11jj Privacy Policy – Your Data, Your Rights, Our Obligations

1. Introduction

This Privacy Policy ("Policy") describes how 11jj ("we", "us", "Operator") collects, uses, stores, shares and protects personal data in connection with your use of the 11jj platform, including all betting, casino, slots and account management services available at 11jj.asia.

By registering an account or accessing any part of the 11jj platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein. If you do not agree with this Policy, you must not use the 11jj platform.

We take the privacy of our users seriously. The 11jj platform serves Pakistani players across cities including Karachi, Lahore, Islamabad, Rawalpindi and Faisalabad, and we are committed to handling all personal data responsibly and in compliance with applicable data protection principles.

2. Data We Collect

2.1 Registration Data

When you create an 11jj account, we collect the following personal data:

• Full legal name (as it appears on your CNIC);
• Email address;
• Pakistani mobile number (with country code +92);
• Date of birth (for age verification purposes);
• Chosen username and password (stored in hashed form — never in plain text).

2.2 KYC Verification Data

To comply with AML regulations and to verify your identity before processing withdrawals, we collect:

• CNIC number and scanned copies (front and back);
• Selfie photograph for liveness verification;
• Proof of address documents where required for enhanced due diligence.

2.3 Transactional Data

11jj records all deposit and withdrawal transactions, including payment method used (JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, USDT), transaction amounts in PKR, timestamps and transaction reference numbers. This data is retained for regulatory and AML compliance purposes.

2.4 Behavioural & Technical Data

We automatically collect technical data when you access the 11jj platform, including your IP address, device type and operating system, browser type and version, session duration, pages visited, game history and betting activity. This data is used for fraud prevention, platform improvement and responsible gaming monitoring.

2.5 Communications Data

Where you contact 11jj support via email or live chat, we retain records of those communications for quality assurance, dispute resolution and regulatory audit purposes.

3. How We Use Your Data

11jj does not use your personal data for automated decision-making that produces legal effects on your account without human review, except where automated systems flag accounts for AML or fraud review — in which case a human compliance officer conducts a final assessment.

4. Legal Basis for Processing

11jj processes your personal data on the following legal grounds:

• Contractual necessity — Processing required to fulfil our obligations to you as a registered platform user, including account management, bet settlement and withdrawal processing;
• Legal obligation — Processing required to comply with AML regulations, licensing conditions and other applicable legal requirements including KYC verification and transaction monitoring;
• Legitimate interests — Processing for fraud prevention, platform security, responsible gaming monitoring and service improvement, where these interests are not overridden by your privacy rights;
• Consent — Processing for optional communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

5. Data Sharing

11jj shares your personal data only in the following circumstances:

5.1 Service Providers

We share data with third-party service providers who process data on our behalf under written data processing agreements. These include KYC verification providers, payment processors (including JazzCash and Easypaisa integration partners), fraud detection services, game providers and cloud infrastructure providers. All processors are contractually required to handle data only for the specified purpose and to apply appropriate security measures.

5.2 Regulatory and Legal Disclosure

11jj will disclose personal data to regulatory authorities, law enforcement agencies or courts where required to do so by applicable law, a valid legal order, or our licensing obligations. We will notify you of such disclosure where legally permitted to do so.

5.3 Business Transfers

In the event of a merger, acquisition or sale of all or part of the 11jj business, personal data held by the platform may form part of the transferred assets. You will be notified in advance of any such transfer and of any material changes to the privacy terms applicable to your data.

6. Cookies & Tracking Technologies

The 11jj platform uses cookies and similar tracking technologies for the following purposes:

• Essential cookies — Required for platform functionality, session authentication and security. These cannot be disabled without impairing your ability to use the platform;
• Analytics cookies — Used to measure platform usage patterns, page performance and user journeys in aggregated, anonymised form. This helps us improve the 11jj experience;
• Preference cookies — Store your platform settings such as language, odds format and favourite markets;
• Fraud prevention cookies — Device fingerprinting cookies used to detect suspicious activity and protect your account.

