1 Introduction
This Privacy Policy ("Policy") describes how 11phjoy ("we," "us," or "our") collects, uses, stores, shares, and protects the personal information of users ("you" or "Player") who access or use the 11phjoy website, mobile application, and associated gaming services (collectively, the "Platform").
11phjoy is committed to protecting the privacy and personal data of all Filipino players in accordance with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (DPA), its Implementing Rules and Regulations (IRR), and the issuances of the National Privacy Commission (NPC) of the Philippines.
By registering an account on 11phjoy or otherwise using the Platform, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree to this Policy, please discontinue use of the Platform immediately.
This Policy should be read together with our Terms & Conditions and Responsible Gaming Policy, which are incorporated by reference.
2 Data We Collect
11phjoy collects personal data that is necessary to provide you with a safe, compliant, and enjoyable gaming experience. The categories of personal data we collect include:
2.1 Registration & Identity Data
- Full legal name as it appears on a government-issued ID
- Date of birth (for age verification — you must be 21 or older)
- Philippine mobile number and email address
- Username and encrypted password
- Residential address (province, city/municipality)
2.2 Identity Verification (KYC) Data
- Government-issued photo ID (e.g., PhilSys National ID, passport, driver's licence, SSS/GSIS ID, PRC ID, voter's ID)
- Selfie or live photo for facial verification purposes
- Proof of address documents where required
2.3 Financial Data
- GCash or Maya account reference (mobile number only — we do not store full wallet credentials)
- Bank account name and last four digits for withdrawal verification
- Transaction history: deposits, withdrawals, wager amounts, and bonus usage
2.4 Technical & Usage Data
- IP address and approximate geolocation (province/city level)
- Device type, operating system, and browser information
- Session duration, pages visited, and features used on the Platform
- Login timestamps and access logs
2.5 Communications Data
- Records of your communications with 11phjoy customer support via live chat or email
- Feedback, survey responses, and promotional opt-in preferences
3 How We Use Your Data
11phjoy processes your personal data for the following specific purposes:
- Account Management: To create, maintain, and administer your 11phjoy player account, including processing deposits, withdrawals, and bonus credits.
- Identity Verification (KYC): To verify your identity and confirm that you meet the minimum age requirement of 21 years, as mandated by Philippine gaming regulations.
- Regulatory Compliance: To fulfil our obligations under PAGCOR licensing requirements, the Anti-Money Laundering Act (AMLA), and the Data Privacy Act of 2012.
- Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, unauthorized account access, money laundering, and other prohibited conduct on the Platform.
- Responsible Gaming: To monitor gaming behaviour and identify players who may be at risk of problem gambling, and to administer self-exclusion, deposit limit, and cooling-off requests.
- Customer Support: To respond to your enquiries, resolve disputes, and provide technical assistance.
- Platform Improvement: To analyse usage patterns and improve the performance, features, and user experience of the 11phjoy Platform.
- Marketing Communications: To send you promotional offers, bonus notifications, and platform updates — but only where you have provided explicit consent to receive such communications. You may withdraw consent at any time.
4 Legal Basis for Processing
Under the Data Privacy Act of 2012 and its IRR, 11phjoy processes your personal data on the following legal bases:
- Contractual Necessity: Processing is necessary to perform our obligations under the Terms & Conditions you agreed to upon registration — including account management, payment processing, and game provision.
- Legal Obligation: Processing is required to comply with applicable Philippine laws, including PAGCOR regulations, AMLA obligations, and NPC directives.
- Legitimate Interests: Processing is necessary for our legitimate interests in operating a secure, fair, and commercially viable gaming platform — including fraud prevention, security monitoring, and platform analytics — provided these interests are not overridden by your rights and freedoms.
- Consent: For marketing communications and non-essential cookies, we rely on your freely given, specific, and informed consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.
5 Data Sharing
11phjoy does not sell, rent, or trade your personal data to third-party marketers or data brokers under any circumstances. We may share your personal data with the following categories of recipients, strictly on a need-to-know basis:
- Payment Processors: GCash, Maya, and partner banks receive only the minimum data necessary to process your deposit or withdrawal transactions.
- Identity Verification Providers: Third-party KYC service providers who assist in verifying your identity documents and age. These providers are contractually bound to process your data only for verification purposes.
- Game Software Providers: Game providers may receive anonymised or pseudonymised session data necessary to deliver game content and calculate RTP. They do not receive your full identity data.
- Regulatory Authorities: PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), and other competent Philippine government authorities, where disclosure is required by law or regulatory directive.
- Law Enforcement: Philippine law enforcement agencies, where disclosure is required pursuant to a valid court order, subpoena, or legal process.
- IT & Security Service Providers: Cloud hosting, cybersecurity, and platform infrastructure providers who process data on our behalf under strict data processing agreements.
All third-party service providers engaged by 11phjoy are required to implement appropriate technical and organisational security measures and to process personal data only in accordance with our documented instructions.
6 Data Retention
11phjoy retains your personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law and regulatory obligations. Our standard retention periods are as follows:
- Account Data: Retained for the duration of your active account, plus a minimum of five (5) years following account closure, in compliance with AMLA record-keeping requirements.
