Privacy Policy – 11phwin Member Data Protection & Your Rights

11phwin operates as the data controller for all personal information collected through the platform. As data controller, 11phwin determines the purposes and means by which your personal data is processed, and bears responsibility for ensuring that processing is carried out lawfully, fairly, and transparently in accordance with Philippine law.

11phwin is an online sports betting and casino gaming platform serving Filipino members. The platform is designed primarily for users in the Philippines, and all data practices described in this Privacy Policy are shaped by the requirements and expectations of Filipino members and Philippine regulators.

11phwin collects personal data through several channels: account registration, identity verification (KYC), payment processing, platform usage, and direct communications with our support team. The categories of data we collect are described below.

11phwin does not collect sensitive personal data as defined under RA 10173 (such as health information, religious beliefs, or political opinions) unless specifically required for a defined compliance purpose, in which case your explicit consent will be sought.

11phwin uses your personal data strictly for the purposes outlined below. We do not use your data for purposes that are incompatible with those you consented to at registration, and we do not engage in profiling for advertising purposes using third-party data brokers.

• Account Management: To create, operate, and maintain your 11phwin member account, verify your identity, and ensure only you can access your account.
• Payment Processing: To process deposits and withdrawals through GCash, Maya, bank transfers, and card payments — and to maintain accurate financial records required by law.
• Regulatory Compliance: To fulfil our Know Your Customer (KYC), Anti-Money Laundering (AML), and gaming licence obligations under applicable Philippine law. This includes verifying your age, identity, and source of funds where required.
• Platform Services: To provide sports betting, casino gaming, live in-play betting, promotions, and all other services available at 11phwin, including personalising your platform experience based on your activity.
• Communications: To send you account-related notifications, promotional offers you have opted into, responsible gaming reminders, and service updates via SMS, email, or in-platform message.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, account takeovers, bonus abuse, and other prohibited conduct that could harm you or other 11phwin members.
• Platform Improvement: To analyse aggregated, anonymised usage data to improve 11phwin's platform performance, fix bugs, and develop new features that better serve Filipino members.

Under the Data Privacy Act of 2012 (RA 10173), 11phwin is required to have a lawful basis for each type of personal data processing we carry out. The following bases apply to 11phwin's data processing activities:

• Consent: Where you have provided clear, informed, and voluntary consent — for example, by opting into marketing communications or agreeing to this Privacy Policy during registration.
• Contractual Necessity: Processing required to fulfil our contract with you as a member — including account creation, bet settlement, and payment processing — is conducted on the basis of contractual necessity.
• Legal Obligation: Processing required to comply with Philippine gaming regulations, AML obligations, tax reporting requirements, and other statutory duties is conducted on the basis of legal obligation.
• Legitimate Interests: Processing carried out to protect the security of the platform, prevent fraud, improve services, and ensure fair play is conducted on the basis of 11phwin's legitimate interests, balanced against your rights and expectations as a member.

11phwin shares your personal data only in the limited circumstances described below. We never sell your personal data to third-party marketers, data brokers, or advertisers. All third-party processors are contractually required to handle your data with the same level of care and security that 11phwin applies.

• Payment Service Providers: GCash (Mynt), Maya (Voyager Innovations), GrabPay, Coins.ph, BDO, BPI, UnionBank, and Visa/Mastercard processing networks receive only the financial data necessary to execute your specific transaction. They are not given access to your betting history or broader account data.
• Identity Verification Providers: Where required by KYC compliance, your identity documents may be processed by authorised identity verification service providers operating under confidentiality obligations.
• Gaming Technology Partners: Game providers and platform technology suppliers who power 11phwin's casino and sports betting services receive anonymised or minimal data necessary to deliver those services.
• Philippine Regulatory Authorities: In compliance with our gaming licence obligations, 11phwin may be required to share member data with the relevant Philippine gaming regulatory authority upon lawful request.
• Law Enforcement: 11phwin will cooperate with Philippine law enforcement and judicial authorities where legally required by court order, subpoena, or equivalent legal process.
• Anti-Fraud Networks: To protect our members and platform integrity, 11phwin participates in industry-standard fraud prevention systems. Data shared is limited to fraud-relevant signals and is never used for marketing purposes.

