jl11 Privacy Policy – How We Handle Your Personal Data

1. Introduction and Scope

This Privacy Policy ("Policy") is issued by jl11, the operator of the online gaming platform accessible at jl11.lat ("jl11", "we", "us", "the Platform"). jl11 operates under a license issued by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to the Republic Act No. 10173, also known as the Data Privacy Act of 2012 (DPA), and its Implementing Rules and Regulations (IRR), as enforced by the National Privacy Commission (NPC) of the Philippines.

This Policy applies to all personal information collected by jl11 in connection with your registration, use of the platform, transactions, customer support interactions, and any other activity involving jl11 services. By registering a jl11 account or using the platform, you consent to the collection and processing of your personal data as described in this Policy.

This Policy should be read in conjunction with jl11's Terms & Conditions and Responsible Gaming Policy.

2. Legal Basis for Processing

jl11 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 jl11 (i.e., to operate your account, process deposits and withdrawals, and provide gaming services).
• Legal Obligation: Processing required to comply with PAGCOR licensing requirements, Anti-Money Laundering Act (AMLA) obligations, and other applicable Philippine regulations — including KYC identity verification.
• Legitimate Interest: Processing necessary for jl11's legitimate business interests, such as fraud prevention, security monitoring, and platform improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing based on your explicit consent, such as for marketing communications. You may withdraw consent at any time without affecting the lawfulness of prior processing.

3. Personal Data We Collect

jl11 collects the following categories of personal data:

Category	Data Elements	Collection Point
Identity Data	Full legal name, date of birth, gender, nationality, government ID number and type	Registration; KYC verification
Contact Data	Philippine mobile number, email address, residential address	Registration; account settings
Financial Data	GCash number, bank account details (BPI, BDO, Metrobank), transaction history, deposit and withdrawal records	Payment processing; withdrawal requests
Gaming Data	Game history, bet records, win/loss data, session durations, bonus usage	Platform activity logging
Technical Data	IP address, device type, browser type, operating system, session tokens	Automatic collection during platform access
Communication Data	Customer support correspondence, complaint records, live chat transcripts	Support interactions
KYC Documents	Copies of government-issued ID (PhilSys, UMID, driver's license, passport), selfie verification images	Identity verification for withdrawal processing

jl11 does not collect sensitive personal information as defined under the DPA (such as health or medical data, sexual life, genetic data) except where expressly required by applicable law or regulation in the context of responsible gaming assessments.

4. How We Use Your Personal Data

jl11 uses your personal data for the following purposes:

4.1 Account Management. To create and manage your jl11 account, verify your identity, process deposits and withdrawals, and communicate account-related information to you.

4.2 Regulatory Compliance. To fulfill jl11's obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), the Terrorism Financing Prevention and Suppression Act, and other applicable Philippine laws. This includes conducting KYC checks, transaction monitoring, and filing Suspicious Transaction Reports (STRs) where legally required.

4.3 Fraud Prevention and Security. To detect, investigate, and prevent fraudulent activity, money laundering, multi-accounting, bonus abuse, and other prohibited conduct on the platform.

4.4 Responsible Gaming. To monitor gaming patterns for indicators of problem gambling behavior, administer responsible gaming tools (deposit limits, self-exclusion), and contact players where we have reasonable concerns about their gaming behavior.

4.5 Platform Improvement. To analyze aggregate usage data, improve platform performance, develop new features, and optimize the user experience for Filipino players.

4.6 Marketing Communications. Where you have provided consent, to send you promotional offers, bonus notifications, and platform updates via SMS, email, or in-platform notifications. You may opt out at any time.

4.7 Legal Proceedings. To establish, exercise, or defend legal claims, respond to regulatory inquiries, and cooperate with lawful requests from Philippine law enforcement or PAGCOR.

5. Disclosure of Personal Data to Third Parties

jl11 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the stated purpose:

5.1 Payment Processors. GCash (G-Xchange, Inc.), PayMaya Philippines, BancNet, and other licensed Philippine payment service providers, for the sole purpose of processing your deposits and withdrawals.

5.2 Identity Verification Providers. Third-party KYC service providers engaged to assist jl11 in verifying player identity documents in compliance with PAGCOR and AMLA requirements.

