jj11 Privacy Policy

1. Data Controller

1.1 For the purposes of this Policy, jj11 ("the Company", "we", "us", "our") acts as the data controller in respect of personal data collected from players via the jj11 Platform.

1.2 As data controller, jj11 determines the purposes and means of processing personal data collected through registration, KYC verification, payment processing, and general Platform use.

1.3 All data protection queries, subject access requests, and complaints should be directed to jj11 at: [email protected]

2. Personal Data We Collect

2.1 jj11 collects and processes the following categories of personal data from players:

Identity Data

• Full legal name as it appears on official identification
• Date of birth
• Pakistani Computerised National Identity Card (CNIC) number and document images
• Passport details (where provided as an alternative identity document)

Contact Data

• Email address
• Pakistani mobile phone number
• Residential address
• City of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad)

Financial Data

• JazzCash or Easypaisa mobile wallet account details
• Bank account details for withdrawals (HBL, UBL, Meezan Bank, Bank Alfalah, and others)
• Cryptocurrency wallet addresses (where applicable)
• Deposit and withdrawal transaction history in PKR

Technical & Usage Data

• IP address and approximate geographic location
• Device type, operating system, and browser information
• Login timestamps and session duration
• Pages visited and features used within the jj11 Platform
• Game history and betting records

Communications Data

• Support ticket content and chat transcripts
• Email correspondence with jj11
• Responses to surveys or feedback requests

2.2 jj11 does not intentionally collect special categories of personal data (e.g., health data, political opinions, or biometric data) beyond what is strictly required for responsible gaming assessments.

3. How We Collect Your Data

3.1 jj11 collects personal data through the following means:

• Direct collection: Information you provide when registering a jj11 account, completing KYC verification, making deposits or withdrawals, or contacting support.
• Automated collection: Technical data collected automatically as you use the Platform, including through cookies, web beacons, and server logs.
• Third-party sources: Identity verification services, payment processors (JazzCash, Easypaisa, partner banks), fraud detection providers, and publicly available sanctions and PEP screening databases.

4. Legal Basis for Processing

4.1 jj11 processes personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil the player agreement — including account management, deposits, withdrawals, game provision, and support.
• Legal obligation: Processing required to comply with jj11's licensing obligations, including KYC/AML requirements, age verification, and regulatory reporting.
• Legitimate interests: Processing for fraud prevention, Platform security, responsible gaming monitoring, and service improvement — where jj11's legitimate interests are not overridden by your rights.
• Consent: Processing for marketing communications, where you have provided explicit opt-in consent. You may withdraw marketing consent at any time by contacting [email protected].

5. How We Use Your Personal Data

5.1 jj11 uses your personal data for the following purposes:

• Creating and managing your jj11 account, including login authentication and session management
• Processing deposits and withdrawals in PKR via your chosen payment method
• Conducting KYC identity and age verification in compliance with licensing requirements
• Conducting Anti-Money Laundering (AML) screening and transaction monitoring
• Providing and improving the jj11 game library, sports betting markets, and Platform features
• Administering bonuses, promotions, and loyalty programmes
• Providing customer support and resolving complaints
• Enforcing responsible gaming limits, cooling-off periods, and self-exclusion arrangements
• Detecting, investigating, and preventing fraud, cheating, and prohibited conduct
• Sending service-related communications (account alerts, transaction confirmations, security notifications)
• Sending marketing communications where you have given consent
• Complying with legal, regulatory, and audit obligations

6. Data Sharing & Disclosure

6.1 jj11 does not sell, rent, or trade your personal data to third parties for their independent marketing purposes.

6.2 jj11 may share your personal data with the following categories of recipients, strictly on a need-to-know basis:

• Payment processors: JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, Skrill, Neteller, and cryptocurrency network providers — for transaction processing.
• Identity verification providers: Third-party KYC and AML screening services used to verify your identity and comply with licensing requirements.
• Game software providers: Licensed game developers whose titles are hosted on the jj11 Platform may receive limited technical data to facilitate game delivery and RNG certification.
• Fraud prevention services: Third-party providers engaged to detect and prevent fraudulent activity on the Platform.
• Regulatory and licensing authorities: Where jj11 is legally required to disclose data to its licensing authority, law enforcement, or other competent governmental bodies.
• Professional advisers: Legal, accounting, and audit professionals engaged by jj11 under strict confidentiality obligations.

