ph11 Casino Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how ph11 ("ph11," "we," "us," or "our"), operator of the online gaming platform at https://ph11.onl, collects, uses, stores, discloses, and protects the personal information of individuals ("Data Subjects," "Players," or "you") who access or use the ph11 Platform.

ph11 operates as a personal information controller under the Data Privacy Act of 2012 (Republic Act No. 10173) and is subject to the oversight of both the National Privacy Commission (NPC) and PAGCOR (Philippine Amusement and Gaming Corporation) with respect to the handling of personal data in the context of regulated online gaming operations.

By registering an account on ph11 or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein.

2. Data Controller Information

ph11 is the personal information controller responsible for your data collected via the ph11 Platform. For all privacy-related inquiries, data subject requests, or complaints, you may contact ph11's designated Data Protection Officer (DPO) at:

• Email: [email protected] (plain text — not a clickable link)
• Platform: https://ph11.onl
• Jurisdiction: Republic of the Philippines

ph11's Data Protection Officer is responsible for overseeing compliance with the Data Privacy Act, this Policy, and all related internal data governance procedures.

3. Information We Collect

3.1 Information You Provide Directly

ph11 collects the following personal information when you register, verify your account, or interact with the Platform:

3.2 Information Collected Automatically

ph11 automatically collects certain technical data when you access the Platform:

• Device information (device type, operating system, browser type and version);
• Internet Protocol (IP) address and approximate geolocation derived therefrom;
• Session data (login timestamps, session duration, pages visited, game sessions initiated);
• Cookies and similar tracking technologies (see Section 7);
• Referring URL and traffic source information.

3.3 Information from Third Parties

ph11 may receive personal data about you from third-party sources including payment processors (GCash, Maya, BPI, BDO), identity verification service providers, and fraud detection services engaged by ph11 for compliance purposes.

4. How We Use Your Personal Data

ph11 processes your personal data for the following purposes:

• Account Management: Creating, maintaining, and managing your ph11 account, including authentication and password reset;
• KYC and Age Verification: Verifying your identity and confirming that you are at least 21 years of age as required by Philippine law and PAGCOR regulations;
• Payment Processing: Processing deposits, withdrawals, and refunds via GCash, Maya, and other accepted Philippine payment methods;
• Anti-Money Laundering (AML) Compliance: Monitoring transactions and fulfilling PAGCOR and AMLC (Anti-Money Laundering Council) reporting obligations;
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent activity, unauthorized account access, and terms violations;
• Platform Improvement: Analyzing usage data to improve Platform performance, game library curation, and user experience;
• Customer Support: Responding to support inquiries, resolving disputes, and communicating important account information;
• Responsible Gaming: Monitoring play patterns to identify potential problem gambling behavior and providing appropriate interventions;
• Marketing Communications: Sending promotional offers, bonus notifications, and platform updates where you have provided consent or where ph11 has a legitimate interest, subject to your right to opt out.

5. Legal Basis for Processing

ph11 processes your personal data on the following legal bases under the Data Privacy Act of 2012:

• Contractual Necessity: Processing required to perform the contract between you and ph11 (i.e., operating your account and processing transactions);
• Legal Obligation: Processing required to comply with PAGCOR license conditions, AML regulations, tax obligations, and other applicable Philippine laws;
• Legitimate Interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your privacy rights;
• Consent: Processing for marketing communications and non-essential cookies, where your explicit consent has been obtained and may be withdrawn at any time.

6. Data Sharing & Disclosure

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

• PAGCOR and Regulatory Authorities: ph11 is legally obligated to provide player data to PAGCOR upon request and to submit required reports under its operating license. This includes transaction data, KYC documents, and responsible gaming records;
• AMLC (Anti-Money Laundering Council): ph11 is required to file covered transaction reports and suspicious transaction reports with AMLC as mandated by the Anti-Money Laundering Act;
• Payment Processors: Your financial data is shared with GCash (Mynt), Maya (Voyager Innovations), and other payment processors solely to facilitate transactions;
• Game Providers: Limited technical data (player session identifiers, game results) is shared with certified game software providers (PG Soft, Pragmatic Play, Jili, etc.) to operate the gaming service;
• KYC and Fraud Service Providers: Identity verification and fraud detection service providers engaged by ph11 under data processing agreements;
• Law Enforcement: ph11 may disclose personal data to law enforcement or courts where required by valid legal process, court order, or national security requirement.

