Privacy Policy

1 Scope & Application

This Privacy Policy applies to all personal data collected, processed, stored, or transmitted by jli11 in connection with your use of the jli11 online gaming platform, including the website accessible at jli11.net, any associated mobile interface, the jli11 wallet system, live casino services, sports betting markets, slot games, and bingo products.

This policy applies to all registered players, prospective players who browse the platform without registering, and any individual who contacts jli11 through our support channels. It applies regardless of where in the Philippines you are located — whether you are playing from Metro Manila, Cebu City, Davao, Quezon City, Makati, or any other part of the archipelago.

By registering an account on jli11 or continuing to use the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein.

2 Information We Collect

jli11 collects personal information from you in the following categories, depending on how you interact with our platform:

jli11 does not collect sensitive personal information such as biometric data beyond the liveness check required for KYC, political opinions, religious beliefs, or health information, unless expressly required by a PAGCOR regulatory obligation.

3 How We Use Your Data

jli11 uses your personal information for the following specific purposes:

• Account Management: To create, maintain, and administer your jli11 player account, including processing login requests, managing your wallet balance, and applying responsible gaming settings.
• Identity Verification & KYC: To verify your identity in compliance with PAGCOR's Know Your Customer requirements and the Anti-Money Laundering Act (AMLA) of the Philippines, prior to processing withdrawals or when required by our compliance team.
• Payment Processing: To facilitate deposits and withdrawals through your chosen Philippine payment method — GCash, PayMaya, BPI, BDO, or Metrobank — and to maintain an accurate record of all financial transactions on your account.
• Fraud Prevention & Security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, collusion, unauthorised account access, and any other conduct that may violate our Terms & Conditions or Philippine law.
• Customer Support: To respond to your enquiries, resolve disputes, process complaints, and provide assistance through our 24/7 live chat and email support channels.
• Legal & Regulatory Compliance: To fulfil jli11's obligations under PAGCOR regulations, the Data Privacy Act of 2012, the AMLA, and any other applicable Philippine legislation, including responding to lawful requests from government authorities.
• Platform Improvement: To analyse aggregated usage data, identify technical issues, improve the player experience, and develop new features across the jli11 gaming platform.
• Marketing Communications: To send you personalised promotional offers, bonus notifications, and platform updates — but only where you have opted in to receive such communications. You may withdraw your marketing consent at any time through your account settings or by contacting support.
• Responsible Gaming: To monitor gaming patterns, apply self-imposed limits, flag potential problem gambling indicators, and contact you where our responsible gaming team identifies a concern requiring follow-up.

4 Legal Bases for Processing

Under the Data Privacy Act of 2012 (RA 10173), jli11 processes your personal data on the following legal bases:

• Consent: Where you have given clear and informed consent to a specific processing activity, such as receiving marketing communications or participating in optional loyalty programmes.
• Contractual Necessity: Where processing is necessary to perform the contract between you and jli11, including account registration, payment processing, and delivery of gaming services.
• Legal Obligation: Where processing is required by applicable Philippine law, including PAGCOR regulations, the Anti-Money Laundering Act, and orders from the National Privacy Commission or other competent authorities.
• Legitimate Interest: Where processing is necessary for jli11's legitimate business interests — such as fraud prevention, platform security, and business analytics — provided those interests are not overridden by your rights and freedoms as a data subject.

5 Sharing Your Information

jli11 does not sell, rent, or trade your personal information to any third party. We may share your data only in the following limited and controlled circumstances:

• Payment Processors: We share the minimum necessary financial information with GCash, PayMaya, BPI, BDO, and Metrobank to process deposits and withdrawals on your behalf. These providers are bound by their own data protection obligations under Philippine law.
• Identity Verification Providers: We work with PAGCOR-approved KYC and identity verification service providers to validate government-issued IDs and perform liveness checks as required for compliance. These providers process your data solely for verification purposes.
• Game Providers: Where you play games supplied by third-party game studios integrated into the jli11 platform, anonymised or pseudonymised gameplay data (such as bet amounts and round outcomes) may be shared with those providers for game integrity and RTP certification purposes.
• Regulatory & Law Enforcement Authorities: jli11 is legally obligated to disclose player information to PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission (NPC), or any other competent Philippine authority when required by law, regulation, or valid legal process.
• Professional Advisors: We may share data with our legal counsel, auditors, or compliance consultants under strict confidentiality obligations where necessary to obtain professional advice.

In all cases where personal data is shared with third parties, jli11 ensures that appropriate data processing agreements and confidentiality obligations are in place, consistent with RA 10173 requirements.

6 Cookies & Tracking Technologies

The jli11 platform uses cookies and similar tracking technologies to operate correctly, enhance the player experience, and analyse platform usage. The types of cookies used on jli11 are as follows:

Strictly necessary cookies cannot be disabled as they are essential for the platform to function. You may manage your preferences for functional, analytics, and marketing cookies through your browser settings. Note that disabling certain cookies may affect the functionality of some jli11 features.

7 Data Retention

jli11 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. Our standard data retention periods are as follows:

• Account and Registration Data: Retained for the duration of your active account plus 5 years following permanent account closure, in compliance with PAGCOR record-keeping requirements and the AMLA's 5-year retention rule.
• KYC and Identity Documents: Retained for 5 years from the date of submission or account closure, whichever is later, as required by PAGCOR and AMLC regulations.
• Financial Transaction Records: Retained for 5 years from the date of each transaction, in compliance with AMLA and PAGCOR financial reporting obligations.
• Gaming Activity Logs: Retained for 3 years from the date of each recorded gaming session, for dispute resolution and regulatory audit purposes.
• Communications and Support Records: Retained for 2 years from the date of the last communication, unless the subject matter relates to an ongoing dispute or regulatory investigation.
• Marketing Preferences: Retained until you withdraw consent or request deletion, whichever comes first.

