Privacy Policy — 11qp: Your Data, Protected

A 11qp, the operator of the platform available at 11qp.click, is the controller responsible for processing personal data collected during the use of sports betting, online casino, and other platform services.

For the purposes of this Privacy Policy, data processing follows the definitions established by the General Data Protection Law (LGPD, Law No. 13.709/2018), including the concepts of controller, processor, data subject, personal data, and sensitive personal data.

The Data Protection Officer (DPO) of the 11qp can be contacted at privacidade@11qp.click for any questions regarding personal data processing, the exercise of data subject rights, or security incident notifications.

A 11qp collects personal data at different points during your interaction with the platform. Below is a breakdown by category:

A 11qp uses collected data exclusively for the purposes described below. No data is used beyond these purposes without the data subject's express consent:

• Account creation and management: verify identity, keep registration details up to date, and ensure secure access;
• Service delivery: process sports bets, manage casino sessions, release bonuses, and calculate cashback;
• Payment processing: process deposits via Pix, boleto bancário, card, and digital wallets (Mercado Pago, PicPay), and handle withdrawals to your registered Pix key;
• Compliance verification (KYC/AML): verify identity, confirm eligibility to use the platform, and comply with anti-money laundering legislation (Law No. 9.613/1998);
• Customer support: answer questions, resolve complaints, and keep a record of support interactions;
• Transactional communications: send deposit, withdrawal, and bet confirmations, security alerts, and notifications about active promotions on your account;
• Security and fraud prevention: monitor suspicious activity, detect unauthorized access, and prevent misuse of the platform;
• Service improvement: analyze aggregated usage patterns (with no individual identification) to improve the platform experience;
• Legal and regulatory compliance: comply with obligations imposed by laws, regulations, and orders from competent authorities.

A 11qp does not use personal data to sell to third parties, to build behavioral profiles sold to external advertisers, or for any purpose not stated in this Policy.

Every personal data processing operation carried out by the 11qp has a defined legal basis under art. 7 of the LGPD. The bases used are:

• Contract performance (art. 7, V): processing required to perform the platform usage agreement entered into at registration — including bet processing, deposits, withdrawals, and account management;
• Legal obligation (art. 7, II): processing required to meet legal obligations, such as those imposed by anti-money laundering legislation, betting sector regulations, and tax requirements;
• Legitimate interest (art. 7, IX): processing carried out for fraud prevention, platform security, and service improvement, always balanced against the interests and rights of data subjects;
• Consent (art. 7, I): used to send marketing communications and optional promotions — you can withdraw your consent to marketing communications at any time in your account settings.

A 11qp may share personal data with the following categories of third parties, always for a legitimate purpose and under the conditions described:

• Payment providers: payment gateways and financial institutions involved in processing deposits and withdrawals via Pix, boleto bancário, credit card, and digital wallets such as Mercado Pago and PicPay. These providers receive only the data strictly necessary to complete the transaction;
• Game providers: studios such as Pragmatic Play, Evolution Gaming, and others that operate the games available on the platform may receive technical session data required for the games to function. This data does not include complete financial information;
• Identity verification services: certified KYC platforms that assist with document verification and fraud prevention;
• Authorities and regulatory bodies: when required by law, court order, or a competent regulatory authority — such as the Ministry of Finance, the Central Bank of Brazil, or law enforcement agencies in money laundering investigations;
• IT infrastructure providers: cloud hosting and cybersecurity services, engaged under contractual confidentiality obligations and compliance with the LGPD.

A 11qp adopts technical and organizational measures to protect users' personal data against unauthorized access, loss, alteration, improper disclosure, or destruction. The main security measures in place include:

• Encryption in transit: all communication between the user's device and the servers of 11qp is protected by TLS protocol with 256-bit encryption (SSL), the same standard used by Brazilian banks and financial institutions;
• Encryption at rest: sensitive data stored on our servers is encrypted, including documents submitted during the KYC process;
• Access control: only staff with a legitimate need may access personal data, subject to strong authentication and access log recording;
• Two-Factor Authentication: available to all users in the account dashboard — strongly recommended as an additional layer of protection;
• Continuous monitoring: intrusion detection systems and suspicious activity monitoring operate 24 hours a day;
• Security testing: the platform undergoes periodic security assessments, including penetration testing conducted by specialized teams.

