jll11 Privacy Policy

About This Policy

This Privacy Policy ("Policy") is issued by jll11 ("jll11," "we," "us," or "our") and applies to all personal data processed in connection with the jll11 online gaming platform, accessible at https://jll11.net (the "Platform"). It covers personal data collected from registered players, visitors, and any individual who interacts with the jll11 Platform, customer support channels, or related communications.

jll11 is committed to protecting the privacy and personal data of every Filipino player on the Platform. This Policy is designed to comply with the Philippines Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the directives of the National Privacy Commission (NPC) of the Philippines.

By using the jll11 Platform — including the jll11 Login page, any game lobby, the cashier, or any support channel — you acknowledge that you have read and understood this Privacy Policy and consent to the collection, processing, and use of your personal data as described herein. If you do not consent, please discontinue use of the Platform immediately.

Personal Data We Collect

jll11 collects the following categories of personal data from players and Platform visitors. We only collect data that is necessary, proportionate, and relevant to the purposes for which it is collected.

2.1 Identity & Contact Data

• Full legal name (as it appears on your government-issued ID)
• Date of birth (for 21+ age verification)
• Nationality and country of residence
• Residential address (barangay, city/municipality, province)
• Email address and mobile number
• Government-issued ID details (PhilSys National ID, passport, driver's licence number)

2.2 Financial Data

• GCash or PayMaya account number (last digits only after verification)
• BPI, BDO, or Metrobank account details provided for withdrawals
• Visa / Mastercard details (card number partially masked; processed via PCI-DSS compliant payment gateways)
• Transaction history: deposit amounts, withdrawal amounts, dates, and payment method references

2.3 Gaming & Usage Data

• Game history: games played, wagers placed (in Philippine Peso ₱), results, and session durations
• Login history: timestamps, IP addresses, and device identifiers associated with jll11 Login events
• Responsible gaming settings: deposit limits, self-exclusion status, session reminders
• Bonus and promotion participation records

2.4 Technical & Device Data

• IP address and approximate geolocation (city/region level)
• Browser type and version, operating system
• Device type (mobile, tablet, desktop) and device identifiers
• Cookie identifiers and session tokens (see Section 7 for full cookie details)
• Referring URL and pages visited on the jll11 Platform

2.5 Communications Data

• Records of customer support interactions (live chat transcripts, email correspondence)
• Feedback, survey responses, and complaints submitted to jll11
• Marketing communication preferences (opt-in / opt-out records)

How We Collect Data

jll11 collects personal data through the following channels:

• Direct Submission: Data you provide during account registration, identity verification (KYC), deposit or withdrawal requests, or when contacting our support team.
• Automated Collection: Data collected automatically when you access the Platform, including through cookies, web beacons, server logs, and similar tracking technologies (see Section 7).
• Third-Party Verification: Identity and address verification data obtained from third-party KYC and identity verification service providers engaged by jll11.
• Payment Processors: Transaction confirmation data received from GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard payment processing partners.
• Regulatory Sources: Data received from government agencies or regulatory authorities in the context of legal obligations, such as AML reporting requirements.

Legal Basis for Processing

jll11 processes your personal data only where a valid legal basis exists under RA 10173. The primary legal bases we rely on are:

How We Use Your Data

jll11 uses the personal data we collect for the following specific purposes:

• Account Management: Creating, maintaining, and managing your jll11 account, including processing jll11 Login events and account security alerts.
• Identity Verification: Verifying your age (21+) and identity as required under PAGCOR regulations and Philippine KYC obligations before allowing real-money gaming.
• Payment Processing: Processing deposits and withdrawals in Philippine Peso (₱) via your chosen payment method (GCash, PayMaya, BPI, BDO, Metrobank, Visa, Mastercard).
• Game Operation: Enabling access to jll11 games including slots, live casino, bingo, and fishing games; recording game results and maintaining your transaction history.
• Regulatory Compliance: Meeting obligations under Philippine law, including AML reporting to the Anti-Money Laundering Council (AMLC) and responding to lawful requests from government authorities.
• Responsible Gaming: Operating deposit limits, self-exclusion tools, and session reminders to promote safe gaming practices among all jll11 players.
• Fraud Prevention: Detecting, investigating, and preventing fraudulent transactions, multiple account abuse, and other prohibited activities on the Platform.
• Customer Support: Responding to your support requests, resolving disputes, and maintaining records of communications for quality assurance.
• Marketing: Sending promotional offers, bonus notifications, and updates about new jll11 games or features — but only where you have opted in and only to your registered email or mobile number.
• Platform Improvement: Analysing aggregated usage data to improve the jll11 Platform's performance, content, and user experience.

Sharing Your Data

jll11 does not sell, rent, or trade your personal data to third parties. We share your personal data only in the following limited circumstances:

• Payment Service Providers: We share financial data with GCash, PayMaya, BPI, BDO, Metrobank, Visa, and Mastercard processing partners solely to execute your deposit and withdrawal requests. These providers are bound by their own privacy policies and PCI-DSS security standards.
• KYC / Identity Verification Providers: We share identity document data with accredited KYC verification service providers engaged to perform age and identity checks on jll11 accounts.
• Game Content Providers: We share a player session token and account reference with the game studio or content provider whose game you are actively playing, solely to enable game session management. No personally identifiable information is shared beyond what is necessary for this purpose.
• Regulatory and Law Enforcement Authorities: We are legally required to disclose data to the AMLC, NPC, PAGCOR, or other competent Philippine government authorities upon receipt of a valid legal order or where disclosure is required by law (e.g., AML suspicious transaction reporting).
• Professional Advisors: We may share data with our lawyers, auditors, and accountants where necessary in connection with legal proceedings or regulatory audits, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of substantially all of jll11's assets, player data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third parties with whom jll11 shares personal data are required to process that data only for the specified purpose and in accordance with applicable Philippine data protection law.

