Privacy Policy
11kbs Platform

1 Introduction

11kbs ("we," "us," "our," or "the Platform") is committed to protecting the privacy and personal data of all individuals who access or use the 11kbs website, mobile application, and associated gaming services (collectively, the "Services"). This Privacy Policy ("Policy") describes how 11kbs collects, uses, stores, shares, and protects personal data in connection with the operation of the platform.

This Policy applies to all registered players, prospective players, and visitors to the 11kbs platform, regardless of the device or method used to access the Services. By registering an account on 11kbs or by continuing to use the platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy should be read together with the 11kbs Terms & Conditions and Responsible Gaming Policy, which together govern your use of the platform.

2 Data Controller

For the purposes of the Philippine Data Privacy Act of 2012 and applicable data protection legislation, 11kbs is the personal information controller responsible for the personal data collected through the platform. This means that 11kbs determines the purposes and means by which your personal data is processed.

11kbs has appointed a Data Protection Officer (DPO) who is responsible for overseeing compliance with this Policy and applicable data protection laws. If you have any questions or concerns about how your personal data is handled, or if you wish to exercise any of your data subject rights, you may contact our DPO using the contact details provided in Section 15 of this Policy.

3 Data We Collect

11kbs collects the following categories of personal data in connection with the operation of the platform and the provision of gaming services to Filipino players:

11kbs does not intentionally collect sensitive personal information (as defined under the Data Privacy Act) beyond what is strictly necessary for identity verification and regulatory compliance purposes. Where sensitive personal information is collected (such as government ID numbers), it is handled with the highest level of care and access controls.

4 How We Collect Your Data

11kbs collects personal data through the following means:

• Direct interactions: Data you provide when registering an account, completing identity verification, making deposits or withdrawals, contacting support, or participating in promotions;
• Automated technologies: Data collected automatically when you access the platform, including cookies, web beacons, server logs, and similar tracking technologies that record your device information, IP address, and browsing behavior on the 11kbs platform;
• Third-party sources: Data received from payment processors (such as GCash, PayMaya, BPI, BDO, and Metrobank) in connection with deposit and withdrawal transactions, and from identity verification service providers used to fulfill our KYC obligations;
• Publicly available sources: In limited circumstances, 11kbs may verify information you have provided against publicly available records for fraud prevention and compliance purposes.

5 How We Use Your Data

11kbs uses the personal data we collect for the following purposes:

• Account management: To register and maintain your 11kbs player account, verify your identity and age, and manage your account settings and preferences;
• Service delivery: To provide access to games, process deposits and withdrawals, credit bonuses, and deliver all other features of the 11kbs platform;
• Legal and regulatory compliance: To fulfill our obligations under the Philippine Data Privacy Act, anti-money laundering regulations, PAGCOR regulatory requirements, and other applicable laws, including conducting Know Your Customer (KYC) checks and maintaining required records;
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, unauthorized account access, money laundering, and other illegal or prohibited activities on the platform;
• Responsible gaming: To monitor gaming activity for signs of problem gambling, enforce self-exclusion and deposit limit requests, and provide responsible gaming interventions where appropriate;
• Customer support: To respond to your inquiries, resolve disputes, and maintain records of communications for quality assurance and compliance purposes;
• Marketing communications: Where you have given your consent, to send you promotional offers, bonus notifications, and platform updates. You may withdraw this consent at any time;
• Platform improvement: To analyze usage patterns, conduct research, and improve the features, performance, and user experience of the 11kbs platform.

6 Legal Basis for Processing

11kbs processes your personal data on the following legal bases under the Philippine Data Privacy Act of 2012:

• Consent: Where you have given clear, informed, and freely given consent to the processing of your personal data for a specific purpose, such as receiving marketing communications or the use of non-essential cookies;
• Contractual necessity: Where processing is necessary to perform the contract between you and 11kbs — that is, to provide the gaming services you have registered to use, including account management, payment processing, and game delivery;
• Legal obligation: Where processing is necessary for 11kbs to comply with a legal obligation, including KYC requirements, anti-money laundering obligations, tax reporting, and regulatory record-keeping requirements;
• Legitimate interests: Where processing is necessary for the legitimate interests of 11kbs or a third party, provided those interests are not overridden by your rights and interests. This includes fraud prevention, platform security, and improving the quality of our services.

7 Sharing Your Data

11kbs does not sell, rent, or trade your personal data to third parties. We may share your personal data with the following categories of recipients only to the extent necessary for the purposes described in this Policy:

• Payment processors: GCash, PayMaya, BPI, BDO, Metrobank, and other payment service providers used to process your deposits and withdrawals. These providers process your financial data under their own privacy policies and are bound by applicable financial regulations;
• Identity verification providers: Third-party KYC and identity verification service providers engaged by 11kbs to verify your identity and age in compliance with regulatory requirements;
• Technology and hosting providers: Cloud hosting, data storage, and platform infrastructure providers who process data on behalf of 11kbs under strict data processing agreements;
• Game software providers: Licensed game developers and content providers whose games are available on the 11kbs platform may receive limited technical data necessary for game delivery and integrity monitoring;
• Regulatory and law enforcement authorities: Where required by law, court order, or regulatory directive, 11kbs may disclose personal data to the National Privacy Commission, PAGCOR, the Anti-Money Laundering Council (AMLC), or other competent Philippine authorities;
• Professional advisers: Legal counsel, auditors, and compliance consultants engaged by 11kbs, subject to professional confidentiality obligations.

