11kbs Casino Privacy Policy

1. Introduction

1.1 11kbs Casino ("11kbs," "we," "us," or "our") is committed to protecting the privacy and personal data of all players and visitors who use the 11kbs Casino platform (the "Platform"), accessible at https://11kbs.app.

1.2 This Privacy Policy describes how 11kbs Casino collects, uses, stores, discloses, and protects personal information in accordance with the Philippine Data Privacy Act of 2012 (Republic Act No. 10173), its Implementing Rules and Regulations, and the issuances of the National Privacy Commission (NPC).

1.3 This policy applies to all personal data collected through the Platform, including data collected during account registration, gameplay, financial transactions, customer support interactions, and marketing communications.

1.4 Please read this policy carefully. If you do not agree with any part of this policy, you must not use the Platform. Questions about this policy may be directed to our Data Protection Officer (DPO) using the contact details in Section 15.

2. Data Controller

2.1 For the purposes of the Data Privacy Act of 2012, 11kbs Casino is the Personal Information Controller (PIC) in respect of the personal data collected through the Platform. As PIC, 11kbs Casino determines the purposes and means of processing your personal data.

2.2 Where 11kbs Casino engages third-party service providers to process personal data on its behalf (for example, payment processors or game providers), those parties act as Personal Information Processors (PIPs) and are contractually bound to process data only on 11kbs Casino's instructions and in accordance with applicable law.

3. Personal Data We Collect

3.1 11kbs Casino collects the following categories of personal data:

3.1 Identity & Contact Data

• Full legal name, date of birth, nationality;
• Residential address (including city — e.g., Manila, Cebu, Davao, Makati, Quezon City);
• Email address and mobile number;
• Government-issued identification documents (e.g., PhilSys ID, passport, driver's licence, SSS/GSIS ID) submitted for KYC verification.

3.2 Account & Financial Data

• Username and encrypted password;
• Account balance, transaction history, deposit and withdrawal records;
• Payment method details (GCash mobile number, PayMaya/Maya account reference, bank account name and number for bank transfer, debit card details — card numbers are not stored in full);
• Bonus and promotion history.

3.3 Gaming & Behavioural Data

• Game session logs, wager amounts, win/loss records;
• Responsible gaming settings (deposit limits, loss limits, self-exclusion status);
• Platform usage patterns, feature interactions, and session duration.

3.4 Technical Data

• IP address, device type, operating system, browser type and version;
• Cookie identifiers and session tokens;
• Geolocation data (country/region level, derived from IP address).

3.5 Communications Data

• Records of customer support interactions (live chat transcripts, email correspondence);
• Survey responses and feedback submissions.

4. How We Collect Your Data

4.1 Directly from you — when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or respond to a survey.

4.2 Automatically — through cookies, web beacons, and similar tracking technologies when you access and interact with the Platform. See Section 7 for details on our cookie practices.

4.3 From third parties — including identity verification providers, payment processors (GCash, PayMaya/Maya, banks), fraud prevention services, and regulatory bodies such as PAGCOR, where disclosure is required or permitted by law.

5. Purpose & Legal Basis for Processing

5.1 11kbs Casino processes your personal data for the following purposes and on the following legal bases:

Purpose	Legal Basis (DPA 2012)
Account registration and management	Performance of contract; consent
Identity verification (KYC/AML)	Legal obligation; legitimate interest
Processing deposits and withdrawals	Performance of contract
Providing gaming services and customer support	Performance of contract
Fraud prevention and security monitoring	Legitimate interest; legal obligation
Responsible gaming compliance	Legal obligation; legitimate interest
Regulatory reporting to PAGCOR and other authorities	Legal obligation
Sending promotional communications (with opt-out)	Consent
Platform analytics and improvement	Legitimate interest

5.2 Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Sharing Your Personal Data

6.1 11kbs Casino does not sell, rent, or trade your personal data. We may share your data with the following categories of recipients only to the extent necessary for the stated purpose:

• Payment processors — GCash, PayMaya/Maya, BPI, BDO, Metrobank, UnionBank, Landbank, PNB, Security Bank, and debit card networks, for the purpose of processing financial transactions;
• Identity verification providers — third-party KYC and AML screening services engaged to verify your identity and comply with anti-money laundering regulations;
• Game content providers — licensed game studios and live dealer operators whose games are hosted on the Platform, who may receive session data necessary to deliver the game;
• IT and infrastructure providers — cloud hosting, cybersecurity, and platform maintenance providers operating under strict data processing agreements;
• Regulatory and law enforcement authorities — PAGCOR, the Anti-Money Laundering Council (AMLC), the National Privacy Commission, and other competent Philippine authorities, where disclosure is required by law or court order;
• Professional advisers — lawyers, auditors, and accountants, subject to professional confidentiality obligations.

