jl11 Privacy Policy — How We Collect, Use, and Protect Your Personal Data

1. Data Controller

jl11, operating via jl11.biz, is the Data Controller responsible for personal information collected through the Platform. As Data Controller, jl11 determines the purposes and means of processing your personal data and is responsible for ensuring that such processing complies with applicable Philippine data privacy law.

For all privacy-related enquiries, requests, and concerns, you may contact jl11's designated Data Protection Officer (DPO) at: [email protected] — Manila, Philippines (PHT UTC+8).

2. Personal Data We Collect

jl11 collects the following categories of personal data from registered players and platform visitors:

jl11 does not collect special categories of sensitive personal data (e.g., biometric data, health data, political views) except where expressly required for identity verification under applicable law.

3. How We Collect Personal Data

jl11 collects personal data through the following channels:

• Direct submission — information you provide when registering an account, completing identity verification, submitting support requests, or participating in promotions on jl11.
• Automated collection — technical data collected automatically through cookies, server logs, and analytics tools when you access and use jl11.biz. See Section 7 for full details on cookies.
• Third-party sources — identity verification data from document verification service providers; payment verification data from GCash, Maya, BPI, BDO, Metrobank, and other payment partners; fraud screening data from compliance service providers.

4. Purpose and Legal Basis for Processing

jl11 processes your personal data on the following legal bases and for the following purposes:

• Performance of Contract — processing your registration, account management, deposits, withdrawals, and gameplay on jl11 is necessary to perform the service agreement between you and the Platform.
• Legal Obligation — jl11 is required by applicable Philippine law (including AML regulations and PAGCOR-related compliance obligations) to collect and retain certain identity, financial, and transaction data. This processing is mandatory and cannot be waived by player consent withdrawal.
• Legitimate Interests — jl11 processes technical and gaming data to detect and prevent fraud, ensure Platform security, improve service quality, and manage responsible gaming obligations. These interests are proportionate and do not override your fundamental privacy rights.
• Consent — where jl11 sends marketing communications or promotional offers, such processing is based on your affirmative opt-in consent. You may withdraw consent to marketing communications at any time without affecting your account.

5. Data Sharing and Disclosure

jl11 does not sell your personal data to third parties. We share personal data only in the following circumstances and only to the extent strictly necessary:

• Payment Service Providers — GCash (Mynt), Maya (Voyager Innovations), BPI, BDO, Metrobank, Coins.ph, and other payment partners receive financial and identity data necessary to process your deposits and withdrawals.
• Game Content Providers — certified third-party game providers (e.g., Pragmatic Play and similar suppliers) receive the minimum data necessary to deliver and authenticate game sessions. These providers operate under data processing agreements with jl11.
• Identity Verification Providers — KYC and age verification service providers receive identity document data for verification processing. All such providers are bound by confidentiality obligations.
• Fraud and AML Compliance Providers — anti-money laundering screening and fraud detection service providers process transaction and identity data as required by Philippine law.
• Regulatory and Law Enforcement Authorities — jl11 will disclose personal data to Philippine government agencies, regulatory bodies, or law enforcement where required by law, court order, or lawful authority.
• Professional Advisers — lawyers, accountants, and auditors acting as service providers to jl11 may access personal data as necessary and subject to professional confidentiality obligations.

All third-party data processors engaged by jl11 are contractually required to process personal data only on jl11's documented instructions and to implement appropriate security measures.

6. Data Retention

jl11 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, subject to any longer retention period required by applicable law:

• Account Data and Identity Documents — retained for the duration of your active account plus a minimum of 5 years after account closure, consistent with Philippine AML record-keeping requirements.
• Financial Transaction Records — retained for a minimum of 5 years from the date of each transaction, as required by applicable Philippine financial regulations.
• Gaming and Activity Logs — retained for 2 years from the date of each logged session, unless retained longer for dispute resolution or legal compliance purposes.
• Support Communications — retained for 2 years from the date of the last communication in each case, unless required for ongoing dispute resolution.
• Marketing Consent Records — retained for the duration of consent plus 2 years after withdrawal, to demonstrate compliance.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with jl11's data destruction procedures.

