11wln Privacy Policy

1. Introduction

11wln ("we", "us", "our") is committed to protecting the privacy and personal data of all users of the 11wln platform ("Platform"). This Privacy Policy describes our practices regarding the collection, use, storage, and disclosure of personal information provided to us by users in connection with their use of the Platform and our Services.

This Policy should be read alongside the 11wln Terms & Conditions, which govern the overall use of the Platform. Terms not defined in this Policy carry the meanings ascribed to them in the Terms & Conditions.

Pakistani users are specifically acknowledged as a primary user base for the 11wln Platform. This Policy is designed to be clear and accessible to users across Pakistan, including those accessing the Platform from Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, and other cities.

2. Data Controller

11wln acts as the data controller in respect of personal data collected through the Platform. As data controller, 11wln determines the purposes for which and the means by which personal data is processed.

For all data-related enquiries, including access requests, correction requests, and deletion requests, please contact us using the details provided in Section 14 of this Policy.

3. Data We Collect

11wln collects personal data in the following categories:

3.1 Registration Data. When you create an 11wln account, we collect your full name, date of birth, mobile number or email address, and a password (stored in hashed form — we never store your plain-text password). This information is required to establish and maintain your account.

3.2 KYC Verification Data. To comply with our obligations under applicable anti-money laundering and responsible gaming frameworks, we collect identity documents (such as a CNIC or passport copy), proof of address, and where applicable, evidence of source of funds. KYC data is collected only when required for withdrawal processing or where mandated by our compliance obligations.

3.3 Financial Data. We collect records of deposits and withdrawals processed through your account, including payment method details sufficient to process and record transactions. We do not store full payment card numbers; card tokenisation is handled by our payment processors.

3.4 Usage Data. We collect data about how you interact with the Platform, including pages visited, games played, betting history, session duration, and device and browser information. This data is used for platform improvement, fraud detection, and responsible gaming monitoring.

3.5 Communications Data. If you contact 11wln support, we retain records of those communications, including the content of messages, for support quality and compliance purposes.

3.6 Cookie and Technical Data. We collect IP addresses, browser type, device identifiers, and cookie data as described in Section 8 of this Policy.

4. How We Use Your Data

11wln uses personal data for the following purposes:

• Account Management: To create, maintain, and secure your 11wln account, and to verify your identity and age.
• Service Delivery: To provide access to betting, casino, and gaming services available on the Platform.
• Payment Processing: To process deposits and withdrawals, and to maintain accurate financial records of your account activity.
• Legal Compliance: To fulfil our obligations under applicable anti-money laundering regulations, licensing conditions, and any lawful requests from regulatory or law enforcement authorities.
• Responsible Gaming: To monitor account activity for indicators of problem gambling and to apply responsible gaming restrictions where required by our policies or your own settings.
• Fraud Prevention: To detect, investigate, and prevent fraudulent activity, including duplicate account detection, collusion, and money laundering.
• Customer Support: To respond to your support enquiries and resolve account issues.
• Platform Improvement: To analyse usage patterns and improve the performance, design, and content of the Platform.
• Marketing Communications: To send you promotional offers and updates where you have consented to receive such communications. You may withdraw marketing consent at any time through your account settings.

5. Legal Basis for Processing

11wln processes personal data on the following legal bases:

• Contractual Necessity: Processing required to deliver the Services you have requested under our Terms & Conditions, including account management and payment processing.
• Legal Obligation: Processing required to comply with applicable laws, including KYC, AML, and regulatory reporting obligations.
• Legitimate Interests: Processing for fraud prevention, platform security, and service improvement, where those interests are not overridden by your privacy rights.
• Consent: Processing for marketing communications, where you have provided explicit consent. Consent may be withdrawn at any time without affecting the lawfulness of processing prior to withdrawal.

6. Third-Party Disclosure

11wln does not sell or rent personal data to third parties. We may share your data in the following limited circumstances:

• Payment Processors: We share financial data with payment service providers (including JazzCash, Easypaisa, HBL, UBL, and Meezan Bank integrations) as necessary to process your transactions. These processors are bound by their own privacy and security obligations.
• Game Providers: Usage data may be shared with licensed game developers (such as Pragmatic Play, PG Soft, and Evolution Gaming) to the extent necessary for game delivery and RNG certification compliance.
• Regulatory Authorities: We may disclose data to licensing authorities, financial intelligence units, or law enforcement agencies where required by law or regulation.
• Service Providers: We engage third-party service providers for IT infrastructure, analytics, and customer support functions, who process data on our behalf under data processing agreements that restrict their use of your data.
• Business Transfers: In the event of a merger, acquisition, or sale of assets, user data may be transferred to the acquiring entity, subject to equivalent privacy protections.

