11j Privacy Policy Data Protection

1. Data Controller

For the purposes of this Privacy Policy, the data controller is the operator of 11j.asia and the 11j Android application (collectively referred to as "11j", "we", "us", or "our"). 11j is an internationally licensed online gaming operator. For data-related enquiries, the primary point of contact is [email protected].

Users in Pakistan ("you", "your") interact with 11j via the website and Android app and are subject to both this Privacy Policy and the 11j Terms and Conditions. Processing of personal data is undertaken in accordance with the operator's licensing obligations and applicable data protection frameworks.

2. Data We Collect

2.1 Registration Data

When you create a 11j account, we collect the information you voluntarily provide, which typically includes:

• Full legal name as it appears on your identity document
• Date of birth (for age verification purposes)
• Pakistani mobile number (03XX format) used as your account identifier
• Email address (where provided)
• Country of residence
• Preferred currency (PKR)

2.2 Identity Verification Data (KYC)

To comply with anti-money laundering and age verification requirements, 11j collects copies of government-issued identity documents. For Pakistani users, this typically means a scan or photograph of your CNIC (Computerised National Identity Card) or passport. We may also request proof of address or proof of source of funds in certain circumstances.

2.3 Financial Data

We collect transactional data including deposit amounts, withdrawal requests, payment method identifiers (JazzCash account numbers, Easypaisa account references, bank account details, or partial card numbers), and the history of all PKR transactions on your account.

2.4 Usage and Behavioural Data

We automatically collect information about how you interact with the 11j platform, including IP address, device type, operating system, browser or app version, pages visited, games played, bet history, session duration, and clickstream data. This data is collected via server logs and, where applicable, cookies and similar tracking technologies.

2.5 Communication Data

If you contact 11j support, we retain records of your communications including emails, chat transcripts, and any documents you share in connection with a support request or dispute.

3. How We Use Your Data

11j uses the personal data collected for the following purposes:

• Account management: Creating, maintaining, and securing your 11j account and enabling login authentication
• Service delivery: Processing deposits and withdrawals in PKR, settling bets and casino game outcomes, and crediting bonus funds
• Identity and age verification: Ensuring all account holders are 18 or older in compliance with our licensing obligations and responsible gaming commitments
• Fraud prevention and AML compliance: Detecting, investigating, and preventing fraudulent activity, money laundering, and other prohibited conduct
• Responsible gaming: Monitoring for signs of problem gambling behaviour and enforcing self-exclusion and deposit limit settings where applicable
• Customer support: Responding to enquiries, resolving disputes, and processing account requests
• Platform improvement: Analysing usage patterns to improve game performance, payment flows, and overall user experience on the 11j Android app and website
• Marketing communications: Sending promotional offers and platform updates where you have opted in to receive such communications
• Legal compliance: Meeting our obligations under applicable gaming, anti-money laundering, and data protection laws

4. Legal Bases for Processing

11j processes your personal data on the following legal bases:

• Contractual necessity: Processing required to provide you with the 11j services under the Terms and Conditions you accepted at registration
• Legal obligation: Processing required to comply with anti-money laundering regulations, age verification requirements, and our gaming licence conditions
• Legitimate interests: Processing for fraud prevention, security monitoring, and platform improvement, where such interests are not overridden by your rights
• Consent: Processing for optional purposes such as marketing communications, where you have provided explicit, withdrawable consent

5. KYC & Identity Data

KYC (Know Your Customer) verification is a regulatory requirement for all licensed online gaming operators. At 11j, KYC is triggered when a user submits their first withdrawal request, when cumulative deposits exceed defined thresholds, or when our compliance team has reasonable grounds to verify an account.

CNIC and passport data submitted to 11j is processed solely for identity verification and age confirmation purposes. This data is handled with the highest level of security: stored encrypted at rest, accessible only to authorised compliance staff, and never used for marketing or shared with non-essential third parties. KYC documents are retained for the period required by our licensing and anti-money laundering obligations, which is typically a minimum of five (5) years following account closure.

6. Payment Data

11j does not store complete payment instrument credentials on its own servers. When you deposit via JazzCash or Easypaisa, the transaction is processed through the respective mobile wallet provider's secure API. When you use a debit card (Visa or Mastercard), full card details are processed by a PCI-DSS compliant payment processor – 11j retains only a tokenised reference and partial card number for display purposes.

For bank transfers through HBL, UBL, Meezan Bank, or Bank Alfalah, account numbers provided for withdrawal processing are used solely for the purpose of remitting funds to you and are retained only as long as necessary for that purpose and applicable record-keeping requirements.

USDT TRC20 wallet addresses submitted for cryptocurrency withdrawals are similarly retained only for transaction processing and audit purposes.

7. Cookies & Tracking Technologies

7.1 What We Use

11j uses cookies and similar technologies (including local storage) on 11j.asia to enable core functionality, maintain login sessions, and collect analytical data about platform usage. The categories of cookies we use include:

• Strictly necessary cookies: Required for the platform to function. These include session authentication tokens and security cookies. They cannot be disabled without breaking core features.
• Analytical cookies: Used to understand how users navigate the 11j platform so we can identify areas for improvement. Data is collected in aggregate and anonymised where possible.
• Preference cookies: Store user preferences such as language settings and game display configurations to improve your experience on return visits.

