11wln Privacy Policy

1. Introduction

This Privacy Policy ("Policy") is issued by 11wln, accessible at https://11wln.cam ("Platform", "11wln", "we", "us", "our"). It sets out how we collect, use, disclose and safeguard the personal data of individuals ("User", "you", "your") who access or use the Platform, including registered account holders and visitors.

11wln is an English-language online betting and casino information platform designed for users in Pakistan. By using the Platform, you acknowledge that you have read this Policy in full and consent to the data processing practices described herein. If you do not accept this Policy, please discontinue use of the Platform immediately.

2. Definitions

For the purposes of this Policy, the following terms have the meanings assigned to them:

• "Personal Data" — any information relating to an identified or identifiable natural person; includes name, email address, phone number, CNIC number, IP address and payment-account details.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, retrieval, use, disclosure, transfer or deletion.
• "Data Controller" — the entity that determines the purposes and means of processing Personal Data. For the purposes of this Policy, the Data Controller is the Operator of the 11wln Platform.
• "Data Processor" — a third party that processes Personal Data on behalf of the Data Controller, pursuant to a data-processing agreement.
• "KYC" — Know Your Customer; the identity and document verification process required under applicable operator obligations before withdrawals are processed.
• "Cookies" — small text files placed on your device by a website to store information about your session or preferences.
• "Consent" — freely given, specific, informed and unambiguous indication of your wishes by which you agree to the processing of your Personal Data for a stated purpose.

3. Personal Data We Collect

3.1 Data You Provide Directly

When you register for an Account, use Platform features or contact support, you provide us with Personal Data including:

• Full legal name, date of birth and country of residence;
• Email address and mobile phone number;
• CNIC or other government-issued identity document (for KYC verification);
• Payment account details, including bank account numbers, IBAN, or mobile wallet identifiers (e.g., Easypaisa or JazzCash numbers);
• Correspondence and support messages sent to us;
• Self-reported responsible gambling information, including limit preferences and self-exclusion requests.

3.2 Data Collected Automatically

When you access the Platform, certain technical data is collected automatically:

• IP address and approximate geolocation (city/region level);
• Device type, operating system and browser version;
• Pages visited, session duration and click-path data;
• Referring URL and search terms where applicable;
• Cookies and similar tracking technology identifiers (see Section 9).

3.3 Transaction and Betting Data

All financial transactions on the Platform — deposits, withdrawals, bets placed, game results and bonus activity — are recorded as part of the Platform's operational and regulatory record-keeping obligations. This data is associated with your Account and retained in accordance with Section 8 below.

3.4 Summary Table

4. Lawful Basis for Processing

Where applicable international data-protection principles require a lawful basis for processing Personal Data, 11wln relies on the following bases:

• Contract performance: Processing necessary to fulfil our contractual obligations to you as an Account holder — including operating your Account, processing deposits and withdrawals, and providing customer support.
• Legal obligation: Processing required to comply with the Operator's licensing conditions, anti-money-laundering obligations, KYC requirements and any applicable regulatory reporting obligations.
• Legitimate interests: Processing carried out for fraud prevention, platform security, analytics and service improvement, where our legitimate interests are not overridden by your fundamental rights and freedoms.
• Consent: Processing for optional purposes — such as sending marketing communications or placing non-essential cookies — where we have obtained your prior, explicit and informed consent. You may withdraw consent at any time.

5. How We Use Your Data

11wln processes your Personal Data for the following purposes:

5.1 Platform Operation

To register and maintain your Account; to process deposits, withdrawals and bets; to verify your identity (KYC); to apply responsible gambling tools including limits and self-exclusion; and to deliver customer support in English (and Urdu on request) to users across Pakistan.

5.2 Security and Fraud Prevention

To detect and prevent fraudulent activity, money laundering, multiple-account creation and unauthorised access. This includes monitoring transaction patterns, IP addresses and login activity for anomalies. Technical data and betting history may be reviewed by our security team or shared with the Operator's compliance function in connection with suspected fraudulent activity.

5.3 Legal and Regulatory Compliance

To satisfy the Operator's obligations under its applicable gambling licence, including anti-money-laundering (AML) checks, responsible gambling record-keeping, and cooperation with lawful requests from regulatory or law enforcement authorities. Personal Data retained for compliance purposes may be held beyond the standard Account retention period.

5.4 Platform Analytics and Improvement

To analyse aggregated, anonymised usage data — such as pages visited, feature interaction and session duration — in order to improve the Platform's design, performance and content. Where analytics involve Personal Data, processing is based on legitimate interests and is subject to appropriate safeguards.

5.5 Communications

To send you transactional communications related to your Account — including deposit confirmations, withdrawal status updates, KYC requests and responsible gambling notifications. Marketing or promotional communications are sent only with your prior consent and you may opt out at any time.

6. Data Sharing & Disclosure

11wln does not sell your Personal Data to third parties. We may share your data only in the following circumstances:

6.1 Service Providers (Data Processors)

We engage third-party service providers who process data on our behalf, including payment processing partners, KYC verification providers, cloud hosting services, analytics platforms and customer support tools. All such providers are contractually bound to process data only as instructed by 11wln and to implement appropriate security measures.

6.2 The Operator

Personal Data may be shared with the Operator entity holding the gambling licence under which the Platform operates, for the purposes of regulatory compliance, account management and dispute resolution.

