Privacy Policy

1. Who We Are

11ph2 ("the Company," "we," "us," or "our") operates the online gaming platform accessible at https://11ph2.app, including all associated pages, features, games, and services (collectively, the "Platform"). 11ph2 is the data controller responsible for the personal information collected through the Platform, as defined under the Philippine Data Privacy Act of 2012 (RA 10173).

We serve players across the Philippines — from Manila and Makati to Cebu, Davao, Quezon City, and beyond — and we are committed to handling your personal data with the highest standards of care, transparency, and compliance with applicable Philippine law.

If you have any questions about this Privacy Policy or how 11ph2 handles your personal data, please refer to Section 15 for our contact details and Data Protection Officer (DPO) information.

2. Information We Collect

11ph2 collects personal information that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal information we collect include:

2.1 Identity & Registration Data

• Full legal name as it appears on your government-issued identification.
• Date of birth (used to verify that you are at least 21 years of age).
• Gender (optional, for personalisation purposes).
• Nationality and country of residence.
• Username and account password (stored in encrypted form).

2.2 Contact Information

• Email address (primary communication channel).
• Mobile phone number (used for account verification and security alerts).
• Residential address (required for KYC verification and regulatory compliance).

2.3 Identity Verification (KYC) Documents

• Copies of government-issued photo identification (e.g., Philippine passport, SSS ID, PhilSys National ID, driver's licence, UMID).
• Proof of address documents (e.g., utility bill, bank statement dated within the last three months).
• Proof of payment method ownership (e.g., screenshot of GCash or PayMaya account showing your registered name).

2.4 Financial & Transaction Data

• Deposit and withdrawal amounts, dates, and payment method references.
• GCash or PayMaya account reference numbers (not full account credentials).
• Bank account details used for withdrawals (account name and number only).
• Transaction history and account balance records.

2.5 Gaming Activity Data

• Game session logs, including games played, wagers placed, and outcomes.
• Bonus and promotion usage history.
• Responsible gaming tool settings (deposit limits, session reminders, self-exclusion status).

2.6 Technical & Device Data

• IP address and approximate geolocation (country and city level).
• Device type, operating system, and browser version.
• Session timestamps and login history.
• Cookie identifiers and similar tracking data (see Section 7).

2.7 Communications Data

• Records of your communications with 11ph2 support, including live chat transcripts and email correspondence.
• Feedback, complaints, and dispute records.

3. How We Collect Your Data

11ph2 collects your personal information through the following means:

• Directly from you: When you register an account, complete KYC verification, make a deposit or withdrawal, contact support, or update your account settings.
• Automatically: When you access and use the Platform, our servers and analytics tools automatically record technical and device data, including your IP address, session duration, and pages visited.
• Through cookies and similar technologies: As described in Section 7, we use cookies and similar tracking technologies to enhance your experience and gather usage analytics.
• From third-party service providers: Identity verification providers, payment processors, and fraud detection services may share data with us as part of their service delivery. All such providers are contractually bound to handle your data in accordance with applicable privacy law.
• From regulatory and law enforcement authorities: In limited circumstances, we may receive information from PAGCOR, the National Privacy Commission (NPC), or other competent authorities as part of our regulatory compliance obligations.

4. Legal Basis for Processing

Under the Philippine Data Privacy Act of 2012, 11ph2 processes your personal information on the following legal bases:

5. How We Use Your Information

11ph2 uses the personal information we collect for the following purposes:

• To create, verify, and manage your 11ph2 account.
• To verify your identity and age (21+) in compliance with Philippine gaming regulations.
• To process your deposits and withdrawals through approved Philippine payment channels.
• To deliver the games, promotions, and services you request through the Platform.
• To detect, investigate, and prevent fraud, money laundering, and other illegal or prohibited activities.
• To enforce our Terms & Conditions and other applicable policies.
• To provide customer support and respond to your enquiries and complaints.
• To send you account-related notifications, security alerts, and service updates.
• To send you marketing communications about promotions and new features, where you have given your consent to receive such communications. You may withdraw this consent at any time.
• To comply with our legal and regulatory obligations under Philippine law, including reporting obligations to PAGCOR and the Anti-Money Laundering Council (AMLC).
• To improve the Platform through analytics and user experience research.
• To administer responsible gaming tools and monitor for signs of problem gambling behaviour.