5.3 Game Providers. Licensed game software providers (including but not limited to JILI, Pragmatic Play, PG Soft) receive limited technical data necessary to operate their game engines within the jl11 platform. These providers operate under data processing agreements with jl11.

5.4 Regulatory Authorities. PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where required by law or regulatory obligation.

5.5 Professional Advisors. Legal, audit, and compliance professionals engaged by jl11, subject to professional confidentiality obligations.

6. Data Retention

jl11 retains your personal data for as long as your account is active and for a period thereafter as required by Philippine law and regulatory obligations. Specific retention periods are as follows:

• Account and identity data: Five (5) years from account closure or last transaction, in compliance with AMLA record-keeping requirements.
• Transaction records: Five (5) years from the date of each transaction, per AMLA and PAGCOR requirements.
• KYC documents: Five (5) years from account closure.
• Customer support records: Two (2) years from the date of each interaction, unless the matter is subject to ongoing legal proceedings.
• Marketing consent records: Until consent is withdrawn, plus one (1) year for compliance documentation purposes.

After the applicable retention period, jl11 will securely delete or anonymize your personal data unless retention is required by a court order, regulatory direction, or ongoing legal proceedings.

7. Data Security

jl11 implements technical and organizational security measures appropriate to the risk level associated with the personal data we process. These measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and jl11 servers
• Encrypted storage of passwords using industry-standard hashing algorithms (bcrypt)
• Segregated storage of player fund records from operational data
• Role-based access controls limiting staff access to personal data on a need-to-know basis
• Regular security audits and penetration testing of jl11 infrastructure
• Two-factor authentication available for all player accounts via SMS OTP
• Automated monitoring for suspicious login patterns and unauthorized access attempts

Notwithstanding the above, no method of electronic transmission or storage is completely secure. jl11 cannot guarantee absolute security of your personal data but will notify affected players and the NPC in the event of a personal data breach as required under the DPA.

8. Cookies and Tracking Technologies

jl11 uses cookies and similar technologies on the platform for the following purposes:

8.1 Strictly Necessary Cookies: Required for the platform to function correctly, including session management, authentication, and security. These cannot be disabled without impairing platform functionality.

8.2 Functional Cookies: Enable the platform to remember your preferences (language, display settings, last visited game category) to improve your experience.

8.3 Analytics Cookies: Used to collect aggregate, anonymized data about how players interact with jl11, to identify performance issues and improve platform design. No individually identifiable data is shared with analytics providers.

You may configure your browser to block or delete cookies; however, disabling strictly necessary cookies may prevent you from accessing your jl11 account or using certain platform features.

9. Your Rights as a Data Subject

Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by jl11:

To exercise any of the above rights, contact jl11's Data Privacy Officer at [email protected] with the subject line "Data Privacy Request". jl11 will respond within fifteen (15) business days as required by the DPA.

10. Children and Minors

jl11 is strictly a 21+ platform. We do not knowingly collect personal data from individuals under 21 years of age. If jl11 becomes aware that personal data has been collected from a person under 21, that account will be immediately terminated, all data will be deleted except as required by law, and the matter may be reported to PAGCOR. Parents or guardians who believe their child has registered on jl11 should contact [email protected] immediately.

11. Cross-Border Data Transfers

In the course of providing gaming services, certain personal data may be transferred to and processed by jl11's game software providers and technology partners located outside the Philippines (including but not limited to servers in Southeast Asia and other regions). All cross-border data transfers are conducted in compliance with Section 21 of the Data Privacy Act and its IRR. jl11 ensures that recipient entities implement data protection standards equivalent to those required under Philippine law through contractual data processing agreements.

12. Changes to This Privacy Policy

jl11 may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or platform services. When material changes are made, jl11 will notify registered players via the email address on their account at least fourteen (14) days before the changes take effect. The updated Policy will be published on this page with a revised effective date. Continued use of jl11 following notification of changes constitutes acceptance of the updated Policy.

13. Contact and Data Privacy Officer

For any privacy-related inquiries, requests to exercise your data subject rights, or to report a potential data breach, please contact jl11's designated Data Privacy Officer:

If you are not satisfied with jl11's response to your privacy request, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.