11ph5 Privacy Policy

1. Who We Are

This Privacy Policy is issued by 11ph5 ("11ph5," "we," "us," or "our"), the operator of the online gaming platform accessible at 11ph5.net and any associated mobile applications or digital services (collectively, the "Platform").

11ph5 acts as the Personal Information Controller (as defined under Republic Act No. 10173, the Data Privacy Act of 2012) with respect to the personal data of registered players and visitors to the Platform. This means we determine the purposes and means by which your personal data is processed.

This Privacy Policy applies to all personal data collected from you when you visit, register on, or use the 11ph5 Platform, including when you contact our support team, participate in promotions, or interact with us through any other channel.

2. Personal Data We Collect

11ph5 collects the following categories of personal data from players and Platform visitors:

We do not intentionally collect sensitive personal information (as defined under the Data Privacy Act) unless strictly required for regulatory compliance, such as government-issued ID details for KYC purposes. Where sensitive data is collected, we apply heightened security and access controls.

3. How We Collect Your Data

11ph5 collects personal data through the following means:

• Direct collection: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical data collected automatically when you access the Platform, including through cookies, web beacons, log files, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud and risk data from payment processors; publicly available information where permitted by law.
• Payment providers: Transaction confirmation data from GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners used to process your deposits and withdrawals.

4. How We Use Your Personal Data

11ph5 uses your personal data for the following purposes:

• Account management: Creating and maintaining your 11ph5 player account, verifying your identity, and managing your account settings.
• Service delivery: Processing bets and wagers, crediting winnings, processing deposits and withdrawals, and providing access to all Platform features.
• Regulatory compliance: Fulfilling our obligations under Philippine gaming regulations, the Anti-Money Laundering Act (AMLA), the Data Privacy Act of 2012, and PAGCOR requirements, including reporting suspicious transactions to the Anti-Money Laundering Council (AMLC).
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent activity, money laundering, multi-accounting, and other prohibited conduct on the Platform.
• Responsible gaming: Monitoring gaming activity to identify potential problem gambling behaviors and applying responsible gaming tools where appropriate.
• Customer support: Responding to your inquiries, resolving disputes, and providing technical assistance.
• Marketing and promotions: Sending you information about 11ph5 promotions, bonuses, and new features, where you have consented to receive such communications. You may opt out at any time.
• Platform improvement: Analyzing usage patterns and technical data to improve the performance, security, and user experience of the Platform.

5. Legal Basis for Processing

Under the Data Privacy Act of 2012, 11ph5 processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform our obligations under the Terms & Conditions you agreed to when registering your account, including delivering gaming services and processing financial transactions.
• Legal obligation: Processing required to comply with applicable Philippine laws and regulations, including AMLA reporting obligations, PAGCOR regulatory requirements, and NPC directives.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where such interests are not overridden by your data protection rights.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6. Data Sharing and Disclosure

11ph5 does not sell your personal data to third parties. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection safeguards:

• KYC and identity verification providers: To verify your identity and age as required for account registration and withdrawal processing.
• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment partners, to process your deposits and withdrawals.
• Regulatory and law enforcement authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other Philippine government authorities, where required by law or court order.
• IT and platform service providers: Cloud hosting, cybersecurity, and technical support providers who process data on our behalf under strict data processing agreements.
• Fraud prevention services: Third-party fraud detection and risk management providers used to protect the integrity of the Platform.

All third-party service providers who process personal data on behalf of 11ph5 are required to implement appropriate technical and organizational security measures and to process data only in accordance with our instructions and applicable law.

7. Cookies and Tracking Technologies

11ph5 uses cookies and similar tracking technologies (such as web beacons and local storage) to operate and improve the Platform. Cookies are small text files stored on your device when you visit the Platform.

We use the following types of cookies:

• Strictly necessary cookies: Essential for the Platform to function, including session management, login authentication, and security features. These cannot be disabled without affecting Platform functionality.
• Performance and analytics cookies: Used to collect anonymized data about how players use the Platform, helping us identify areas for improvement.
• Functional cookies: Used to remember your preferences, such as language settings and display options, to personalize your experience.
• Marketing cookies: Used to deliver relevant promotional content about 11ph5 features and offers, where you have consented to receive such content.

