11vipph Privacy Policy

1. Overview

11vipph ("we," "us," or "our") is the data controller responsible for the personal information of users ("you," "your") who access and use the 11vipph online gaming platform at 11vipph.app. We are committed to protecting your personal data in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the guidelines issued by the National Privacy Commission (NPC).

This Privacy Policy describes our practices regarding the collection, use, storage, disclosure, and protection of personal data. It also outlines the rights available to you as a data subject under Philippine law and how you may exercise those rights.

We process personal data only for legitimate, specified, and explicit purposes. We do not sell your personal data to third parties for their own marketing purposes.

2. Data We Collect

Depending on how you interact with the 11vipph platform, we may collect the following categories of personal data:

2.1 Identity & Contact Data

• Full legal name, date of birth, nationality
• Government-issued ID number (e.g., PhilSys ID, passport, driver's license)
• Email address, mobile number
• Residential address (city, province, region — e.g., Metro Manila, Cebu, Davao)

2.2 Account & Authentication Data

• Username and encrypted password
• Security questions and answers
• Two-factor authentication (2FA) records
• Login timestamps and session identifiers

2.3 Financial Data

• GCash or Maya account reference (masked)
• Bank account details for withdrawal processing (BPI, BDO, Metrobank, UnionBank, etc.)
• Debit card details (masked, last 4 digits only)
• Transaction history: deposits, withdrawals, bonuses, and game wagers in Philippine Peso (₱)

2.4 Gaming & Behavioral Data

• Game history, bet amounts, win/loss records
• Session duration and frequency of play
• Responsible gaming tool usage (deposit limits, self-exclusion requests)
• Bonus and promotion redemption history

2.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system, browser type and version
• Referring URL and pages visited on the 11vipph platform
• Cookie identifiers and similar tracking technologies

2.6 Communications Data

• Customer support chat logs and email correspondence
• Survey responses and feedback submissions
• Promotional opt-in preferences

3. How We Collect Your Data

11vipph collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making deposits or withdrawals, or contacting customer support.
• Automated collection: Technical data collected automatically when you access the platform, including via cookies, web beacons, and server logs.
• Third-party sources: Identity verification data from licensed KYC/AML service providers; payment confirmation data from GCash, Maya, and banking partners; fraud detection signals from security service providers.
• Regulatory sources: Data shared with us by PAGCOR or other regulatory bodies in connection with compliance obligations.

4. Purpose of Processing

We process your personal data for the following specific purposes:

We do not use your personal data for automated decision-making that produces significant legal effects without human review.

5. Legal Basis for Processing

Under the Philippine Data Privacy Act, 11vipph processes your personal data on the following legal bases:

• Contractual necessity: Processing required to fulfill our obligations under the Terms & Conditions you agreed to upon registration (e.g., account management, payment processing, game delivery).
• Legal obligation: Processing required to comply with Philippine law, including Anti-Money Laundering Act (AMLA) obligations, PAGCOR regulatory requirements, and NPC data protection rules.
• Legitimate interests: Processing for fraud prevention, platform security, and responsible gaming monitoring, where our interests do not override your fundamental rights.
• Consent: Processing for marketing communications and optional analytics features, where you have given explicit, informed consent that you may withdraw at any time.

6. Data Sharing & Disclosure

11vipph does not sell your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors: GCash, Maya, and banking partners (BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank) to process your financial transactions.
• KYC/AML service providers: Licensed identity verification and anti-money laundering screening providers operating under data processing agreements.
• Game software providers: Third-party game studios that supply games on the 11vipph platform, limited to data necessary for game delivery and fairness auditing.
• Regulatory authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and law enforcement agencies, where required by law or court order.
• IT and security service providers: Cloud hosting, cybersecurity, and fraud detection vendors operating under strict confidentiality and data processing agreements.

All third-party service providers are contractually required to process your data only on our instructions and in compliance with applicable Philippine data protection law.