6. Sharing Your Information

11ph2 does not sell, rent, or trade your personal information to third parties for their own marketing purposes. We share your data only in the following limited circumstances:

• Service Providers: We engage trusted third-party service providers to assist with identity verification (KYC), payment processing, fraud detection, customer support technology, and platform analytics. These providers are contractually obligated to process your data only on our instructions and in accordance with applicable privacy law.
• Game Suppliers: The game providers whose titles are available on the 11ph2 Platform may receive limited technical data (such as session tokens and game results) necessary to deliver their games. They do not receive your full personal profile.
• Regulatory Authorities: We are required by law to share certain information with PAGCOR, the AMLC, the National Privacy Commission, and other competent Philippine authorities upon lawful request or as part of our routine regulatory reporting obligations.
• Law Enforcement: We may disclose personal information to law enforcement agencies where required by a valid court order, subpoena, or other lawful legal process.
• Business Transfers: In the event of a merger, acquisition, or sale of all or part of the business, your personal information may be transferred to the acquiring entity, subject to the same privacy protections described in this Policy.

In all cases, we take reasonable steps to ensure that any third party receiving your personal information is bound by appropriate confidentiality and data protection obligations.

7. Cookies & Tracking Technologies

The 11ph2 Platform uses cookies and similar tracking technologies to enhance your experience, maintain your session, and gather analytics data. The types of cookies we use include:

• Strictly Necessary Cookies: Essential for the Platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled.
• Functional Cookies: Remember your preferences, such as your preferred language, game lobby layout, and responsible gaming settings.
• Analytics Cookies: Help us understand how players use the Platform — which pages are visited most, where users drop off, and how features are used. This data is aggregated and anonymised where possible.
• Security & Fraud Detection Cookies: Used to identify suspicious activity, detect multiple accounts, and protect the integrity of the Platform.

You can manage your cookie preferences through your browser settings. Please note that disabling certain cookies may affect the functionality of the 11ph2 Platform. Strictly necessary cookies cannot be disabled without preventing you from using the Platform.

8. Data Retention

11ph2 retains your personal information for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. The following general retention periods apply:

• Account and KYC data: Retained for a minimum of five (5) years from the date of account closure, in compliance with the Anti-Money Laundering Act (RA 9160, as amended) and PAGCOR regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Support communications: Retained for three (3) years from the date of the last communication, or longer if the communication relates to an ongoing dispute or regulatory matter.
• Marketing consent records: Retained for as long as you remain a registered player, and for one (1) year following account closure or withdrawal of consent.
• Technical and device data: Retained for up to twelve (12) months from collection, unless required for longer periods for security or fraud investigation purposes.

When personal information is no longer required, 11ph2 will securely delete or anonymise it in accordance with our internal data disposal procedures.

9. Data Security

11ph2 implements a range of technical and organisational security measures to protect your personal information against unauthorised access, disclosure, alteration, or destruction. These measures include:

• Transport Layer Security (TLS) encryption for all data transmitted between your device and the 11ph2 Platform.
• Encryption of sensitive data at rest, including passwords (hashed using industry-standard algorithms) and KYC documents.
• Role-based access controls ensuring that only authorised personnel can access personal data, and only to the extent necessary for their role.
• Regular security audits, vulnerability assessments, and penetration testing of the Platform infrastructure.
• Two-factor authentication (2FA) available to all players for additional account security.
• Continuous monitoring for suspicious activity and automated alerts for unusual login patterns or transaction behaviour.
• Staff training on data privacy obligations under the Philippine Data Privacy Act and internal security protocols.

While 11ph2 takes all reasonable steps to protect your personal information, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying us immediately if you suspect any unauthorised access to your account.

