11seas Privacy Policy

1About This Privacy Policy

This Privacy Policy ("Policy") applies to all individuals who visit, register on, or use the 11seas platform — including the website at 11seas.net and the 11seas mobile application. The Policy covers all personal data processing activities conducted by 11seas in connection with the provision of online gaming, casino, sports betting, Cockfighting betting, loyalty programme, and related services.

References to "11seas", "we", "us", and "our" in this Policy refer to the 11seas platform and its operating entity. References to "you", "your", and "member" refer to any individual who accesses or uses the 11seas platform, whether registered or not.

This Policy should be read in conjunction with the 11seas Terms & Conditions, which govern your use of the platform. By accepting the Terms & Conditions during registration, you also consent to the data processing practices described in this Policy.

2Personal Data We Collect

11seas collects personal data through several channels — directly from you when you register or interact with the platform, automatically through your use of the platform, and from third-party service providers we work with for payment processing and identity verification.

3How 11seas Uses Your Personal Data

11seas uses the personal data it collects for the following specific purposes:

• Account Registration and Management: To create, verify, and maintain your 11seas account, including processing your CNIC-based KYC verification and linking your Pakistan payment methods.
• Processing PKR Transactions: To facilitate deposits via Easypaisa, JazzCash, HBL, UBL, MCB Bank and other approved Pakistan payment methods, and to process withdrawal requests to your verified payment account.
• Providing Gaming Services: To operate and personalise the 11seas game lobby, calculate and credit loyalty points, settle sports betting and Cockfighting wagers, and deliver live dealer casino sessions.
• Security and Fraud Prevention: To detect, investigate, and prevent fraudulent activity, multiple account creation, money laundering, underage gambling, and other prohibited conduct on the 11seas platform.
• Regulatory Compliance: To fulfil our obligations under applicable anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, and other legal obligations applicable to the operation of an online gaming platform.
• Responsible Gaming: To monitor gaming behaviour patterns that may indicate problem gambling, enforce self-exclusion requests, apply account deposit limits, and support the 11seas responsible gaming programme.
• Customer Support: To respond to your enquiries, resolve account issues, and improve our support service based on the content of your communications with the 11seas team.
• Platform Improvement: To analyse aggregate usage data, diagnose technical issues, and improve the performance of the 11seas platform on Pakistan mobile networks and devices.
• Marketing Communications (with consent only): To send promotional information about 11seas offers, new game launches, and loyalty programme updates to members who have opted in to receive such communications.

4Legal Basis for Processing

11seas processes personal data on the following legal bases, depending on the specific processing activity:

• Contractual Necessity: The majority of 11seas data processing — including account management, KYC verification, PKR payment processing, and gaming service delivery — is necessary for the performance of the contract between 11seas and the member (i.e., the Terms & Conditions).
• Legal Obligation: KYC identity verification, AML transaction monitoring, age verification, and the retention of certain financial records are required by applicable legal and regulatory obligations.
• Legitimate Interests: Security monitoring, fraud detection, platform performance analysis, and responsible gaming monitoring are conducted on the basis of 11seas's legitimate interests in maintaining a secure, fair, and compliant platform.
• Consent: Marketing communications via email and SMS to Pakistan mobile numbers are sent only on the basis of explicit opt-in consent, which may be withdrawn at any time through account settings or by contacting 11seas support.

5Data Sharing & Third Parties

11seas does not sell, rent, or trade your personal data to third parties for their own commercial or marketing purposes. We share personal data with third parties only in the following limited circumstances:

• Payment Processors: We share the minimum necessary transaction data with payment service providers — including Easypaisa, JazzCash, SadaPay, and banking partners — to process your PKR deposits and withdrawals.
• Identity Verification Providers: 11seas uses certified third-party KYC service providers to verify CNIC data and biometric identity documents. These providers process identity data under strict confidentiality obligations.
• Game Software Providers: Live casino studio providers (such as Evolution Gaming) and RNG slot providers receive session and stake data necessary to operate the games. These providers are contractually bound to data protection standards.
• Regulatory Authorities: 11seas may disclose member data to law enforcement, regulatory bodies, or government authorities when required by law, court order, or valid legal process.
• Professional Advisers: Legal counsel, auditors, and compliance consultants may access member data to the extent necessary to provide professional services to 11seas, subject to professional confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of the 11seas business, member data may be transferred to the successor entity, subject to equivalent privacy protections.

6Data Retention

11seas retains personal data for as long as necessary to fulfil the purposes for which it was collected, including legal, regulatory, and compliance requirements. Specific retention periods are as follows:

• Active Account Data: Retained for the duration of your 11seas membership plus a minimum of 5 years following account closure, in line with standard AML record-keeping requirements.
• KYC and Identity Documents: Retained for a minimum of 5 years following account closure or the last transaction on the account, whichever is later.
• Financial Transaction Records: PKR deposit and withdrawal records, including Easypaisa and JazzCash transaction references, are retained for a minimum of 5 years.
• Gaming Activity Logs: Game session and wager history is retained for a minimum of 3 years for responsible gaming and dispute resolution purposes.
• Support Communications: Live chat transcripts and email correspondence are retained for 2 years following the resolution of the relevant query.
• Marketing Consent Records: Records of your marketing opt-in or opt-out preferences are retained for 3 years to demonstrate compliance with consent requirements.