6.3 Legal and Regulatory Authorities

Where required by law, court order or a binding request from a competent regulatory or law enforcement authority, 11wln will disclose the minimum Personal Data necessary to comply with that obligation. We will notify you of any such disclosure where we are legally permitted to do so.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of the Platform's business, Personal Data held by 11wln may be transferred to the acquiring entity, subject to equivalent data-protection obligations. Users will be notified of any material change in data controller identity.

6.5 Aggregated or Anonymised Data

11wln may share aggregated or fully anonymised data — from which no individual can be identified — with partners, advertisers or research bodies for statistical or business purposes. Such data is not Personal Data and is not subject to this Policy.

7. International Data Transfers

11wln operates globally and may transfer your Personal Data to servers or service providers located outside Pakistan. Where such transfers occur, we take reasonable steps to ensure that adequate protections are in place — including contractual safeguards consistent with internationally recognised data-transfer mechanisms.

Given that Pakistan does not yet have a formal international data-transfer framework, users should be aware that data transferred outside Pakistan may be subject to the laws of the destination country rather than Pakistani law. By using the Platform, you acknowledge and accept this.

8. Data Retention

11wln retains Personal Data for as long as your Account is active and for a period thereafter as required by the Operator's licensing obligations, anti-money-laundering regulations and applicable legal requirements. As a general guide:

Once the applicable retention period expires, data is securely deleted or anonymised. Specific retention periods may vary in accordance with the Operator's licence conditions.

9. Cookies & Tracking Technologies

9.1 What Are Cookies?

Cookies are small text files stored on your device when you visit a website. They allow the website to recognise your device, remember preferences and collect usage information. 11wln uses cookies and similar technologies (such as local storage and pixel tags) to operate and improve the Platform.

9.2 Types of Cookies We Use

• Strictly Necessary Cookies: Required for the Platform to function. These include session authentication cookies, security tokens and load-balancing cookies. They cannot be disabled without breaking core Platform functionality.
• Functional Cookies: Remember your preferences — such as language setting (English), currency display (PKR) and time zone (Pakistan Standard Time / UTC+5) — to personalise your experience.
• Analytics Cookies: Collect anonymised data about how users navigate the Platform. This helps us understand which pages perform well and where improvements are needed. Analytics data is aggregated and not linked back to individual identities.
• Marketing Cookies: Where consented to, these track your interaction with Platform content to help us deliver relevant promotional information. You may withdraw consent at any time.

9.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the Platform. Instructions for managing cookies are available in the help section of your browser. Continuing to use the Platform without adjusting your settings constitutes acceptance of our use of cookies as described in this section.

10. Data Security

11wln implements a range of technical and organisational security measures to protect your Personal Data against unauthorised access, disclosure, alteration or destruction. These measures include:

• SSL/TLS encryption for all data transmitted between your device and our servers;
• Encrypted storage of sensitive data including payment credentials and identity documents;
• Role-based access controls limiting who can access Personal Data internally;
• Regular security assessments and penetration testing of Platform infrastructure;
• Two-factor authentication options for user Accounts.

Notwithstanding the above, no internet-based system is wholly immune from security risks. You are responsible for maintaining the security of your own devices and Account credentials. If you believe your Account has been compromised, please contact support immediately.

11. Your Data Rights

Consistent with internationally recognised data-protection principles, 11wln respects the following rights in relation to your Personal Data:

To exercise any of the above rights, please contact us using the details in Section 16. We will respond to verified requests within 30 days, or notify you if additional time is required. We will not charge a fee for reasonable requests.

12. Minors and Age Restriction

The Platform is strictly for adults aged 18 years or older — or the higher minimum age required by the Operator's licence jurisdiction. 11wln does not knowingly collect Personal Data from individuals below this age threshold. If we become aware that Personal Data has been collected from a minor, we will take immediate steps to delete that data and close the associated Account.

If you are a parent or guardian and believe that a minor in your care has created an Account on 11wln, please contact us immediately at [email protected] so we can investigate and act promptly.

13. Marketing Communications

11wln sends marketing and promotional communications — including information about bonuses, offers, and platform features — only to users who have provided explicit prior consent to receive such communications. You may withdraw this consent at any time by:

• Clicking the "unsubscribe" link in any marketing email;
• Updating your communication preferences in your Account settings; or
• Contacting our support team at [email protected].

Transactional communications — such as deposit confirmations, withdrawal updates, KYC requests and responsible gambling notifications — are sent as part of the Platform's operational obligations and are not subject to marketing opt-out.

14. Third-Party Links and Services

The Platform may contain references to third-party services (such as payment providers) that operate under their own privacy policies. 11wln is not responsible for the privacy practices of third-party services. When you use a payment method such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah, your transaction data is also subject to that provider's own terms and privacy practices.

We recommend that you review the privacy policy of any third-party service before providing your personal information. The listing of payment provider names on this Platform does not constitute endorsement of their privacy practices.

15. Amendments to This Policy

11wln reserves the right to update or amend this Privacy Policy at any time. When material changes are made, we will post the updated Policy on this page with a revised Effective Date. Where technically feasible, we will also notify registered users via their registered email address.

Your continued use of the Platform after a revised Policy has been published constitutes your acceptance of the changes. We encourage you to review this Policy periodically. The current Effective Date is displayed at the top of this page.

16. Contact Us

If you have any questions, concerns or requests relating to this Privacy Policy or the processing of your Personal Data, please contact the 11wln data team:

All enquiries are handled in Pakistan Standard Time (PKT / UTC+5). For complaints that cannot be resolved directly, you may refer the matter to the data protection supervisory authority of the Operator's licensing jurisdiction.