7. Data Retention

11vipph retains your personal data for as long as necessary to fulfill the purposes for which it was collected, subject to the following minimum retention periods:

• Account and identity data: Retained for the duration of your account and for a minimum of five (5) years after account closure, in compliance with AMLA record-keeping requirements.
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction.
• Gaming history: Retained for a minimum of three (3) years from the date of each gaming session.
• Customer support records: Retained for two (2) years from the date of the last interaction.
• Marketing consent records: Retained until consent is withdrawn, plus one (1) year for audit purposes.

After the applicable retention period, personal data is securely deleted or anonymized in accordance with NPC guidelines.

8. Data Security

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

• SSL/TLS encryption for all data transmitted between your device and the 11vipph platform;
• AES-256 encryption for sensitive data stored at rest;
• Multi-factor authentication options for account access;
• Regular security audits and penetration testing by independent third parties;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Incident response procedures aligned with NPC breach notification requirements.

9. Cookies & Tracking Technologies

11vipph uses cookies and similar tracking technologies to enhance your experience on the platform. The types of cookies we use include:

• Strictly necessary cookies: Required for the platform to function, including session management and security tokens. These cannot be disabled.
• Functional cookies: Remember your preferences such as language settings and display options.
• Analytics cookies: Collect aggregated, anonymized data about how users interact with the platform to help us improve performance and usability.
• Marketing cookies: Used only with your explicit consent to deliver relevant promotional content within the 11vipph platform.

You can manage your cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the 11vipph platform. We do not use third-party advertising cookies that track you across external websites.

10. Your Data Subject Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 11vipph:

• Right to be informed: You have the right to know what personal data we collect and how it is processed — which this Privacy Policy fulfills.
• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request correction of inaccurate or incomplete personal data.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose it was collected, subject to our legal retention obligations.
• Right to object: You may object to processing based on legitimate interests or for direct marketing purposes.
• Right to data portability: You may request your personal data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on consent, you may withdraw it at any time without affecting the lawfulness of prior processing.
• Right to lodge a complaint: You have the right to file a complaint with the National Privacy Commission (NPC) if you believe your data rights have been violated.

To exercise any of these rights, please contact our Data Protection Officer using the details in Section 14. We will respond to verified requests within fifteen (15) business days in accordance with NPC guidelines.

11. Minors & Age Policy

As part of our KYC verification process, all registered users are required to submit a valid government-issued ID confirming they are at least 21 years old. This requirement is mandated by PAGCOR regulations and Philippine law governing online gambling activities.

If you are a parent or guardian and believe your child has registered on the 11vipph platform, please contact our Data Protection Officer immediately at the details provided in Section 14.

12. Cross-Border Data Transfers

In certain circumstances, your personal data may be transferred to and processed in countries outside the Philippines — for example, where our game software providers or cloud infrastructure partners operate servers in other jurisdictions.

Where such transfers occur, 11vipph ensures that appropriate safeguards are in place in accordance with NPC guidelines on cross-border data transfers, including:

• Data processing agreements incorporating standard contractual clauses approved by the NPC;
• Transfers only to countries or organizations that provide an adequate level of data protection;
• Your explicit consent where required by applicable law.

You may request information about the specific safeguards applicable to any cross-border transfer of your data by contacting our Data Protection Officer.

13. Changes to This Privacy Policy

11vipph reserves the right to update or modify this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or regulatory requirements. When we make material changes, we will:

• Update the "Last Updated" date at the top of this page;
• Display a prominent notice on the 11vipph platform for a reasonable period following the change;
• Where required by law, notify registered users via email or in-platform notification.

Your continued use of the 11vipph platform after the effective date of any revised Privacy Policy constitutes your acknowledgment of the changes. We encourage you to review this page periodically to stay informed about how we protect your data.

14. Contact & Data Protection Officer

11vipph has appointed a Data Protection Officer (DPO) in compliance with the Philippine Data Privacy Act. If you have any questions, concerns, or requests regarding this Privacy Policy or the processing of your personal data, please contact: