Privacy Policy

1. Introduction and Scope

This Privacy Policy ("Policy") applies to all personal information collected by 711jll ("we," "us," "our," "the Company") through our website located at 711jll.cam, mobile applications, and any other digital platforms or services we operate (collectively, the "Platform"). By accessing or using the 711jll Platform, creating an account, or providing us with your personal information, you acknowledge that you have read, understood, and consent to the collection, use, and disclosure of your information as described in this Policy.

711jll is the data controller responsible for the processing of your personal information. We process your data in accordance with the Data Privacy Act of 2012 (RA 10173), its implementing rules and regulations, and guidelines issued by the National Privacy Commission of the Philippines. This Policy should be read in conjunction with our Terms & Conditions and other legal notices published on our Platform.

2. Information We Collect

2.1 Personal Information You Provide

When you register for a 711jll account, make deposits, request withdrawals, or contact customer support, we collect the following categories of personal information:

• Identity Information: Full legal name, date of birth, nationality, gender, government-issued identification numbers (e.g., passport number, driver's license number, UMID number, Philippine National ID)
• Contact Information: Residential address, email address, Philippine mobile phone number, alternative contact details
• Financial Information: Bank account details, GCash or Maya account numbers, payment card information, transaction history, deposit and withdrawal records, cryptocurrency wallet addresses
• Account Credentials: Username, password (stored in encrypted form), security questions and answers, two-factor authentication settings
• Verification Documents: Copies of government-issued IDs, proof of address (utility bills, bank statements), selfie photographs for identity verification, source of funds documentation
• Communication Records: Customer support chat logs, email correspondence, phone call recordings (with your consent), feedback and survey responses

2.2 Information Automatically Collected

When you use the 711jll Platform, we automatically collect certain technical and usage information through cookies, web beacons, and similar tracking technologies:

• Device Information: Device type, operating system, browser type and version, screen resolution, device identifiers (IMEI, MAC address, advertising ID)
• Usage Data: Pages visited, features accessed, games played, betting history, session duration, clicks and interactions, referral sources
• Location Data: IP address, geographic location (country, region, city), time zone, language preferences, geolocation data (if you grant permission)
• Cookies and Tracking: Session cookies, persistent cookies, analytics cookies, advertising cookies, local storage data

2.3 Information from Third Parties

We may receive personal information about you from third-party sources, including payment processors (GCash, Maya, banks), identity verification service providers, fraud prevention agencies, credit reference agencies (where permitted by law), marketing partners, and social media platforms (if you choose to link your social media accounts).

3. How We Use Your Information

711jll processes your personal information for the following purposes, which are necessary for the performance of our contract with you, compliance with legal obligations, protection of our legitimate interests, and with your consent where required:

3.1 Account Management and Service Provision

• Create, maintain, and manage your 711jll account
• Verify your identity and age to comply with legal requirements (21+ age restriction)
• Process deposits, withdrawals, and other financial transactions
• Provide access to games, betting markets, and platform features
• Maintain records of your gaming activity, bets, wins, and losses
• Communicate with you about your account, transactions, and services

3.2 Legal Compliance and Security

• Comply with Know Your Customer (KYC) and Anti-Money Laundering (AML) regulations
• Prevent, detect, and investigate fraud, money laundering, and other illegal activities
• Comply with licensing requirements and regulatory reporting obligations
• Respond to legal requests from courts, law enforcement, and regulatory authorities
• Enforce our Terms & Conditions and other legal agreements
• Protect the security and integrity of our Platform and users

3.3 Responsible Gaming and Player Protection

• Monitor for signs of problem gambling behavior
• Implement deposit limits, loss limits, and self-exclusion requests
• Provide access to responsible gaming tools and resources
• Comply with responsible gaming regulations and industry standards

3.4 Marketing and Communications

• Send promotional offers, bonuses, and special deals (with your consent)
• Provide personalized recommendations based on your gaming preferences
• Send newsletters, product updates, and platform announcements
• Conduct customer satisfaction surveys and market research
• Display targeted advertisements on our Platform and third-party websites

3.5 Platform Improvement and Analytics

• Analyze usage patterns to improve user experience and platform performance
• Test new features, games, and services
• Conduct statistical analysis and generate reports for business intelligence
• Optimize website speed, functionality, and mobile responsiveness

4. Data Sharing and Disclosure

711jll does not sell your personal information to third parties. However, we may share your information with the following categories of recipients under strict confidentiality and data protection obligations:

4.1 Service Providers and Business Partners

• Payment Processors: GCash, Maya, banks, cryptocurrency exchanges, and other payment service providers to process deposits and withdrawals
• Identity Verification Providers: Third-party KYC and AML compliance services to verify your identity and prevent fraud
• Game Providers: Software developers and game studios that power our slot machines, live dealers, and other gaming content
• Cloud Service Providers: Hosting companies, data storage providers, and content delivery networks
• Marketing Partners: Email service providers, SMS gateways, advertising platforms (Google, Facebook), and affiliate marketers
• Analytics Providers: Google Analytics, Mixpanel, and similar tools to analyze platform usage

4.2 Legal and Regulatory Authorities

We may disclose your personal information to law enforcement agencies, courts, regulatory bodies (including PAGCOR and the National Privacy Commission), tax authorities, and other governmental entities when required by law, court order, or regulatory request, or when necessary to protect our legal rights and interests.

4.3 Corporate Transactions

In the event of a merger, acquisition, reorganization, asset sale, or bankruptcy, your personal information may be transferred to the successor entity, subject to continued compliance with this Privacy Policy and applicable data protection laws.