Following the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents reconstruction of individual identities.

7Security Measures

11seas implements a multi-layered security framework to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• Encryption in Transit: All data transmitted between your Pakistan device and 11seas servers — including your 11seas login credentials, KYC documents, and PKR payment data — is encrypted using 256-bit SSL/TLS protocols.
• Encryption at Rest: Sensitive personal data stored on 11seas servers, including CNIC data and payment reference information, is encrypted at rest using AES-256 encryption.
• Access Controls: Access to personal data within 11seas is limited to personnel with a legitimate operational need. All internal access is logged and subject to regular audit review.
• Two-Factor Authentication: 11seas login sessions support SMS-based two-factor authentication (2FA) to your registered Pakistan mobile number, providing an additional layer of account security.
• Fraud Detection Systems: 11seas operates automated fraud detection and anomaly-detection systems that monitor login patterns, device signatures, and transaction behaviour for indicators of unauthorised access or suspicious activity.
• Regular Security Reviews: 11seas conducts periodic internal security reviews and vulnerability assessments to identify and address potential weaknesses in its data security infrastructure.

While 11seas takes extensive measures to protect your personal data, no security system is impenetrable. In the event of a data breach that presents a material risk to members, 11seas will notify affected individuals in accordance with applicable notification requirements.

8Cookies & Tracking Technologies

11seas uses cookies and similar tracking technologies on the 11seas.net website and in the 11seas Android application. The following categories of cookies are used:

• Strictly Necessary Cookies: Essential for the operation of the 11seas platform — including maintaining your 11seas login session, remembering your language and currency preferences, and supporting the security features of the platform. These cookies cannot be disabled without impairing platform functionality.
• Functional Cookies: Used to remember your platform customisation preferences, such as your preferred game lobby layout, notification settings, and responsible gaming limit configurations.
• Analytical Cookies: Used by 11seas to understand aggregate patterns of platform usage — such as which game categories are most popular, which pages have the highest load times on Pakistan mobile networks, and where members encounter technical issues. This data is used in anonymised aggregate form only.

You may manage cookie preferences through your browser settings. Disabling strictly necessary cookies will impair your ability to log in to and use the 11seas platform. Disabling functional and analytical cookies will not prevent you from using 11seas, but may reduce the personalisation of your experience.

9Your Data Rights

As a 11seas member, you hold the following rights in relation to your personal data. To exercise any of these rights, contact the 11seas support team via live chat or by email at [email protected]:

• Right of Access: You may request a copy of all personal data that 11seas holds about you. We will respond to verified access requests within 30 days.
• Right to Rectification: If any personal data held by 11seas is inaccurate or incomplete, you may request that it be corrected. Contact the support team with the correct information and relevant documentation.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data. Note that 11seas may be unable to fulfil deletion requests in full where retention is required for legal, regulatory, or compliance obligations (e.g., KYC and AML record-keeping requirements).
• Right to Restrict Processing: You may request that 11seas limit its processing of your data in certain circumstances, such as while the accuracy of data is being contested.
• Right to Data Portability: You may request a copy of your personal data in a commonly used, machine-readable format. This right applies to data processed on the basis of consent or contractual necessity.
• Right to Object: You may object to processing of your personal data where 11seas is relying on legitimate interests as the legal basis, including profiling for responsible gaming purposes.
• Withdraw Consent: Where processing is based on your consent (primarily marketing communications), you may withdraw that consent at any time by updating your account preferences or contacting support. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

10Children and Minors

11seas is an 18+ platform. The collection or processing of personal data from individuals under the age of 18 is strictly prohibited. 11seas implements mandatory CNIC-based age verification for all members before any real-money gaming activity is permitted.

If 11seas becomes aware that personal data has been collected from an individual under the age of 18, that data will be deleted immediately, the associated account will be closed, and any deposits will be refunded to the originating payment method. If you believe a minor has created a 11seas account, please contact our support team at [email protected] immediately.

11Changes to This Privacy Policy

11seas may update this Privacy Policy from time to time to reflect changes in our data processing practices, applicable legal requirements, or the services we provide. Material changes to this Policy will be communicated to registered members via the email address on file or through a prominent notification on the 11seas platform at least 14 days before the changes take effect.

The "Effective Date" at the top of this Policy reflects when the current version came into force. We encourage all 11seas Pakistan members to review this Policy periodically to stay informed about how we protect their personal data. Continued use of the 11seas platform following notification of a Policy update constitutes acceptance of the revised terms.

12Contact & Data Enquiries

For any questions, concerns, or requests relating to this Privacy Policy or the way 11seas handles your personal data, please contact us through the following channels:

• Live Chat: The fastest channel for privacy enquiries — available 24/7 through the 11seas platform. Our English-language support team will respond to privacy queries in real time.
• Email: [email protected] — for formal data subject requests (access, deletion, portability, etc.), please include "Privacy Request" in your subject line and provide your registered Pakistan mobile number for account identification. We will respond within 30 days of receiving a verified request.