You can manage or disable non-essential cookies through your browser settings at any time. Please note that disabling certain cookies may affect the functionality of the Platform.

8. Data Retention

11ph5 retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, and reporting requirements.

Specific retention periods include:

• Account and KYC data: Retained for a minimum of five (5) years after account closure, as required under Philippine AMLA regulations.
• Transaction and gaming records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with PAGCOR and AMLA requirements.
• Support communications: Retained for two (2) years from the date of the last communication, unless a longer period is required for dispute resolution.
• Marketing data: Retained until you withdraw consent or request deletion, subject to any overriding legal retention obligations.

When personal data is no longer required, 11ph5 will securely delete or anonymize it in accordance with our data disposal procedures.

9. Data Security

11ph5 implements appropriate technical and organizational measures to protect your personal data against unauthorized access, accidental loss, destruction, alteration, or disclosure. Our security measures include:

• SSL/TLS encryption for all data transmitted between your device and the Platform.
• Encryption of sensitive data at rest, including financial and identity information.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security assessments, penetration testing, and vulnerability scanning.
• Multi-factor authentication for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 11ph5 will notify the National Privacy Commission (NPC) within seventy-two (72) hours of becoming aware of the breach, and will notify affected data subjects without undue delay, in accordance with NPC Circular No. 16-03.

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 11ph5:

• Right to be informed: You have the right to be informed of how your personal data is collected, used, and processed, as set out in this Privacy Policy.
• Right of access: You may request a copy of the personal data we hold about you, along with information about how it is being processed.
• Right to rectification: You may request correction of any inaccurate or incomplete personal data we hold about you.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to overriding legal retention obligations.
• Right to object: You may object to the processing of your personal data for direct marketing purposes at any time. You may also object to processing based on legitimate interests, subject to our demonstrating compelling legitimate grounds.
• Right to data portability: You may request that we provide your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to lodge a complaint: You have the right to lodge a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Privacy Request." We will respond to all valid requests within thirty (30) days, or within the timeframe required by applicable law.

11. Children's Privacy

The 11ph5 Platform is strictly intended for persons aged 21 years and above. We do not knowingly collect personal data from individuals under 21 years of age. If we become aware that personal data has been collected from a person under 21, we will take immediate steps to delete that data and close the associated account.

If you believe that a minor has registered on the 11ph5 Platform, please contact us immediately at [email protected] so that we can investigate and take appropriate action.

12. Cross-Border Data Transfers

Where 11ph5 transfers personal data outside the Philippines — for example, to cloud hosting providers or technology partners operating in other jurisdictions — we ensure that such transfers are subject to appropriate safeguards in accordance with the Data Privacy Act of 2012 and NPC guidelines. These safeguards may include contractual clauses, data processing agreements, or transfers to jurisdictions recognized as providing an adequate level of data protection.

We will not transfer your personal data to a foreign jurisdiction unless we are satisfied that adequate protections are in place to ensure the continued security and integrity of your data.

13. Updates to This Privacy Policy

11ph5 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 via email or an in-platform notification prior to the changes taking effect.

The "Last Updated" date at the top of this page indicates when the most recent revision was made. We encourage you to review this Privacy Policy periodically to stay informed about how 11ph5 protects your personal data. Your continued use of the Platform after any amendment constitutes your acceptance of the revised Policy.

14. Contact Our Data Protection Officer

If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data by 11ph5, please contact our Data Protection Officer:

• Email: [email protected]
• Subject line: "Data Privacy Request" or "Privacy Policy Inquiry"
• Support Hours: Daily, 8AM to 12MN (Manila time)

You also have the right to lodge a complaint directly with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have not been adequately addressed by 11ph5.

This Privacy Policy was last updated in January 2026. By continuing to use the 11ph5 Platform, you confirm that you have read and understood this Privacy Policy and consent to the processing of your personal data as described herein.