ph11com Privacy Policy

01 Who We Are

ph11com ("we," "us," or "our") operates the online gaming platform accessible at ph11com.org and any associated mobile-optimized interfaces. ph11com acts as the Personal Information Controller (PIC) in respect of the personal data of registered users and visitors to the platform, as defined under the Philippine Data Privacy Act of 2012 (Republic Act No. 10173, "DPA") and its Implementing Rules and Regulations.

ph11com operates within the regulatory framework established by the Philippine Amusement and Gaming Corporation (PAGCOR) and is subject to applicable Philippine laws governing online gaming and data privacy. This Privacy Policy applies to all personal data collected through the ph11com platform, including data collected during account registration, gameplay, payment processing, customer support interactions, and general platform use.

02 Personal Data We Collect

ph11com collects the following categories of personal data, depending on how you interact with the platform:

ph11com does not intentionally collect sensitive personal information (as defined under the DPA) beyond what is strictly necessary for identity verification and regulatory compliance. Where sensitive data is collected, it is handled with heightened security controls.

03 How We Collect Your Data

ph11com collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or participating in promotions.
• Automated technologies: Technical and usage data collected automatically when you access the ph11com platform, including through cookies, web beacons, server logs, and similar tracking technologies.
• Third-party sources: Identity verification data from KYC service providers; fraud and AML screening data from compliance partners; payment data from GCash, Maya, and banking partners in connection with transaction processing.
• Publicly available sources: Information from public records or databases where necessary for regulatory compliance or fraud prevention purposes.

04 How We Use Your Personal Data

ph11com uses your personal data for the following purposes:

• To create, verify, and manage your ph11com account, including identity and age verification in compliance with PAGCOR requirements and Philippine law (minimum age: 21 years).
• To process deposits and withdrawals via GCash, Maya, bank transfer, and debit card, and to maintain accurate financial records.
• To comply with Anti-Money Laundering (AML) and Counter-Terrorism Financing (CTF) obligations under Philippine law, including transaction monitoring and suspicious activity reporting.
• To provide customer support and resolve disputes, complaints, or technical issues.
• To enforce our Terms & Conditions, detect and prevent fraud, cheating, and other prohibited conduct, and protect the security and integrity of the ph11com platform.
• To monitor gameplay patterns for responsible gaming purposes, including identifying players who may be exhibiting signs of problem gambling and proactively offering support tools.
• To send you transactional communications (account notices, deposit confirmations, withdrawal updates) and, where you have opted in, promotional communications about ph11com offers and new games.
• To analyze platform usage, improve game offerings, and personalize your ph11com experience.
• To comply with all applicable legal and regulatory obligations, including responding to lawful requests from PAGCOR, the National Privacy Commission (NPC), the Anti-Money Laundering Council (AMLC), and other competent authorities.

05 Legal Basis for Processing

ph11com processes your personal data on the following legal bases under the DPA and its IRR:

• Contractual necessity: Processing required to perform our contract with you (i.e., to operate your ph11com account, process transactions, and provide gaming services).
• Legal obligation: Processing required to comply with applicable Philippine laws, including the DPA, the Anti-Money Laundering Act, PAGCOR regulations, and tax laws.
• Legitimate interests: Processing necessary for ph11com's legitimate interests in fraud prevention, platform security, responsible gaming monitoring, and business analytics, where these interests are not overridden by your rights and freedoms.
• Consent: Where we rely on your consent (e.g., for marketing communications), you may withdraw that consent at any time by contacting ph11com support or updating your account preferences. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

06 Data Sharing & Disclosure

ph11com does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients, strictly on a need-to-know basis and subject to appropriate data protection agreements:

• Payment processors: GCash, Maya, and banking partners, solely for the purpose of processing your deposits and withdrawals.
• KYC and compliance providers: Third-party identity verification and AML screening services engaged to assist ph11com in meeting its regulatory obligations.
• Game software providers: Licensed game studios whose products are available on the ph11com platform, to the extent necessary for game operation and dispute resolution.
• IT and infrastructure providers: Cloud hosting, cybersecurity, and platform maintenance vendors operating under strict data processing agreements.
• Regulatory and law enforcement authorities: PAGCOR, the NPC, the AMLC, the Bureau of Internal Revenue (BIR), and other competent Philippine authorities, where disclosure is required by law or court order.
• Professional advisors: Legal counsel, auditors, and accountants, subject to professional confidentiality obligations.