7. Cookies and Tracking Technologies

jl11.biz uses cookies and similar tracking technologies to operate the Platform and improve your experience. The following categories of cookies are used:

• Strictly Necessary Cookies — required for the Platform to function. These include session authentication cookies and security cookies. They cannot be disabled without preventing Platform use.
• Functional Cookies — used to remember your preferences (e.g., language settings, remembered login) and personalise your jl11 experience. Disabling these may affect Platform functionality.
• Analytics Cookies — used to collect aggregate, anonymised data about how visitors use jl11.biz, including pages visited, session duration, and device types. This data helps jl11 improve the Platform.
• Security Cookies — used to detect and prevent fraudulent or unauthorised access to your jl11 account, including login anomaly detection and device fingerprinting for 2FA purposes.

You may manage cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent you from accessing your jl11 account.

8. Security Measures

jl11 implements the following technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• 256-bit SSL/TLS Encryption — all data transmitted between your device and jl11.biz is encrypted in transit using industry-standard TLS protocols.
• At-Rest Encryption — sensitive personal data stored on jl11 servers is encrypted at rest using AES-256 encryption standards.
• Access Controls — access to player personal data by jl11 staff is restricted on a strict need-to-know basis, with role-based access controls and comprehensive audit logging.
• Two-Factor Authentication — all jl11 administrative systems require multi-factor authentication. Players are encouraged to enable 2FA on their accounts via Account Settings.
• Security Monitoring — jl11 operates continuous security monitoring for intrusion detection, unusual access patterns, and data breach indicators.
• Data Breach Response — in the event of a personal data breach affecting Philippine data subjects, jl11 will notify the National Privacy Commission (NPC) and affected individuals within the timeframes required by the DPA and its IRR.

9. Your Data Subject 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 jl11:

• Right to Be Informed — the right to be notified about how your personal data is collected, processed, and used by jl11. This Privacy Policy fulfils that obligation.
• Right of Access — the right to request a copy of the personal data jl11 holds about you and information about how it is being processed.
• Right to Rectification — the right to request correction of inaccurate or incomplete personal data. You may update most account details directly in your jl11 Account Settings.
• Right to Erasure — the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to jl11's legal retention obligations.
• Right to Object — the right to object to processing based on legitimate interests or for direct marketing purposes. Objecting to marketing processing will not affect your account access.
• Right to Data Portability — the right to receive a copy of your personal data in a structured, commonly used, machine-readable format for transfer to another service where technically feasible.
• Right to Withdraw Consent — where processing is based on your consent (e.g., marketing communications), the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal.

To exercise any of the above rights, contact jl11's Data Protection Officer at [email protected] with the subject line "Data Privacy Request". jl11 will respond within 15 business days. You also have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe jl11 has not handled your data in compliance with the DPA.

10. Minors and Age Restriction

jl11 does not knowingly collect personal data from individuals under the age of 21. The Platform is strictly restricted to adults aged 21 and above in accordance with Philippine gambling regulations.

If jl11 becomes aware that personal data has been collected from an individual under 21 without appropriate verification, the relevant account will be immediately suspended, all personal data associated with the account will be deleted (subject to any mandatory retention obligations), and any deposited funds will be returned to the payment source.

If you believe a minor has registered an account on jl11, please contact us immediately at [email protected] so we can take prompt action.

11. Changes to This Privacy Policy

jl11 may update this Privacy Policy periodically to reflect changes in our data practices, applicable law, or Platform functionality. Material changes will be communicated to registered players via the email address on their account and/or via a notice on the jl11 Platform at least 7 days before the updated Policy takes effect.

The "Last updated" date at the top of this Policy indicates when the most recent changes were made. Your continued use of jl11.biz after any Policy update constitutes your acknowledgement of the updated terms. If the updated Policy is not acceptable to you, you should close your account before the effective date.

12. Contact and Data Protection Officer

For all privacy enquiries, data subject rights requests, and data breach reports, please contact jl11's Data Protection Officer:

jl11 takes all data privacy concerns seriously. Where your concern relates to a potential breach of the Data Privacy Act, you retain the right to raise a complaint with the National Privacy Commission of the Philippines (NPC).