Upon expiry of the applicable retention period, jli11 will securely delete or anonymise your personal data in accordance with NPC-approved data disposal protocols, unless a legal obligation requires continued retention.

8 Data Security

jli11 implements comprehensive technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, loss, or destruction. Our security infrastructure includes:

• 256-bit SSL/TLS Encryption: All data in transit between your browser or app and jli11 servers is encrypted using industry-standard 256-bit SSL/TLS protocols.
• Encryption at Rest: Sensitive personal data stored on jli11 servers — including KYC documents and financial records — is encrypted at rest using AES-256 encryption.
• Access Control & Role-Based Permissions: Internal access to personal data is restricted by role-based access controls. Staff access to player data is logged, monitored, and regularly audited.
• Multi-Factor Authentication: Administrative access to jli11 back-end systems requires multi-factor authentication, reducing the risk of credential-based breaches.
• Regular Security Assessments: jli11 conducts periodic vulnerability assessments and penetration testing of its platform infrastructure to identify and remediate security weaknesses before they can be exploited.
• Data Breach Response: In the event of a personal data breach that poses a risk to your rights and freedoms, jli11 will notify the National Privacy Commission within 72 hours of becoming aware of the breach, and will notify affected players without undue delay as required by RA 10173.

9 Your Rights as a Data Subject

Under the Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by jli11:

• Right to be Informed: You have the right to know what personal data jli11 collects about you, how it is used, and with whom it is shared — as described in this Privacy Policy.
• Right to Access: You may request a copy of the personal data jli11 holds about you at any time. jli11 will respond to access requests within 15 business days.
• Right to Rectification: If any personal data jli11 holds about you is inaccurate, incomplete, or outdated, you have the right to request correction. You may update certain details directly through your account profile, or contact support for assistance.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes it was collected, or where you withdraw consent and there is no other legal basis for continued processing. Note that deletion requests may be subject to jli11's legal retention obligations under PAGCOR and AMLA regulations.
• Right to Object: You have the right to 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 jli11's assessment of overriding legitimate grounds.
• Right to Data Portability: You may request that jli11 provide your personal data in a structured, commonly used, and machine-readable format where technically feasible.
• Right to File a Complaint: If you believe jli11 has violated your data privacy rights, you have the right to file a complaint with the National Privacy Commission of the Philippines at privacy.gov.ph.

To exercise any of the above rights, please contact our Data Protection Officer at [email protected] with the subject line "Data Subject Rights Request" and a clear description of your request. We may require verification of your identity before processing any such request.

10 Children & Minors

jli11 is strictly an adult gaming platform. In accordance with PAGCOR regulations and the Philippine laws governing online gambling, access to and participation in jli11's gaming services is restricted to individuals aged 21 years and above.

jli11 does not knowingly collect personal data from individuals under the age of 21. If you are under 21, you are not permitted to register an account, make a deposit, or participate in any gaming activity on the jli11 platform.

Where jli11 discovers that personal data has been collected from an individual under the age of 21, we will immediately close the associated account, return any deposited funds to the original payment method where possible, delete all personal data associated with the minor, and report the incident to PAGCOR as required.

11 International Data Transfers

jli11 operates primarily within the Philippines and prioritises keeping your personal data within Philippine jurisdiction wherever possible. However, certain operational requirements — such as the use of internationally hosted game provider servers, KYC verification technology, or cloud infrastructure — may involve the transfer of some personal data to servers or service providers located outside the Philippines.

Where such international transfers occur, jli11 ensures that adequate safeguards are in place to protect your personal data to a standard at least equivalent to that required by RA 10173, including:

• Contractual clauses requiring the overseas recipient to comply with Philippine data protection standards.
• Verification that the receiving jurisdiction has been assessed as providing adequate data protection under NPC guidelines.
• Explicit consent from you where required and where no other adequate safeguard is available.

jli11 does not transfer personal data to jurisdictions that the NPC has identified as providing inadequate data protection without first putting in place approved safeguard mechanisms.

12 Policy Amendments

jli11 may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable Philippine law, PAGCOR regulatory requirements, or our platform's features and services.

When material changes are made to this Privacy Policy, jli11 will notify registered players via the email address associated with their account at least 7 calendar days before the amended policy takes effect. The updated Privacy Policy will also be published on this page with a revised effective date clearly displayed at the top of the document.

Your continued use of the jli11 platform following publication of an amended Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with any amendments, you must stop using the platform and request account closure by contacting our support team.

13 Contact & Data Protection Officer

jli11 has appointed a Data Protection Officer (DPO) in accordance with Section 21 of the Data Privacy Act of 2012. If you have any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data, please contact our DPO through the following channels:

• Email: [email protected] — use subject line "Privacy / DPO Enquiry"
• Live Chat: Available 24/7 via the jli11 platform — mention your request is privacy-related so it can be routed directly to our DPO team

jli11 is committed to resolving all privacy-related enquiries promptly and fairly. If you are not satisfied with our response, you have the right to escalate your complaint to the National Privacy Commission of the Philippines.