- KYC & Identity Documents: Retained for a minimum of five (5) years from the date of verification, or longer if required by PAGCOR or AMLC directives.
- Transaction Records: Retained for a minimum of five (5) years in accordance with AMLA obligations.
- Customer Support Records: Retained for three (3) years from the date of the last interaction.
- Marketing Consent Records: Retained for as long as you remain subscribed, plus one (1) year following withdrawal of consent.
- Technical Logs: Retained for up to twelve (12) months for security and fraud investigation purposes.
Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with NPC-approved data disposal procedures.
7 Cookies & Tracking
11phjoy uses cookies and similar tracking technologies to operate the Platform effectively and improve your experience. The types of cookies we use are:
- Strictly Necessary Cookies: Essential for the Platform to function. These include session authentication cookies and security tokens. They cannot be disabled without affecting core Platform functionality.
- Performance & Analytics Cookies: Used to collect anonymised data about how players use the Platform — such as which pages are visited most frequently and where errors occur — to help us improve performance.
- Functional Cookies: Used to remember your preferences, such as language settings and responsible gaming limit configurations, to personalise your experience.
- Marketing Cookies: Used only with your explicit consent to deliver relevant promotional content. You may opt out of marketing cookies at any time through your account settings.
You can manage your cookie preferences through your browser settings. Please note that disabling strictly necessary cookies may impair your ability to use certain features of the 11phjoy Platform.
8 Data Security
11phjoy implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:
- 256-bit TLS Encryption: All data in transit between your device and 11phjoy servers is encrypted using industry-standard TLS 1.2 or higher.
- Encryption at Rest: Sensitive personal data stored on our servers — including identity documents and financial records — is encrypted at rest using AES-256 encryption.
- Access Controls: Access to personal data is restricted to authorised 11phjoy personnel on a strict need-to-know basis, enforced through role-based access controls and multi-factor authentication.
- Regular Security Audits: The Platform undergoes regular penetration testing and security audits conducted by independent cybersecurity professionals.
- Incident Response: In the event of a personal data breach, 11phjoy will notify affected players and the National Privacy Commission within 72 hours of becoming aware of the breach, in accordance with NPC Circular No. 16-03.
While we take every reasonable precaution to protect your data, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your 11phjoy login credentials and for notifying us immediately of any suspected unauthorised access to your account.
9 Your Rights
Under the Data Privacy Act of 2012, you have the following rights with respect to your personal data held by 11phjoy:
- Right to be Informed: The right to be informed of how your personal data is collected, used, and shared — as set out in this Policy.
- Right of Access: The right to request a copy of the personal data we hold about you, including information on how it has been processed.
- Right to Rectification: The right to request correction of inaccurate or incomplete personal data. You may update most account information directly through your 11phjoy account settings.
- Right to Erasure: The right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to our legal and regulatory retention obligations.
- Right to Object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on our legitimate interests.
- Right to Data Portability: The right to receive your personal data in a structured, commonly used, and machine-readable format, where technically feasible.
- Right to Lodge a Complaint: The right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines if you believe your data privacy rights have been violated.
To exercise any of these rights, please contact our Data Protection Officer at the details provided in Section 13 of this Policy. We will respond to all verified requests within fifteen (15) business days.
10 Children's Privacy
The 11phjoy Platform is strictly intended for adults aged 21 years and older, in accordance with Philippine gaming law. We do not knowingly collect personal data from individuals under the age of 21.
If we become aware that personal data has been collected from a person under 21 years of age, we will immediately suspend the associated account, delete the data in question, and report the incident to PAGCOR as required by our licensing obligations.
If you are a parent or guardian and believe that a minor has registered on the 11phjoy Platform, please contact our support team immediately so that we can take appropriate action.
11 Third-Party Links
The 11phjoy Platform may contain links to third-party websites or services — such as payment provider portals — that are not operated by 11phjoy. This Privacy Policy applies solely to the 11phjoy Platform and does not govern the data practices of any third-party websites.
We encourage you to review the privacy policies of any third-party services you access through links on the 11phjoy Platform. 11phjoy accepts no responsibility or liability for the privacy practices or content of third-party websites.
12 Policy Updates
11phjoy reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable Philippine law, or NPC regulatory guidance. When material changes are made, we will notify registered players via email or a prominent notice on the Platform at least seven (7) days before the changes take effect.
The "Last Updated" date at the top of this page reflects the date of the most recent revision. Your continued use of the 11phjoy Platform following the effective date of any revised Policy constitutes your acceptance of the updated terms.
We encourage you to review this Policy periodically to stay informed about how 11phjoy protects your personal data.
13 Contact & DPO
11phjoy has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Data Privacy Act of 2012 and this Privacy Policy. If you have any questions, concerns, or requests regarding your personal data, please contact us through the following channels:
- Data Protection Officer Email: [email protected]
- General Support Email: [email protected]
- Live Chat: Available 24/7 through the 11phjoy Platform
- Response Time: We aim to respond to all data privacy requests within fifteen (15) business days.
If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission (NPC) of the Philippines.