Any third party receiving your personal data from ph11com is contractually required to process it only for the specified purpose and in accordance with applicable data protection law.

07 Cookies & Tracking Technologies

ph11com uses cookies and similar tracking technologies to operate and improve the platform. The following types of cookies are used:

• Strictly necessary cookies: Essential for platform functionality, including session management, login authentication, and security. These cannot be disabled without impairing platform use.
• Performance cookies: Collect anonymized data about how users interact with the ph11com platform to help us identify and fix technical issues and improve performance.
• Functional cookies: Remember your preferences (e.g., language, display settings) to provide a more personalized experience.
• Analytics cookies: Used to understand aggregate usage patterns on the ph11com platform. Data collected is anonymized and used for internal reporting only.

You may manage cookie preferences through your browser settings. Note that disabling certain cookies may affect the functionality of the ph11com platform. ph11com does not use third-party advertising or behavioral tracking cookies.

08 Data Retention

ph11com retains your personal data for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.

Specifically:

• Account and identity data is retained for the duration of your ph11com account and for a minimum of five (5) years following account closure, in compliance with PAGCOR and AMLC record-keeping requirements.
• Financial transaction records are retained for a minimum of five (5) years from the date of the transaction, as required by Philippine AML regulations.
• Customer support communications are retained for three (3) years from the date of the interaction.
• Technical and usage logs are retained for up to twelve (12) months, after which they are anonymized or deleted.

Upon expiry of the applicable retention period, ph11com will securely delete or anonymize your personal data in accordance with its data disposal procedures.

09 Data Security

ph11com implements a comprehensive set of 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 ph11com platform.
• Encryption of sensitive data at rest, including financial data and identity documents.
• Role-based access controls limiting employee access to personal data on a strict need-to-know basis.
• Regular security audits, penetration testing, and vulnerability assessments.
• Multi-factor authentication for administrative access to systems containing personal data.
• Incident response procedures for detecting, reporting, and managing personal data breaches in accordance with NPC notification requirements.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, ph11com will notify the NPC within seventy-two (72) hours of becoming aware of the breach and will notify affected data subjects without undue delay, as required by the DPA.

10 Your Data Privacy Rights

Under the Philippine Data Privacy Act of 2012, you have the following rights with respect to your personal data held by ph11com:

• Right to be informed: The right to know what personal data ph11com collects about you and how it is processed.
• Right of access: The right to request a copy of the personal data ph11com holds about you.
• Right to rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to erasure: The right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to ph11com's legal retention obligations.
• Right to data portability: The right to receive your personal data in a structured, commonly used, machine-readable format.
• Right to object: The right to object to processing of your personal data for direct marketing purposes or where processing is based on legitimate interests.
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission (NPC) if you believe ph11com has violated your data privacy rights.

To exercise any of these rights, please contact ph11com's Data Protection Officer at the contact details provided in Section 13. ph11com will respond to all verified requests within thirty (30) days of receipt.

11 Children's Privacy

The ph11com platform is strictly intended for individuals aged 21 years and above. ph 11com does not knowingly collect personal data from individuals under the age of 21. If ph11com becomes aware that personal data has been collected from a person under 21, that data will be deleted immediately and the associated account will be suspended pending investigation.

If you are a parent or guardian and believe that your child has registered on the ph11com platform or provided personal data without your consent, please contact ph11com's Data Protection Officer immediately using the contact details in Section 13. ph11com takes underage access seriously and will act promptly on all such reports.

12 Changes to This Privacy Policy

ph11com 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, ph11com will notify registered users via the email address or mobile number on file at least seven (7) days before the changes take effect, and will post a prominent notice on the platform.

The date of the most recent revision is indicated at the top of this Privacy Policy. Your continued use of the ph11com 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 ph11com protects your personal data.

13 Contact & Data Protection Officer

ph11com has appointed a Data Protection Officer (DPO) responsible for overseeing compliance with the Philippine Data Privacy Act and this Privacy Policy. If you have any questions, concerns, or requests relating to your personal data or this Privacy Policy, please contact our DPO using the details below.

All data privacy inquiries and rights requests should be submitted in writing to ensure proper documentation and timely response. ph11com will acknowledge receipt of your request within five (5) business days and provide a substantive response within thirty (30) days.

Email: [email protected]

General Support: [email protected]

For complaints that remain unresolved after contacting ph11com, you may lodge a complaint with the National Privacy Commission (NPC) of the Philippines through their official channels.