4.4 Third-Party Links

Our Platform may contain links to third-party websites, services, or applications. We are not responsible for the privacy practices of these third parties. We encourage you to review their privacy policies before providing any personal information.

5. Data Security Measures

711jll implements industry-standard technical, physical, and organizational security measures to protect your personal information from unauthorized access, disclosure, alteration, and destruction. Our security measures include:

• Encryption: All data transmitted between your device and our servers is encrypted using 256-bit SSL/TLS encryption, the same technology used by Philippine banks
• Secure Storage: Personal information is stored on secure servers with restricted access, protected by firewalls and intrusion detection systems
• Password Protection: Passwords are hashed using industry-standard cryptographic algorithms and are never stored in plain text
• Access Controls: Personal information is accessible only to authorized employees and service providers on a need-to-know basis
• Regular Audits: We conduct periodic security audits and vulnerability assessments to identify and address potential risks
• Incident Response: We maintain an incident response plan to promptly address and mitigate data breaches

Despite our best efforts, no security system is impenetrable. You are responsible for maintaining the confidentiality of your account credentials and notifying us immediately if you suspect unauthorized access to your account.

6. Data Retention and Deletion

711jll retains your personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, comply with legal obligations, resolve disputes, and enforce our agreements. Specific retention periods include:

• Account Information: Retained for the duration of your account's active status and for seven (7) years after account closure, as required by anti-money laundering regulations
• Transaction Records: Retained for ten (10) years to comply with financial record-keeping requirements
• Communication Records: Retained for three (3) years for customer service quality assurance and dispute resolution
• Marketing Data: Retained until you withdraw consent or for two (2) years of inactivity, whichever comes first
• Technical Logs: Retained for one (1) year for security monitoring and troubleshooting purposes

After the applicable retention period expires, we will securely delete or anonymize your personal information in accordance with our data deletion procedures. You may request deletion of your personal information at any time, subject to our legal obligations and legitimate business needs.

7. Your Privacy Rights Under Philippine Law

Under the Data Privacy Act of 2012, you have the following rights regarding your personal information:

• Right to Be Informed: You have the right to know how your personal information is being processed
• Right to Access: You may request a copy of the personal information we hold about you
• Right to Rectification: You may request correction of inaccurate or incomplete personal information
• Right to Erasure or Blocking: You may request deletion or blocking of your personal information, subject to legal obligations
• Right to Object: You may object to processing of your personal information for direct marketing purposes
• Right to Data Portability: You may request your personal information in a commonly used, machine-readable format
• Right to Lodge a Complaint: You may file a complaint with the National Privacy Commission if you believe your privacy rights have been violated

To exercise any of these rights, please contact our Data Protection Officer using the contact details provided in Section 10. We will respond to your request within fifteen (15) business days, as required by Philippine law.

8. Cookies and Tracking Technologies

711jll uses cookies and similar tracking technologies to enhance your experience, analyze platform usage, and deliver personalized content. A cookie is a small text file stored on your device that helps us recognize you when you return to our Platform.

8.1 Types of Cookies We Use

• Essential Cookies: Required for platform functionality, account authentication, and security. These cannot be disabled without affecting platform operation
• Performance Cookies: Collect information about how you use our Platform to help us improve performance and user experience
• Functional Cookies: Remember your preferences, such as language settings, display options, and login credentials
• Marketing Cookies: Track your activity across websites to deliver targeted advertisements and measure campaign effectiveness

8.2 Managing Cookies

You can manage your cookie preferences through your browser settings. However, disabling certain cookies may limit your ability to use some features of our Platform. Most browsers allow you to block third-party cookies while accepting first-party cookies. For more information on cookie management, visit your browser's help section.

9. International Data Transfers

While 711jll primarily operates within the Philippines, some of our service providers and data processing facilities may be located outside the Philippines. When we transfer your personal information to countries that do not provide an adequate level of data protection, we implement appropriate safeguards such as standard contractual clauses, binding corporate rules, and data transfer agreements to ensure your information remains protected in accordance with Philippine data privacy standards.

10. Contact Information and Data Protection Officer

If you have questions, concerns, or complaints regarding this Privacy Policy or our data processing practices, or if you wish to exercise your privacy rights, please contact our Data Protection Officer:

• Email: [email protected] (Subject: Privacy Inquiry)
• Live Chat: Available 24/7 on our website
• Response Time: We will respond to privacy inquiries within fifteen (15) business days

If you are not satisfied with our response, you have the right to lodge a complaint with the National Privacy Commission of the Philippines:

• National Privacy Commission: 5th Floor, Philippine International Convention Center (PICC), Vicente Sotto Street, Pasay City, Metro Manila, Philippines
• Website: privacy.gov.ph
• Email: [email protected]

11. Changes to This Privacy Policy

711jll reserves the right to modify this Privacy Policy at any time to reflect changes in our practices, technology, legal requirements, or business operations. We will notify you of material changes by posting the updated Policy on our Platform with a revised "Last Updated" date. For significant changes that materially affect your rights, we may provide additional notice through email or prominent platform notifications.

Your continued use of the 711jll Platform after the effective date of any changes constitutes your acceptance of the revised Privacy Policy. We encourage you to review this Policy periodically to stay informed about how we protect your information.

Thank you for trusting 711jll with your personal information. We are committed to maintaining the highest standards of data protection and privacy for all our Filipino players.