Cookies & Tracking Technologies

jll11 uses cookies and similar tracking technologies on the Platform to ensure proper functionality, enhance your experience, and gather analytical data. The types of cookies we use are:

You may manage or disable non-essential cookies at any time through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to use the jll11 Platform, including the jll11 Login function.

Data Retention

jll11 retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law. Our standard retention periods are as follows:

• Account and KYC Data: Retained for a minimum of five (5) years from account closure, as required under the Anti-Money Laundering Act (RA 9160, as amended) and PAGCOR regulations.
• Transaction Records: Deposit, withdrawal, and gaming transaction records are retained for a minimum of five (5) years from the date of the transaction.
• Customer Support Records: Communication records are retained for three (3) years from the date of the last interaction.
• Marketing Preferences: Opt-in and opt-out records are retained for the duration of your account plus three (3) years.
• Technical / Log Data: Server log files and device data are retained for up to twelve (12) months for security and fraud prevention purposes.

When data is no longer required and no legal retention obligation applies, jll11 will securely delete or anonymise it so that it can no longer be linked to any individual player.

Data Security

jll11 implements appropriate technical and organisational security measures to protect your personal data from unauthorised access, disclosure, alteration, or destruction. Our security framework includes:

• Encryption: All data transmitted between your browser or app and the jll11 Platform is encrypted using TLS (Transport Layer Security) protocols. Sensitive data at rest — including financial account details — is encrypted using AES-256 encryption.
• Access Controls: Personal data is accessible only to jll11 personnel and authorised third parties who require it for a specific, documented purpose. Role-based access controls are enforced across all internal systems.
• PCI-DSS Compliance: Payment card data is handled exclusively through PCI-DSS Level 1 compliant payment processing partners. jll11 does not store full card numbers on its servers.
• Account Security: Players are encouraged to use a strong, unique password for their jll11 Login and to enable any available two-factor authentication (2FA) features. jll11 will never ask for your password via email or live chat.
• Incident Response: jll11 maintains a documented data breach response plan. In the event of a personal data breach that poses a real risk of harm to affected players, jll11 will notify the National Privacy Commission (NPC) and affected individuals within the timeframes prescribed by RA 10173.

Your Rights

Under the Philippines Data Privacy Act of 2012 (RA 10173), you have the following rights in relation to your personal data held by jll11. You may exercise any of these rights by submitting a written request to our Data Protection Officer at [email protected]:

• Right to Be Informed: The right to know what personal data jll11 collects about you, why we collect it, and how we use it — as detailed in this Privacy Policy.
• Right to Access: The right to request a copy of the personal data jll11 holds about you, along with information about how it is processed.
• Right to Rectification: The right to request correction of any inaccurate, incomplete, or outdated personal data in your jll11 account.
• Right to Erasure / Blocking: The right to request deletion or blocking of your personal data where it is no longer necessary for the purpose for which it was collected, subject to jll11's legal retention obligations under AML and gaming regulations.
• Right to Object: The right to object to the processing of your personal data for direct marketing purposes. You may also opt out of marketing emails at any time by using the unsubscribe link in any jll11 marketing email.
• Right to Data Portability: The right to request that certain personal data be provided to you in a structured, commonly used, machine-readable format.
• Right to Damages: The right to seek indemnity for any damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorised use of your personal data.
• Right to File a Complaint: If you believe jll11 has not handled your personal data in accordance with RA 10173, you have the right to file a complaint with the National Privacy Commission (NPC) of the Philippines.

jll11 will respond to all data rights requests within thirty (30) calendar days of receipt. In complex cases, this period may be extended by a further thirty (30) days, and you will be notified of the extension and the reasons for it.

Children's Privacy

The jll11 Platform is strictly intended for individuals aged 21 years and above. jll11 does not knowingly collect personal data from individuals under 21. The minimum age requirement is enforced through mandatory KYC identity verification during account registration.

If jll11 discovers that personal data has been collected from an individual under the age of 21 without parental or guardian consent, we will immediately suspend the associated account, delete the relevant personal data from our systems, and return any funds to the payment source from which they originated.

If you are a parent or guardian and believe your child has registered a jll11 account, please contact us immediately at [email protected] so that we can take prompt action.

Cross-Border Data Transfers

jll11 is a Philippines-facing platform and processes the majority of personal data within the Philippines. However, certain service providers engaged by jll11 — such as cloud infrastructure providers, KYC verification platforms, and game content studios — may process data in jurisdictions outside the Philippines.

Where personal data is transferred outside the Philippines, jll11 ensures that appropriate safeguards are in place to protect the data in accordance with RA 10173, including:

• Contractual clauses requiring the receiving party to apply data protection standards equivalent to those required under Philippine law.
• Due diligence assessments of the data protection framework in the recipient country.
• Engaging only reputable, internationally recognised service providers with established privacy and security programmes.

Changes to This Policy

jll11 reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or Platform features. When material changes are made, jll11 will update the "Last Updated" date at the top of this page and notify registered players via email or an in-Platform notification.

Your continued use of the jll11 Platform following any update to this Policy constitutes your acceptance of the revised Policy. We encourage you to review this Privacy Policy periodically to stay informed about how jll11 protects your personal data.

Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or jll11's processing of your personal data, please contact our Data Protection Officer (DPO):

For formal complaints regarding jll11's data processing practices, you may also contact the National Privacy Commission (NPC) of the Philippines, which is the supervisory authority responsible for enforcing RA 10173.