes, stores, shares, and protects personal information obtained from users ("you," "your," or "User") of our online casino and sports betting platform accessible through the website 11ph2.cam and associated mobile applications (collectively, the "Platform"). This policy applies to all individuals who access or use the Platform, whether as registered members, guest visitors, or participants in promotional activities.

By accessing or using the 11ph2 Platform, you acknowledge that you have read, understood, and agree to the data collection and processing practices described in this Privacy Policy. If you do not agree with any aspect of this policy, you must immediately cease using the Platform and may request deletion of your personal data in accordance with your rights under Philippine law.

This Privacy Policy should be read in conjunction with our Terms and Conditions, which govern your use of the Platform. In the event of any conflict between this Privacy Policy and the Terms and Conditions, the Terms and Conditions shall prevail with respect to matters not specifically related to data privacy.

2. Data Controller and Contact Information

11ph2 acts as the data controller for all personal information collected through the Platform. As data controller, we determine the purposes and means of processing your personal data and are responsible for ensuring compliance with the Data Privacy Act of 2012 and implementing appropriate technical and organizational measures to protect your information.

If you have questions, concerns, or requests regarding this Privacy Policy or our data processing practices, you may contact our Data Protection Officer through the following channels:

• Email: [email protected]
• Subject Line: Please use "Data Privacy Inquiry" or "Data Subject Rights Request" for faster processing
• Response Time: We aim to respond to all privacy-related inquiries within ten (10) business days

3. Personal Information We Collect

11ph2 collects various categories of personal information necessary to provide gaming services, comply with legal obligations, prevent fraud, and improve user experience. The personal information we collect includes but is not limited to:

3.1 Information You Provide Directly

• Account Registration Data: Full legal name, date of birth, gender, residential address, mobile phone number, email address, username, password (stored in encrypted form), and security questions
• Identity Verification Documents: Government-issued identification (Philippine passport, driver's license, UMID, postal ID, or other PAGCOR-approved documents), photographs or scans of identification documents, selfies for facial verification, and proof of address documents (utility bills, bank statements)
• Financial Information: Payment method details (GCash account information, PayMaya account information, bank account numbers, credit/debit card information where applicable), transaction history, deposit and withdrawal records, and betting/gaming activity records
• Communication Data: Content of messages sent through customer support channels (live chat, email, phone), feedback and survey responses, correspondence with our support team, and any other information you voluntarily provide when contacting us

3.2 Information Collected Automatically

• Technical Data: IP address, device type and model, operating system, browser type and version, screen resolution, device identifiers (IMEI, advertising ID), mobile network information, and geographic location data (country, city, region based on IP address)
• Usage Data: Pages visited, time spent on pages, navigation paths, games played, bets placed, session duration, login/logout times, features accessed, search queries within the Platform, and interaction with promotional materials
• Cookies and Tracking Technologies: Session cookies, persistent cookies, analytics cookies, advertising cookies, pixel tags, and local storage data

3.3 Information from Third Parties

• Payment Processors: Transaction confirmation data from GCash, PayMaya, and banking partners
• Identity Verification Services: Validation results from third-party KYC (Know Your Customer) providers
• Game Providers: Gaming activity data, game outcomes, and RTP (Return to Player) statistics
• Fraud Prevention Services: Risk scores, device fingerprints, and behavioral analytics from security partners

4. How We Use Your Personal Information

11ph2 processes your personal information for the following legitimate purposes, in accordance with applicable data protection laws:

4.1 Service Provision and Account Management

• Creating, maintaining, and managing user accounts
• Processing registration and identity verification
• Authenticating users and preventing unauthorized access
• Processing deposits, withdrawals, and payment transactions
• Enabling participation in casino games, sports betting, and other gaming products
• Recording gaming activity and maintaining transaction histories
• Providing customer support and responding to inquiries
• Communicating account-related information and service updates

4.2 Legal and Regulatory Compliance

• Complying with PAGCOR licensing requirements and gaming regulations
• Fulfilling anti-money laundering (AML) and counter-terrorism financing obligations
• Verifying age eligibility and enforcing 21+ age restrictions
• Maintaining responsible gaming controls and self-exclusion registers
• Responding to lawful requests from government authorities, law enforcement, or courts
• Conducting internal audits and compliance monitoring
• Reporting suspicious transactions as required by law

4.3 Security and Fraud Prevention

• Detecting, preventing, and investigating fraudulent activity, money laundering, and terms violations
• Identifying duplicate accounts and preventing bonus abuse
• Monitoring for collusion, arbitrage betting, and unfair gaming practices
• Protecting the Platform from cyber attacks, hacking attempts, and security threats
• Maintaining platform integrity and protecting legitimate users from fraud

4.4 Marketing and Communications

• Sending promotional offers, bonuses, and special event notifications (with your consent)
• Personalizing marketing communications based on gaming preferences
• Conducting customer satisfaction surveys and market research
• Informing you about new games, features, and platform improvements
• Managing loyalty programs and VIP benefits

4.5 Platform Improvement and Analytics

• Analyzing usage patterns to improve user experience and interface design
• Testing new features and conducting A/B experiments
• Optimizing platform performance and load times
• Understanding user preferences to expand game offerings
• Generating aggregated statistics and reports for business intelligence

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 11ph2 must have a lawful basis for processing your personal information. We process your data based on the following legal grounds:

• Contractual Necessity: Processing required to fulfill our obligations under the Terms and Conditions you agreed to when registering
• Legal Obligation: Processing necessary to comply with PAGCOR regulations, AML laws, tax requirements, and other legal obligations
• Legitimate Interest: Processing necessary for fraud prevention, security, platform improvement, and business operations, balanced against your privacy rights
• Consent: Processing based on your explicit consent, particularly for marketing communications and non-essential cookies (which you may withdraw at any time)

6. Data Sharing and Disclosure

11ph2 does not sell, rent, or trade your personal information to third parties for their marketing purposes. However, we may share your information with the following categories of recipients for the purposes described in this policy:

All third-party service providers are required to maintain confidentiality and security of your personal information through contractual agreements. They may only use your data for the specific purposes for which it was shared and are prohibited from using it for their own purposes.

