Privacy Policy – 11ee Pakistan Online Gaming Platform

1Who We Are

This Privacy Policy applies to 11ee, the online gaming platform operated at https://11ee.bet. References to "11ee", "we", "us", or "our" in this document refer to the platform and the entity operating it. References to "you", "your", or "the player" refer to any individual who accesses, registers with, or uses 11ee's services.

11ee is the data controller for the personal information it collects from players in Pakistan. This means 11ee decides the purposes for which your personal data is processed and the means by which that processing takes place. Where 11ee uses third-party service providers to process data on its behalf — for example payment processors — those providers act as data processors under 11ee's instructions.

Any questions about this Privacy Policy or about how 11ee handles your data can be directed to the support team at support@11ee.bet. The 11ee support team is available 24 hours a day and will respond to privacy-related queries within 24 hours.

2Data We Collect

11ee collects personal data in the following categories. The information collected is the minimum necessary for each specific purpose.

3How We Collect Your Data

11ee collects your personal data through the following channels:

3.1 Direct Collection — Information You Provide

• During account registration — name, CNIC, mobile number, email, date of birth.
• During KYC verification — CNIC copy, proof of address documents.
• During payment processing — mobile wallet numbers, bank reference details, card identifiers.
• During support interactions — content of live chat conversations and email correspondence.
• During responsible gaming settings — deposit limits, session reminders, self-exclusion requests.

3.2 Automatic Collection — Platform Activity

When you use 11ee, certain technical and behavioural data is collected automatically by the platform's systems. This includes your IP address, device information, browser type, pages visited within 11ee, games accessed, bet placement activity, and session timestamps. This data is collected using server logs and cookies. It is used primarily for security purposes, fraud detection, and platform improvement.

3.3 Third-Party Sources

In some cases, 11ee may receive data about you from third parties as part of its verification and fraud prevention obligations. This can include verification checks run against CNIC databases, credit reference or identity verification services, and payment processor transaction records. Such third-party data processing is conducted strictly within the bounds of the legal basis described in Section 5.

4Why We Use Your Data

11ee processes personal data for the following clearly defined purposes. No processing takes place outside these stated purposes without separate consent or a new legal basis.

• Account creation and management – verifying your identity, maintaining your account record, and enabling login access.
• Payment processing – executing deposits and withdrawals in PKR via Easypaisa, JazzCash, NayaPay, SadaPay, IBFT bank transfer, and card payment.
• KYC and AML compliance – verifying that account holders are who they say they are and that funds deposited have a legitimate origin, as required by anti-money laundering obligations.
• Fraud and security – detecting and preventing unauthorised account access, bonus abuse, multiple account fraud, and payment fraud through pattern analysis and IP monitoring.
• Customer support – resolving queries, disputes, and technical issues submitted through live chat or email.
• Platform improvement – analysing aggregated usage data to understand how players interact with the platform and to prioritise product improvements.
• Personalisation – displaying relevant game recommendations or promotional offers based on your activity on 11ee. You can opt out of personalisation from Account Settings.
• Responsible gaming – monitoring gaming behaviour patterns to identify potential problem gambling indicators and to enforce player-set limits and self-exclusion arrangements.
• Legal obligations – retaining transaction and identity records as required by applicable law, and disclosing data to regulatory or law enforcement bodies when legally compelled to do so.

5Legal Basis for Processing

Every instance of data processing at 11ee rests on one of the following legal bases:

• Contract performance – processing that is necessary to provide the service you have registered for. Without this, 11ee cannot operate your account, process your bets, or pay out your winnings.
• Legal obligation – processing required by applicable law, including KYC/AML verification requirements and the retention of financial transaction records.
• Legitimate interests – processing carried out to pursue 11ee's legitimate business interests, including fraud prevention, security monitoring, and product improvement, provided those interests are not overridden by your privacy rights.
• Consent – processing based on your freely given, specific consent. This applies primarily to marketing communications. You can withdraw consent for marketing at any time without affecting your account or service.

6Who We Share Your Data With

11ee does not sell, rent, or trade your personal data. Data is shared with third parties only in the following strictly defined circumstances:

6.1 Payment Processors

To execute your deposits and withdrawals, 11ee shares the minimum required transaction data with the relevant payment provider — Easypaisa, JazzCash, NayaPay, SadaPay, your IBFT bank, or your card's payment network. These providers are contractually required to process your data only for the specific transaction purpose and are prohibited from using it for any other purpose.

6.2 Identity Verification Providers

11ee uses approved third-party identity verification services to validate CNIC data during KYC. Your identity data is transmitted to these services in encrypted form and is not retained by the verification provider beyond the period required to complete the verification check.

6.3 Technology and Infrastructure Partners

11ee uses cloud infrastructure and technology service providers to host platform data. These providers operate under data processing agreements that prohibit them from accessing, using, or disclosing your personal data beyond what is strictly necessary to provide their technical services to 11ee.