6.2 All third-party processors engaged by 11kbs Casino are required to implement appropriate technical and organisational security measures and to process personal data only in accordance with 11kbs Casino's instructions.

7. Cookies & Tracking Technologies

7.1 11kbs Casino uses cookies and similar technologies (web beacons, pixel tags, local storage) to operate the Platform, remember your preferences, maintain your session, and analyse usage patterns.

7.2 The following categories of cookies are used:

• Strictly necessary cookies — essential for the Platform to function. These cannot be disabled without impairing core functionality (e.g., session authentication, security tokens);
• Functional cookies — remember your preferences such as language settings and responsible gaming limits;
• Analytics cookies — collect aggregated, anonymised data about how players use the Platform to help us improve performance and user experience;
• Marketing cookies — used to deliver relevant promotional content. These are only set with your consent.

7.3 You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies may prevent you from accessing certain features of the Platform.

8. Data Retention

8.1 11kbs Casino retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable Philippine law, whichever period is longer.

8.2 As a general guide:

• Account and transaction data — retained for a minimum of five (5) years from the date of the last transaction, in accordance with anti-money laundering regulations;
• KYC documents — retained for a minimum of five (5) years from account closure;
• Customer support records — retained for three (3) years from the date of the interaction;
• Marketing consent records — retained until consent is withdrawn, plus one (1) year thereafter for compliance purposes;
• Technical and log data — retained for up to twelve (12) months.

8.3 Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 11kbs Casino's data disposal procedures.

9. Data Security

9.1 11kbs Casino implements appropriate technical and organisational measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• TLS/SSL encryption for all data in transit between your device and 11kbs servers;
• AES-256 encryption for sensitive data stored at rest;
• Role-based access controls limiting staff access to personal data on a need-to-know basis;
• Regular security audits, penetration testing, and vulnerability assessments;
• Two-factor authentication (2FA) available for all player accounts;
• Incident response procedures for detecting, reporting, and managing personal data breaches.

9.2 In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 11kbs Casino will notify the National Privacy Commission and affected data subjects in accordance with the timelines prescribed by the DPA 2012 and NPC regulations.

9.3 While 11kbs Casino takes all reasonable steps to protect your data, no internet transmission is completely secure. You are responsible for keeping your account credentials confidential.

10. Your Rights as a Data Subject

10.1 Under the Philippine Data Privacy Act of 2012, you have the following rights in relation to your personal data held by 11kbs Casino:

• Right to be informed — to know how your personal data is being collected and processed;
• Right of access — to request a copy of the personal data we hold about you;
• Right to rectification — to request correction of inaccurate or incomplete personal data;
• Right to erasure — to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to legal retention obligations;
• Right to object — to object to processing based on legitimate interest, including direct marketing;
• Right to data portability — to receive your personal data in a structured, commonly used format;
• Right to lodge a complaint — to file a complaint with the National Privacy Commission (NPC) if you believe your data privacy rights have been violated.

10.2 To exercise any of the above rights, please contact our Data Protection Officer using the details in Section 15. We will respond to all verified requests within fifteen (15) business days, as required by NPC regulations.

10.3 We may need to verify your identity before processing a data subject request. This is to ensure that personal data is not disclosed to unauthorised parties.

11. Children's Privacy

11.1 The 11kbs Casino platform is strictly for persons aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21.

11.2 If we become aware that personal data has been collected from a person under 21 without appropriate consent, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on the Platform, please contact our support team immediately.

12. Cross-Border Data Transfers

12.1 Some of 11kbs Casino's service providers and game content partners may be located outside the Philippines. Where personal data is transferred to a country that does not provide an equivalent level of data protection, 11kbs Casino will implement appropriate safeguards, such as standard contractual clauses approved by the NPC, to ensure your data remains protected.

12.2 By using the Platform, you acknowledge that your personal data may be transferred to and processed in countries outside the Philippines, subject to the safeguards described above.

13. Third-Party Links

13.1 The Platform may contain links to third-party websites or services. 11kbs Casino is not responsible for the privacy practices of those third parties. We encourage you to review the privacy policies of any third-party sites you visit.

14. Amendments to This Policy

14.1 11kbs Casino reserves the right to update this Privacy Policy at any time. Where changes are material, we will notify you via email or an in-platform notification prior to the changes taking effect.

14.2 The "Last Updated" date at the top of this policy reflects the most recent revision. Continued use of the Platform after the effective date of any amendment constitutes acceptance of the revised policy.

15. Contact & Data Protection Officer

15.1 For any questions, concerns, or requests relating to this Privacy Policy or the processing of your personal data, please contact our Data Protection Officer:

• Email: [email protected]
• General Support: [email protected]
• Response Time: Within 15 business days for data subject requests; within 24 hours for general inquiries

15.2 If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission (NPC) of the Philippines.