7. Data Security Measures

11ph2 implements comprehensive technical and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction:

• Encryption: All data transmission uses 256-bit SSL/TLS encryption; passwords are hashed using bcrypt with unique salts; sensitive data at rest is encrypted using AES-256
• Access Controls: Role-based access restrictions limit employee access to personal data on a need-to-know basis; multi-factor authentication required for administrative access; regular access reviews and deprovisioning of terminated employees
• Infrastructure Security: Firewalls, intrusion detection systems, and DDoS protection; regular security audits and penetration testing; secure data centers with physical access controls; segregated player funds in separate bank accounts
• Monitoring and Incident Response: 24/7 security monitoring for suspicious activity; automated fraud detection systems; incident response plan for data breaches; regular backup and disaster recovery procedures

While we implement robust security measures, no internet-based system is completely secure. You also have responsibility for maintaining account security by using strong passwords, enabling two-factor authentication where available, and never sharing login credentials.

8. Data Retention

11ph2 retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods vary based on data category and legal requirements:

• Account Information: Retained for the duration of your active account plus seven (7) years after account closure (required by PAGCOR and tax regulations)
• Transaction Records: Retained for ten (10) years as required by anti-money laundering laws and financial record-keeping obligations
• Identity Documents: Retained for seven (7) years after account closure for compliance and audit purposes
• Marketing Consent Records: Retained for three (3) years after consent withdrawal to demonstrate compliance with data protection laws
• Technical and Usage Logs: Retained for two (2) years for security monitoring and platform improvement
• Customer Support Communications: Retained for three (3) years for quality assurance and dispute resolution

After the applicable retention period expires, we securely delete or anonymize your personal information using industry-standard data destruction methods. Anonymized data that cannot be linked back to you may be retained indefinitely for statistical and analytical purposes.

9. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights regarding your personal information:

• Right to Information: You have the right to be informed about the collection and processing of your personal data, which we provide through this Privacy Policy
• Right to Access: You may request copies of the personal information we hold about you, subject to certain legal limitations
• Right to Rectification: You may request correction of inaccurate or incomplete personal information through your account settings or by contacting support
• Right to Erasure: You may request deletion of your personal data in certain circumstances, though we may be required to retain some information for legal compliance
• Right to Object: You may object to processing of your personal data for marketing purposes at any time by unsubscribing from promotional communications
• Right to Data Portability: You may request transfer of your personal data to another service provider in a structured, commonly-used format where technically feasible
• Right to Lodge a Complaint: You may file a complaint with the National Privacy Commission (NPC) if you believe your data protection rights have been violated

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with your request. We will respond within fifteen (15) calendar days and may require identity verification to prevent unauthorized disclosure of personal information.

10. Cookies and Tracking Technologies

The 11ph2 Platform uses cookies and similar tracking technologies to enhance user experience, analyze usage patterns, and deliver personalized content. A cookie is a small text file stored on your device that allows us to recognize your browser and remember certain information.

We use the following types of cookies:

• Essential Cookies: Required for platform functionality, security, and user authentication; cannot be disabled without affecting platform operation
• Performance Cookies: Collect information about how visitors use the Platform, allowing us to improve performance and user experience
• Functional Cookies: Remember your preferences and settings to provide enhanced features
• Marketing Cookies: Track your browsing activity to deliver relevant advertisements and promotional content (requires your consent)

You can manage cookie preferences through your browser settings, though disabling certain cookies may limit platform functionality. Most browsers allow you to refuse cookies or delete existing cookies, but this may prevent you from accessing some features or require repeated login.

11. International Data Transfers

11ph2 primarily stores and processes personal data within the Philippines. However, some of our service providers (such as game developers, payment processors, and cloud infrastructure providers) may be located outside the Philippines, potentially resulting in international data transfers.

When we transfer your personal information outside the Philippines, we ensure appropriate safeguards are in place through contractual agreements requiring foreign processors to maintain security standards equivalent to those required under Philippine law. We only work with reputable international partners who demonstrate commitment to data protection.

12. Children's Privacy

The 11ph2 Platform is strictly intended for individuals aged twenty-one (21) years or older. We do not knowingly collect personal information from minors under the age of 21. If we become aware that we have inadvertently collected personal data from someone under 21, we will immediately delete that information and close the associated account.

Parents or guardians who believe their child has provided personal information to 11ph2 should contact us immediately at [email protected] so we can take appropriate action.

13. Changes to This Privacy Policy

11ph2 reserves the right to modify or update this Privacy Policy at any time to reflect changes in our practices, legal requirements, or business operations. Material changes will be communicated through prominent notice on the Platform or via email to your registered address at least thirty (30) days before the changes take effect.

Your continued use of the Platform after the effective date of any changes constitutes acceptance of the revised Privacy Policy. If you do not agree with the changes, you must cease using the Platform and may request account closure and data deletion in accordance with your data subject rights.

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. The "Last Updated" date at the top of this document indicates when the policy was most recently revised.

14. Contact and Questions

If you have any questions, concerns, or requests regarding this Privacy Policy or our data processing practices, please contact us:

• Data Protection Officer Email: [email protected]
• General Support: [email protected]
• Live Chat: Available 24/7 through the Platform

For complaints or concerns about how we handle your personal information, you may also contact the National Privacy Commission of the Philippines through their official website or complaint hotline.