6.3 All third-party data processors engaged by jj11 are bound by data processing agreements that require them to process data only on jj11's instructions and in accordance with applicable data protection standards.

7. Cookies & Tracking Technologies

7.1 The jj11 Platform uses cookies and similar tracking technologies to operate and improve the Platform experience. Cookies are small data files stored on your device when you access jj11.asia.

7.2 jj11 uses the following categories of cookies:

• Strictly necessary cookies: Required for the Platform to function — session management, login authentication, and security. These cannot be disabled.
• Functional cookies: Remember your preferences (language, display settings) to personalise your jj11 experience.
• Analytics cookies: Collect aggregated, anonymised data about how players use the Platform to help jj11 improve its services.
• Marketing cookies: Track your interaction with jj11 promotional content where you have consented to receive marketing communications.

7.3 You can manage cookie preferences through your browser settings. Disabling strictly necessary cookies may affect the functionality of the jj11 Platform.

8. Data Retention

8.1 jj11 retains personal data for as long as necessary to fulfil the purposes set out in this Policy or as required by applicable law and licensing obligations.

8.2 In general, jj11 retains:

• Account registration and KYC data: for the duration of the account plus a minimum of five (5) years following account closure, in compliance with AML regulatory requirements.
• Financial transaction records: minimum five (5) years from the date of each transaction.
• Support and communications data: up to three (3) years from the date of last communication.
• Technical and usage logs: up to twelve (12) months on a rolling basis.

8.3 Where jj11 no longer has a legal or contractual basis for retaining your data, it will be securely deleted or anonymised.

9. Data Security

9.1 jj11 implements appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These include:

• 256-bit SSL/TLS encryption on all connections to the jj11 Platform
• Encrypted storage of sensitive personal and financial data
• Access controls restricting internal data access to authorised personnel on a need-to-know basis
• Two-factor authentication available for all player accounts
• Regular security assessments and penetration testing
• Incident response procedures for detecting, containing, and reporting data breaches

9.2 Notwithstanding these measures, no data transmission over the internet is entirely secure. jj11 cannot guarantee absolute security but commits to maintaining industry-standard protections and promptly addressing any identified vulnerabilities.

10. Your Privacy Rights

10.1 As a jj11 player, you have the following rights in relation to your personal data, subject to applicable law:

• Right of access: Request a copy of the personal data jj11 holds about you.
• Right to rectification: Request correction of inaccurate or incomplete personal data.
• Right to erasure: Request deletion of your personal data where jj11 no longer has a legal basis to retain it. Note that regulatory retention obligations may limit this right.
• Right to restriction: Request that jj11 restricts processing of your data in certain circumstances.
• Right to data portability: Request a machine-readable copy of data you have provided to jj11.
• Right to object: Object to processing based on legitimate interests, including direct marketing.
• Right to withdraw consent: Withdraw consent for marketing communications at any time without affecting the lawfulness of prior processing.

10.2 To exercise any of these rights, contact jj11 at [email protected]. jj11 will respond to data subject requests within 30 calendar days of receipt, and will request identity verification before processing any request.

11. Children's Privacy

11.1 The jj11 Platform is strictly for users aged 18 and above. jj11 does not knowingly collect or process personal data from individuals under the age of 18.

11.2 Age is verified as part of the mandatory KYC process before withdrawal access is granted. Where jj11 becomes aware that personal data has been collected from a person under 18, the associated account will be immediately closed, all data will be deleted, and any deposited funds will be returned to the payment source.

11.3 Parents or guardians who believe a minor has registered on the jj11 Platform should contact [email protected] immediately.

12. Amendments to This Policy

12.1 jj11 reserves the right to update this Privacy Policy at any time. Material changes will be notified via the Platform or to your registered email address where reasonably practicable.

12.2 The "Last Updated" date at the top of this page reflects the date of the most recent revision. Continued use of the jj11 Platform following publication of a revised Policy constitutes acceptance of the revised terms.

13. Contact & Complaints

13.1 For all data protection queries, subject access requests, or complaints regarding jj11's handling of your personal data, please contact:

Email: [email protected]

13.2 jj11 will acknowledge all data protection communications within 5 business days and endeavour to resolve queries within 30 calendar days.

13.3 If you are not satisfied with jj11's response, you may have the right to lodge a complaint with the relevant data protection supervisory authority in the jurisdiction applicable to your situation.