All third parties with whom 11kbs shares personal data are required to handle that data in accordance with applicable data protection laws and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

8 International Data Transfers

In some cases, the personal data 11kbs collects may be transferred to, stored in, or processed in countries outside the Republic of the Philippines. This may occur where our technology providers, hosting infrastructure, or game software partners operate servers or facilities in other jurisdictions.

Where such transfers occur, 11kbs takes appropriate steps to ensure that your personal data receives a level of protection consistent with the requirements of the Philippine Data Privacy Act of 2012. These steps may include entering into data transfer agreements with the relevant recipients that incorporate standard contractual clauses approved by the National Privacy Commission, or relying on other lawful transfer mechanisms.

By using the 11kbs platform, you acknowledge and consent to the transfer of your personal data outside the Philippines where necessary for the purposes described in this Policy, subject to the safeguards described above.

9 Data Retention

11kbs retains personal data only for as long as is necessary to fulfill the purposes for which it was collected, or as required by applicable law. The following general retention periods apply:

• Account data: Retained for the duration of your active account and for a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements;
• Transaction records: Retained for a minimum of five (5) years from the date of the transaction, as required by Philippine financial regulations;
• KYC and identity verification documents: Retained for a minimum of five (5) years following account closure or the completion of the relevant transaction;
• Customer support communications: Retained for a minimum of two (2) years from the date of the communication, or longer where the communication relates to an unresolved dispute or legal matter;
• Marketing consent records: Retained for the duration of your consent and for a reasonable period thereafter as evidence of consent.

When personal data is no longer required for any lawful purpose, 11kbs will securely delete or anonymize it in accordance with our data disposal procedures.

10 Cookies & Tracking Technologies

11kbs uses cookies and similar tracking technologies on the platform. A cookie is a small text file placed on your device when you visit a website. The following types of cookies are used on 11kbs:

• Strictly necessary cookies: These cookies are essential for the platform to function correctly. They enable core features such as user authentication, session management, and security. These cookies cannot be disabled without affecting your ability to use the platform;
• Functional cookies: These cookies remember your preferences and settings (such as language and display preferences) to provide a more personalized experience on 11kbs;
• Analytics cookies: These cookies collect anonymized information about how players use the platform, such as which pages are visited most frequently and how long sessions last. This data helps 11kbs improve the platform experience;
• Marketing cookies: Where you have given consent, these cookies track your activity on the platform to enable 11kbs to deliver relevant promotional content. You may withdraw consent for marketing cookies at any time.

You can manage or disable cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 11kbs platform. For detailed instructions on managing cookies in your browser, refer to your browser's help documentation.

11 Your Rights

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

• Right to be informed: The right to be informed about how your personal data is collected, used, and processed, as set out in this Policy;
• Right of access: The right to request a copy of the personal data 11kbs holds about you and information about how it is being processed;
• Right to rectification: The right to request correction of any inaccurate or incomplete personal data held by 11kbs;
• 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 11kbs's legal obligations to retain certain records;
• Right to object: The right to object to the processing of your personal data for direct marketing purposes or where processing is based on legitimate interests;
• Right to data portability: The right to receive a copy of your personal data in a structured, commonly used, and machine-readable format;
• Right to lodge a complaint: The right to lodge a complaint with the National Privacy Commission of the Philippines if you believe that 11kbs has processed your personal data in violation of the Data Privacy Act.

To exercise any of these rights, please contact the 11kbs Data Protection Officer using the contact details in Section 15. We will respond to all verified requests within thirty (30) days. In some cases, we may need to verify your identity before processing your request.

12 Data Security

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

• Encryption of personal data in transit using Transport Layer Security (TLS) protocols;
• Encryption of sensitive data at rest using industry-standard encryption algorithms;
• Role-based access controls that restrict access to personal data to authorized personnel only, on a need-to-know basis;
• Regular security assessments, vulnerability testing, and penetration testing of the platform infrastructure;
• Staff training on data protection obligations and security best practices;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 11kbs will notify the National Privacy Commission and, where required, affected players in accordance with the notification requirements of the Data Privacy Act and its Implementing Rules and Regulations.

While 11kbs takes all reasonable steps to protect your personal data, no method of electronic transmission or storage is completely secure. You are also responsible for maintaining the security of your account credentials and for notifying 11kbs promptly if you suspect any unauthorized access to your account.

13 Children's Privacy

The 11kbs platform is strictly intended for adults aged 21 years and above, in accordance with Philippine regulations governing online gambling. 11kbs does not knowingly collect personal data from individuals under the age of 21.

If 11kbs becomes aware that personal data has been collected from a person under the age of 21, we will take immediate steps to delete that data and close the associated account. Any funds deposited by an underage player will be handled in accordance with applicable law and our Terms & Conditions.

If you are a parent or guardian and believe that your child has registered on the 11kbs platform, please contact our support team immediately so that we can take appropriate action.

14 Changes to This Policy

11kbs reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. The date of the most recent revision will always be indicated at the top of this page.

Where changes to this Policy are material, 11kbs will provide reasonable advance notice to registered players via email or a prominent notice on the platform. Your continued use of the 11kbs platform following the effective date of any amendment constitutes your acknowledgment of the revised Policy.

We encourage you to review this Policy periodically to stay informed about how 11kbs protects your personal data. If you have any questions about changes to this Policy, please contact our Data Protection Officer.

15 Contact & DPO

If you have any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data by 11kbs, please contact our Data Protection Officer:

We aim to respond to all data subject requests and privacy-related inquiries within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, in which case we will notify you of the extension and the reason for it.

If you are not satisfied with our response to your privacy concern, you have the right to lodge a complaint with the National Privacy Commission of the Philippines. Information about how to file a complaint with the NPC is available on the NPC's official website.