11phwin retains personal data for no longer than is necessary for the purposes for which it was collected, taking into account our legal and regulatory obligations. The following retention periods apply:

• Active Account Data: Retained for the full duration of your active membership at 11phwin, and updated whenever you provide new or corrected information.
• Financial Transaction Records: Retained for a minimum of 5 years after the transaction date, as required by Philippine AML and financial record-keeping regulations.
• KYC Verification Documents: Retained for a minimum of 5 years after account closure or the end of our relationship with you, in compliance with AMLC regulations.
• Support Communications: Retained for 3 years after the last interaction, to allow accurate resolution of any subsequent disputes or regulatory inquiries.
• Platform Usage Logs: Retained for 12 months for platform security and performance purposes, then anonymised or deleted.

11phwin uses cookies and similar tracking technologies to provide a better platform experience. We use only the categories of cookies necessary to operate the service, maintain your session security, and understand how the platform is being used at an aggregate level.

• Strictly Necessary Cookies: These are essential for the platform to function — they maintain your login session, remember your language preference, and enable the bet slip to work correctly. You cannot opt out of these without logging out of your account.
• Performance and Analytics Cookies: These collect anonymised data about how members navigate 11phwin — which pages are visited most, where errors occur, and how features are used. This data helps us improve the platform. No personally identifiable data is included in these analytics.
• Functional Cookies: These remember your preferences (such as odds format or display settings) between sessions so you don't have to re-configure them each time you log in to 11phwin.

Protecting your personal and financial data is a continuous priority at 11phwin. We implement technical and organisational security measures that reflect industry best practices for online gaming platforms operating in the Philippines and across Southeast Asia.

• Encryption: All data transmitted between your device and 11phwin's servers is protected by 256-bit SSL/TLS encryption. Data stored in our systems is encrypted at rest using industry-standard cryptographic protocols.
• Access Controls: Access to member personal data within 11phwin is restricted to employees and contractors who require it to perform specific, documented functions. All access is logged and audited regularly.
• Two-Factor Authentication: 11phwin offers optional two-factor authentication (2FA) for member accounts. We strongly encourage all members to enable 2FA to provide an additional layer of protection against unauthorised access.
• Penetration Testing: 11phwin's platform and infrastructure undergo regular security assessments, including penetration testing by qualified security professionals, to identify and address vulnerabilities before they can be exploited.
• Incident Response: In the event of a data breach that poses a risk to members' rights and freedoms, 11phwin will notify affected members and the National Privacy Commission (NPC) of the Philippines within the timeframe required by RA 10173.

Under Republic Act 10173 (Data Privacy Act of 2012), every Filipino member of 11phwin has specific rights over their personal data. These rights are real, enforceable, and 11phwin is committed to upholding them in full.

11phwin is strictly an adults-only platform. We do not knowingly collect or process personal data from any individual under the age of 18. If you believe a minor has registered an account on 11phwin, please contact our support team immediately so we can investigate and take appropriate action.

During registration, members are required to confirm that they are 18 years of age or older. 11phwin conducts age verification checks as part of the KYC process. Any account found to belong to a minor will be immediately closed and all associated data processed in accordance with our data retention and deletion policies.

11phwin may update this Privacy Policy from time to time to reflect changes in our data practices, updates to Philippine privacy law, or operational changes to the platform. We will always notify members of material changes before they take effect.

• When this Privacy Policy is updated, the "Last Updated" date at the top of this page will be revised to reflect the new effective date.
• For significant changes — such as new categories of data collection or changes to data sharing practices — 11phwin will notify registered members by email and/or prominent in-platform notice at least 7 days before the change takes effect.
• Your continued use of 11phwin after any update to this Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Privacy Policy, you should contact our support team to close your account before the changes take effect.
• Previous versions of this Privacy Policy are available upon written request to our Data Protection Officer for reference and comparison purposes.

For any questions about this Privacy Policy, requests to exercise your data rights, or concerns about how 11phwin handles your personal information, please contact us using the details below. Our support team and Data Protection Officer are committed to responding to all privacy-related inquiries promptly and thoroughly.