10. Your Rights Under the Data Privacy Act

As a data subject under the Philippine Data Privacy Act of 2012 (RA 10173), you have the following rights with respect to your personal information held by 11ph2:

• Right to be Informed: You have the right to know what personal information 11ph2 collects about you, why we collect it, and how it is used — which is the primary purpose of this Privacy Policy.
• Right to Access: You may request a copy of the personal information we hold about you at any time. We will respond to verified access requests within thirty (30) calendar days.
• Right to Rectification: If any personal information we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. You may update basic account details directly through your account settings.
• Right to Erasure or Blocking: You may request the deletion or blocking of your personal information where it is no longer necessary for the purpose for which it was collected, or where processing is unlawful. Note that this right is subject to our legal retention obligations under Philippine law.
• Right to Object: You have the right to object to the processing of your personal information for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to applicable legal grounds.
• Right to Data Portability: Where technically feasible, you may request a copy of your personal information in a structured, commonly used, and machine-readable format.
• Right to Lodge a Complaint: If you believe that 11ph2 has violated your data privacy rights, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.

To exercise any of the above rights, please contact our Data Protection Officer using the details provided in Section 15. We may require you to verify your identity before processing your request to protect against unauthorised access to your personal information.

11. Children & Minors

The 11ph2 Platform is strictly intended for individuals who are at least 21 years of age, in accordance with Philippine gaming regulations. We do not knowingly collect personal information from anyone under the age of 21.

During the registration process, all applicants are required to confirm that they are 21 or older and to submit valid government-issued identification for age verification. If 11ph2 discovers or has reasonable grounds to believe that a registered account belongs to a person under the age of 21, we will immediately suspend the account, forfeit any winnings, return any deposits in accordance with applicable regulations, and delete the personal information of the underage individual from our systems.

If you are a parent or guardian and believe that your child has registered an account on the 11ph2 Platform, please contact our support team immediately so that we can take appropriate action.

12. International Data Transfers

11ph2 primarily processes and stores personal data within the Philippines. However, some of our third-party service providers — including game suppliers, cloud infrastructure providers, and fraud detection services — may be located in or operate from other countries.

Where personal data is transferred outside the Philippines, 11ph2 takes appropriate steps to ensure that such transfers comply with the requirements of the Philippine Data Privacy Act, including ensuring that the recipient country provides an adequate level of data protection or that appropriate contractual safeguards are in place (such as data processing agreements incorporating standard contractual clauses).

By using the 11ph2 Platform, you acknowledge that your personal information may be transferred to and processed in countries outside the Philippines, subject to the safeguards described above.

13. Third-Party Links & Services

The 11ph2 Platform may contain references to third-party game providers and payment services that operate under their own privacy policies. 11ph2 is not responsible for the privacy practices of these third parties, and this Privacy Policy does not apply to any information collected by them directly.

We encourage you to review the privacy policies of any third-party service providers whose services you use in connection with the 11ph2 Platform, particularly your chosen payment provider (e.g., GCash, PayMaya, or your bank).

14. Changes to This Privacy Policy

11ph2 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When material changes are made, we will notify registered players by posting a prominent notice on the Platform and, where practicable, by sending a notification to the email address associated with your account.

The "Last Updated" date at the top of this page indicates when the Privacy Policy was most recently revised. Your continued use of the 11ph2 Platform after the effective date of any amendment constitutes your acknowledgement of the updated Privacy Policy. If you do not agree with the changes, you should stop using the Platform and close your account before the effective date.

We encourage you to review this Privacy Policy periodically to stay informed about how 11ph2 protects your personal information.

15. Contact Us & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 11ph2 handles your personal information, please contact us through the following channels:

• Live Chat: Available 24/7 directly within your 11ph2 account dashboard. This is the fastest way to reach our team — average response time is under 3 minutes.
• Email: [email protected] — for general enquiries and support requests. Responses within 24 hours on business days.
• Data Protection Officer: [email protected] — for formal data privacy requests, including access, rectification, erasure, and complaints. The DPO will acknowledge your request within five (5) business days and provide a substantive response within thirty (30) calendar days.

If you are not satisfied with our response to a data privacy concern, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines. The NPC can be reached through their official government channels.

11ph2 — https://11ph2.app · Serving Filipino players across Manila, Cebu, Davao, Quezon City, Makati, and nationwide.