All third-party service providers engaged by ph11 are bound by data processing agreements requiring them to process your data only for specified purposes and to maintain appropriate security standards.

7. Cookies & Tracking Technologies

ph11 uses cookies and similar technologies on the Platform for the following purposes:

• Strictly Necessary Cookies: Essential for Platform operation — session management, authentication, load balancing. These cannot be disabled;
• Functional Cookies: Remember your preferences (e.g., language settings, game lobby layout preferences);
• Analytics Cookies: Measure Platform usage and performance to help ph11 improve the service (e.g., page load metrics, feature engagement);
• Security Cookies: Detect fraudulent activity and prevent unauthorized access.

You may control non-essential cookie categories through your browser settings. Note that disabling certain cookies may affect Platform functionality.

8. Data Retention

ph11 retains your personal data for as long as necessary to fulfil the purposes described in this Policy, including:

• Active Account Data: Retained for the duration of your account's active status;
• KYC and Transaction Records: Retained for a minimum of five (5) years following account closure as required by PAGCOR license conditions and Philippine AML law;
• Financial Transaction Data: Retained for at least five (5) years for tax and AML compliance purposes;
• Support and Dispute Records: Retained for three (3) years following resolution;
• Technical Logs: Retained for twelve (12) months unless a longer period is required for security investigations.

Upon expiration of applicable retention periods, ph11 will securely delete or anonymize your personal data in accordance with its data disposal procedures.

9. Data Security

ph11 implements technical and organizational security measures appropriate to the nature of the personal data processed and the risks involved, including:

• SSL/TLS encryption for all data transmitted between your device and the ph11 Platform;
• Encryption of sensitive data (including government ID scans and financial data) at rest using industry-standard algorithms;
• Multi-factor authentication (SMS OTP) for account access;
• Regular security audits and penetration testing conducted by qualified security professionals;
• Role-based access controls limiting employee access to personal data on a need-to-know basis;
• Incident response procedures aligned with NPC breach notification requirements under the Data Privacy Act.

10. Your Data Subject Rights

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph11:

To exercise any of the above rights, submit a written request to ph11's Data Protection Officer at [email protected]. ph11 will respond within fifteen (15) business days. If you believe ph11 has violated your privacy rights under Philippine law, you may file a complaint with the National Privacy Commission (NPC) at privacy.gov.ph.

11. Children's Privacy and Age Restrictions

The ph11 Platform is strictly intended for individuals who are at least twenty-one (21) years of age. ph11 does not knowingly collect personal data from individuals under the age of 21. If ph11 discovers that personal data has been collected from an individual under 21, ph11 will immediately terminate the account and delete the associated personal data, subject to any legal retention obligations.

If you believe that ph11 has inadvertently collected data from an underage individual, please contact ph11's Data Protection Officer immediately at [email protected].

12. Cross-Border Data Transfers

ph11 may transfer personal data to third-party service providers located outside the Philippines (including game software providers and cloud infrastructure providers) in the course of operating the Platform. ph11 ensures that such transfers are conducted in compliance with Section 21 of the Data Privacy Act of 2012 by implementing appropriate safeguards, including data processing agreements incorporating standard contractual clauses approved by the National Privacy Commission.

ph11 does not transfer personal data to jurisdictions that do not provide an adequate level of data protection without implementing appropriate contractual safeguards.

13. Changes to This Privacy Policy

ph11 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, PAGCOR regulatory requirements, or ph11's data processing practices. Where changes are material, ph11 will notify registered Players via the Platform or by SMS notification to their registered mobile number.

The effective date of this Policy is noted at the top of this page. Continued use of the ph11 Platform following the effective date of any update constitutes acceptance of the revised Policy. The current version of this Policy is always available at https://ph11.onl/privacy-policy.

14. Contact & DPO Information

For all privacy-related queries, data subject access requests, or concerns regarding ph11's handling of personal data, please contact:

• Data Protection Officer, ph11
• Email: [email protected]
• Response Time: Within 15 business days of receipt
• Escalation: National Privacy Commission of the Philippines — privacy.gov.ph (plain text reference only)