7. Data Retention

11wln retains personal data for the following periods:

• Account Data: Retained for the duration of your account's active status, and for a period of five (5) years following account closure, in accordance with standard AML record-keeping obligations.
• KYC Documents: Retained for a minimum of five (5) years from the date of the most recent transaction or account closure, whichever is later.
• Financial Records: Retained for a minimum of five (5) years, or longer where required by applicable law.
• Usage and Log Data: Retained for up to two (2) years from the date of collection for fraud prevention and platform improvement purposes.
• Support Communications: Retained for two (2) years from the date of the communication.

Following expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with our data disposal procedures.

8. Cookies & Tracking Technologies

The 11wln Platform uses cookies and similar technologies for the following purposes:

• Essential Cookies: Required for the Platform to function correctly. These include session cookies that maintain your logged-in state. These cannot be disabled without impairing core Platform functionality.
• Analytics Cookies: Used to collect aggregated information about how users interact with the Platform, to help us identify areas for improvement. Analytics data is anonymised where possible.
• Functional Cookies: Used to remember your preferences, such as language settings, to improve your experience on return visits.

You may manage cookie preferences through your browser settings. Note that disabling essential cookies will impair your ability to use the Platform, including logging in to your account. 11wln does not use third-party advertising cookies or cross-site tracking technologies for external advertising purposes.

9. Data Security

11wln implements appropriate technical and organisational measures to protect personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• HTTPS encryption for all data in transit between your device and the Platform.
• Password hashing using industry-standard algorithms — your plain-text password is never stored.
• Access controls restricting internal access to personal data on a need-to-know basis.
• Regular security assessments of Platform infrastructure.
• Incident response procedures for data breaches, including notification to affected users where required by applicable law.

Despite these measures, no data transmission over the internet can be guaranteed to be completely secure. You acknowledge that you provide personal data to 11wln at your own risk. You are responsible for maintaining the confidentiality of your account credentials.

10. Your Rights

Subject to applicable law, you have the following rights in relation to the personal data 11wln holds about you:

• Right of Access: The right to request a copy of the personal data we hold about you.
• Right to Rectification: The right to request correction of inaccurate or incomplete personal data.
• Right to Erasure: The right to request deletion of your personal data, subject to our legal obligations to retain certain data (see Section 7).
• Right to Restrict Processing: The right to request that we restrict processing of your data in certain circumstances.
• Right to Object: The right to object to processing of your data based on legitimate interests, including direct marketing.
• Right to Data Portability: The right to receive your data in a structured, machine-readable format where technically feasible.
• Right to Withdraw Consent: Where processing is based on consent, the right to withdraw that consent at any time.

To exercise any of these rights, please contact 11wln support as described in Section 14. We will respond to verified requests within a reasonable timeframe, typically within 30 days. We may need to verify your identity before processing requests.

11. International Data Transfers

11wln may transfer personal data to servers or service providers located outside Pakistan. Where such transfers occur, 11wln takes reasonable steps to ensure that your data is protected to a standard equivalent to that described in this Policy, including through the use of data processing agreements with applicable security requirements.

By using the Platform, you consent to the transfer of your personal data outside Pakistan to the extent described in this Policy.

12. Children's Privacy

The 11wln Platform is strictly intended for users aged 18 years and above. We do not knowingly collect personal data from individuals under the age of 18. If we become aware that personal data has been collected from an underage user, that account will be closed and any personal data collected will be deleted in accordance with our data disposal procedures, subject to any legal retention obligations.

If you are a parent or guardian and believe that a minor has registered on the 11wln Platform, please contact us immediately using the details in Section 14.

13. Policy Updates

11wln may update this Privacy Policy from time to time to reflect changes in our data practices, legal requirements, or the Services we provide. Where updates are material, we will notify registered users via their registered email address or through a notice displayed on the Platform. The "Last Updated" date at the top of this Policy reflects the date of the most recent revision.

Your continued use of the Platform following notification of an updated Policy constitutes your acceptance of the revised terms.

14. Contact Us

If you have questions about this Privacy Policy, wish to exercise your data rights, or wish to raise a privacy concern, please contact 11wln through the official support channel available on the Platform.

Contact email (plain text — not a link): [email protected]

We aim to acknowledge all privacy-related enquiries within 5 business days and to resolve them within 30 days, subject to complexity.