You can manage non-essential cookies through your browser settings. Please note that disabling certain cookies may affect platform functionality. For most players on mobile Chrome or Safari in Pakistan, essential cookies are required for login, deposit and bet placement to function correctly.

7. Data Retention

We retain your personal data for as long as your 11jj account remains active, plus the following minimum retention periods required by our regulatory obligations:

• KYC documents — Minimum 5 years following account closure, in line with AML record-keeping requirements;
• Transactional records — Minimum 5 years following each transaction, for AML audit trail purposes;
• Communications records — 3 years from the date of each communication;
• Behavioural and technical data — 24 months from collection, or for the duration of the account, whichever is longer.

Following the expiry of applicable retention periods, personal data is securely deleted or anonymised so that it can no longer be attributed to an identified individual.

8. Data Security

11jj implements a range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction or alteration:

• TLS 1.3 encryption for all data in transit between your device and our servers;
• AES-256 encryption for sensitive data at rest, including KYC documents and authentication credentials;
• Two-factor authentication available for all player accounts;
• Role-based access controls ensuring that only authorised personnel can access personal data for legitimate operational purposes;
• Regular penetration testing and security audits conducted by external specialists;
• Intrusion detection and 24/7 security monitoring of platform infrastructure.

Despite these measures, no online platform can guarantee absolute security. In the unlikely event of a data breach that affects your rights, 11jj will notify affected users in accordance with applicable regulatory requirements.

9. Your Rights

As a registered 11jj user, you have the following rights in relation to your personal data:

• Right of access — Request a copy of the personal data we hold about you;
• Right to rectification — Request correction of inaccurate or incomplete personal data;
• Right to erasure — Request deletion of your personal data, subject to our legal retention obligations;
• Right to restrict processing — Request that we limit how we use your data in certain circumstances;
• Right to data portability — Request your data in a structured, commonly used, machine-readable format;
• Right to object — Object to processing based on legitimate interests, including direct marketing;
• Right to withdraw consent — Withdraw consent for optional processing at any time, without affecting the lawfulness of prior processing.

To exercise any of these rights, contact our support team at the address listed in Section 13. We will respond within 30 days. Some requests may require identity verification before processing to protect your account security.

10. Children's Privacy

The 11jj platform is strictly for individuals aged 18 years and above. We do not knowingly collect personal data from individuals under the age of 18. If we discover that an account has been registered by or on behalf of a minor, the account will be immediately suspended, all data will be deleted (except where retention is required for AML purposes), and any deposits will be refunded to the originating payment method following investigation.

If you believe a minor has registered an 11jj account, please contact us immediately at the address in Section 13 so that we can take prompt remedial action.

11. International Data Transfers

11jj may process or store personal data on servers located outside Pakistan, including in jurisdictions where the 11jj platform's infrastructure partners operate. Where personal data is transferred internationally, we ensure that appropriate safeguards are in place — including standard contractual clauses and data processing agreements — to provide a level of protection equivalent to that described in this Policy.

By registering an 11jj account, you consent to the international transfer of your personal data for the purposes described in this Policy, subject to the safeguards described above.

12. Changes to This Policy

11jj reserves the right to update this Privacy Policy at any time to reflect changes in platform operations, applicable law or industry best practice. Material changes will be communicated to registered users via email notification or a prominent in-platform notice at least 7 days before the updated Policy takes effect.

The "Last updated" date at the top of this page reflects the most recent revision. Continued use of the 11jj platform following notification of changes constitutes acceptance of the revised Policy. We recommend reviewing this page periodically.

13. Contact Us

For privacy-related enquiries, data subject rights requests, or to report a suspected data security incident, please contact the 11jj data protection team:

Email: [email protected]

Please include "Privacy Request" in your subject line. We will acknowledge your request within 2 business days and provide a full response within 30 days. Complex requests may require additional time, in which case we will notify you of the extended timeline.