7.2 Managing Cookies

You can control non-essential cookies through your browser settings. Note that disabling cookies may affect the functionality of the 11j platform, including the ability to maintain a login session across pages.

8. Data Sharing & Third Parties

11j does not sell your personal data. We share data only in the following limited circumstances:

• Payment processors: JazzCash, Easypaisa, HBL, UBL, card processors, and crypto payment gateways receive only the data necessary to complete your transaction.
• Identity verification providers: Third-party KYC verification services that assist in validating CNIC and passport documents. These providers are contractually bound to handle data only for verification purposes.
• Game software providers: JILI, PG Soft, Pragmatic Play, and other content providers receive anonymised session data to facilitate game delivery. No personally identifiable information is shared with game studios.
• Regulatory and law enforcement authorities: Where required by applicable law, by order of a competent court, or to comply with our gaming licence obligations, 11j may disclose account and transaction data to relevant authorities.
• Fraud prevention networks: In circumstances of suspected fraud, money laundering, or serious platform abuse, relevant data may be shared with industry fraud prevention consortia.

All third-party data processors engaged by 11j are required to maintain appropriate data security standards and to use data only for the specific, documented purpose for which it was shared.

9. Data Retention

11j retains personal data for as long as your account is active and for a defined period thereafter. The specific retention periods are as follows:

• Account and registration data: Retained for the lifetime of your account and for a minimum of five (5) years following permanent account closure, as required by AML regulations.
• KYC identity documents: Minimum five (5) years from account closure or from the date of last transaction, whichever is later.
• Transaction and betting records: Minimum five (5) years, in accordance with financial record-keeping requirements under our gaming licence.
• Support communications: Retained for three (3) years from the date of the communication, unless the matter relates to an ongoing dispute or regulatory inquiry.
• Analytical and usage data: Typically retained in aggregated, anonymised form for up to two (2) years for platform improvement purposes.

Upon expiry of the applicable retention period, data is securely deleted or irreversibly anonymised.

10. Security Measures

11j implements a range of technical and organisational security measures to protect your personal data, including:

• SSL/TLS encryption for all data transmitted between your device and 11j.asia
• Encryption of sensitive data at rest, including KYC documents and payment references
• Role-based access controls limiting data access to authorised personnel only
• Two-factor authentication available for all user accounts
• Continuous monitoring for unauthorised access attempts and anomalous login behaviour
• Regular security assessments and penetration testing of the platform infrastructure

Despite these measures, no online system can guarantee absolute security. In the event of a data breach that affects your rights and freedoms, 11j will notify affected users in accordance with its notification obligations under applicable law.

11. Your Rights

Subject to applicable law and any overriding obligations we have under gaming or AML regulations, you have the following rights in relation to your personal data held by 11j:

• Right of access: You may request a copy of the personal data we hold about you.
• Right to rectification: You may request that inaccurate or incomplete personal data be corrected.
• Right to erasure: You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, subject to overriding legal retention obligations.
• Right to restrict processing: You may request that we limit how we use your data in certain circumstances.
• Right to data portability: Where processing is based on consent or contract and carried out by automated means, you may request your data in a structured, commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on consent (e.g., marketing emails), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing prior to withdrawal.
• Right to object: You may object to processing carried out on the basis of legitimate interests.

To exercise any of these rights, submit a written request to [email protected]. We will respond within a reasonable timeframe, typically within thirty (30) calendar days. We may request proof of identity before processing your request.

12. Children's Privacy

11j services are strictly for adults aged 18 years and older. 11j does not knowingly collect personal data from individuals under the age of 18. If we become aware that a minor has registered an account or provided personal data, the account will be immediately closed, all data will be deleted, and any deposited funds will be returned through the original payment method after verification.

Parents and guardians in Karachi, Lahore, Islamabad, and elsewhere in Pakistan are encouraged to use parental control software to prevent minors from accessing online gambling platforms. If you have reason to believe a minor has created a 11j account, please notify us immediately at [email protected].

13. Changes to This Privacy Policy

11j reserves the right to update this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify registered users via the email address on file and/or via a prominent notice on the 11j platform prior to the changes taking effect.

The "Last updated" date at the top of this Policy reflects when the most recent changes were made. Your continued use of 11j following the posting of an updated Privacy Policy constitutes your acceptance of the revised terms. We encourage you to review this page periodically.

14. Contact Us

For any questions, requests, or complaints relating to this Privacy Policy or the handling of your personal data by 11j, please contact us through:

• Support Email: [email protected] (please mark the subject line as "Privacy Request")
• Live Chat: Available 24/7 via the chat icon on 11j.asia
• Response Time: Privacy-related requests are addressed within 30 calendar days. Complex requests may require additional time, in which case we will notify you of the expected timeline.