6.4 Game Content Providers

Some games in the 11ee lobby are provided by third-party certified game studios. These providers may receive anonymised session data — such as game round identifiers and bet amounts — for the purpose of game integrity monitoring. They do not receive your name, contact details, or payment information.

6.5 Legal and Regulatory Disclosure

11ee may disclose personal data to law enforcement bodies, regulatory authorities, or courts when required to do so by law, court order, or regulatory obligation. 11ee will notify you of such disclosure where legally permitted to do so.

7Cookies & Tracking Technologies

11ee uses cookies and similar tracking technologies on its platform. Cookies are small data files stored on your device that help the platform function correctly and remember your preferences. 11ee uses the following types of cookies:

• Essential cookies – required for the platform to function. These include session cookies that keep you logged in during your visit. Without them, 11ee cannot operate. These cannot be opted out of.
• Functional cookies – remember your preferences such as language settings and last-used payment method. These improve your experience but are not strictly essential.
• Analytics cookies – collect anonymised data about how players navigate 11ee, which pages are most visited, and where users encounter difficulty. This data is aggregated and used to improve the platform. Individual player behaviour is not singled out.
• Security cookies – used to detect fraudulent login attempts, bot activity, and unusual account access patterns.

You can manage cookie preferences through your browser settings. Disabling functional or analytics cookies will not prevent you from using 11ee, but may affect certain personalisation features.

8Data Retention

11ee retains personal data only for as long as necessary for the purpose for which it was collected, or as required by applicable law. The following retention periods apply as a general guide:

• Account and identity data – retained for the duration of your account plus a minimum of five years following account closure, as required for AML compliance and potential dispute resolution.
• Transaction data – retained for a minimum of five years from the date of the transaction, in accordance with financial record-keeping requirements.
• Support communications – retained for two years from the date of the most recent communication in a support thread, unless the matter relates to an open dispute.
• Technical and session logs – retained for 12 months from the date of the logged activity, primarily for security and fraud investigation purposes.
• Marketing consent records – retained for the duration of your consent plus a reasonable period afterward to demonstrate the basis on which you were contacted.

When the retention period for a category of data expires, 11ee securely deletes or anonymises the data in accordance with its internal data management procedures.

9Your Privacy Rights

As a player at 11ee, you have the following rights in respect of your personal data. These rights can be exercised by contacting support@11ee.bet with the subject line "Privacy Request".

10Security Measures

11ee takes the security of your personal data seriously and maintains a range of technical and organisational safeguards to protect it against unauthorised access, disclosure, alteration, or destruction.

In the event of a personal data breach that poses a risk to player rights, 11ee will notify affected players within 72 hours of becoming aware of the breach, detailing the nature of the incident, the data involved, and the steps taken to mitigate impact.

11Children and Minors

11ee's services are strictly for adults aged 18 and over. 11ee does not knowingly collect personal data from anyone under the age of 18. Age verification checks are built into the registration process precisely to prevent minors from creating accounts.

If 11ee becomes aware that it has inadvertently collected personal data from a minor, that data will be securely deleted immediately and the associated account will be closed. If you believe that a minor has registered at 11ee, please contact support@11ee.bet immediately so the account can be reviewed and closed if confirmed.

12Responsible Gaming & Data Use

11ee uses a subset of player activity data specifically for responsible gaming purposes. This includes monitoring session duration, frequency of play, deposit velocity, and patterns that may indicate a change in gaming behaviour toward problematic levels. This monitoring is carried out as part of 11ee's duty of care to its players and is not used for any other purpose.

If 11ee's responsible gaming monitoring system flags a concern with a player's account, the player may receive a proactive communication from the support team. This contact is always supportive in nature — it is never punitive and never results in marketing communications. Players who have set self-exclusion arrangements at 11ee have their data flagged to prevent marketing contact during the exclusion period.

For full details on 11ee's responsible gaming tools and how to use them, please visit Responsible Gaming.

13Third-Party Links

The 11ee platform does not contain outbound links to third-party websites. However, if at any point a link to an external resource is present, 11ee is not responsible for the privacy practices of those external sites. This Privacy Policy applies solely to data processed by 11ee through its own platform. Any interaction you have with a third-party site after leaving 11ee is governed by that site's own privacy policy.

14Changes to This Privacy Policy

11ee reviews and updates this Privacy Policy periodically to reflect changes in the platform's data practices, applicable law, or regulatory guidance. The date of the most recent update is always displayed at the top of this page.

Where a change is material — meaning it significantly alters how your data is used or your privacy rights — 11ee will notify you by email to your registered address and via a notification on the platform at least 14 days before the change takes effect. Non-material changes such as clarifications or typographical corrections may be made without advance notice. Continued use of 11ee following notification of a material change constitutes acceptance of the revised policy.

15Contact & Privacy Requests

For any questions about this Privacy Policy, to exercise your data rights, or to raise a concern about how 11ee has handled your personal information, please contact the 11ee team through the following channels:

If you have submitted a privacy request and are not satisfied with 11ee's response, you have the right to escalate your complaint to the relevant data protection authority or gaming regulator under whose jurisdiction 11ee operates.