In the event of a security incident that may affect users' personal data, the 11qp will notify the National Data Protection Authority (ANPD) and the affected data subjects within the timeframes established by the LGPD, providing details on the nature of the incident, the data involved, and the measures taken to mitigate it.

A 11qp retains personal data only for as long as necessary to fulfill the purposes for which it was collected, or for the period required by law. General retention periods are:

• Registration and KYC data: retained while the account is active and for a minimum of 5 years after closure, in accordance with anti-money laundering legislation (Law No. 9,613/1998);
• Financial transaction history: retained for a minimum of 5 years, in accordance with tax and regulatory obligations;
• Betting and game history: retained for 2 years after the last account activity;
• Security and access logs: retained for 6 months, unless required for incident investigation;
• Support communications: retained for 2 years for quality control purposes and dispute resolution;
• Non-essential cookie data: expire as indicated in the Cookies section of this Policy.

Once applicable retention periods expire, data is securely deleted or anonymized so it can no longer be linked to an identifiable individual.

The LGPD grants the data subject — that is, you — a set of rights regarding your personal data processed by 11qp. See below for the available rights and how to exercise them:

A 11qp uses cookies and similar technologies to ensure the platform functions correctly, personalize the user experience, and analyze aggregate service usage. The types of cookies used are:

• Essential cookies: required for the platform's basic operation — authentication, game session management, and security. They cannot be disabled without affecting the service's functionality;
• Functional cookies: store user preferences such as language, display settings, and interface options. They improve the experience without being strictly necessary;
• Analytical cookies: collect aggregated, anonymous data about how users navigate the platform, helping identify areas for experience improvement. No individually identifiable data is processed by these cookies;
• Security cookies: detect suspicious behavior, prevent fraud, and protect the integrity of gaming sessions and financial transactions.

A 11qp does not use third-party cookies for behavioral advertising on other platforms. You can manage non-essential cookie preferences in your browser settings. Disabling essential cookies may impair critical platform functions, including the login process and bet placement.

The services of 11qp are intended exclusively for individuals aged 18 and over. The platform does not knowingly collect personal data from minors.

If you believe a minor under 18 has created an account or had data collected by the 11qp, please contact us immediately at privacidade@11qp.click. We take these matters with the utmost seriousness: the account will be closed, the data will be deleted, and any deposited balance will be refunded to the legal guardian after verification.

Some of the services used by 11qp — such as cloud infrastructure providers, game studios, and security analytics tools — may involve the storage or processing of data on servers located outside Brazil.

When such a transfer takes place, the 11qp ensures that:

• The destination country provides an adequate level of data protection, as assessed by the ANPD, or;
• Specific contractual clauses are in place that impose on the recipient obligations equivalent to those under the LGPD, or;
• Processing is necessary to perform the agreement entered into with the data subject (such as game processing by internationally certified providers).

The main countries where data may be processed include members of the European Economic Area (with recognized adequacy) and the United States, under approved standard contractual clauses. You may request information about the specific international transfers involving your data by emailing privacidade@11qp.click.

A 11qp may update this Privacy Policy periodically to reflect changes in services, applicable Brazilian legislation, or data processing practices.

Significant changes — those that reduce your rights or expand the scope of data processing — will be communicated at least 7 days in advance by email to the address registered on your account. The date of the last update always appears at the top of this page.

Continued use of the platform after changes take effect constitutes acceptance of the updated Policy. If you do not agree with the changes, you may close your account and request data deletion by emailing privacidade@11qp.click before the effective date.

For any questions regarding the processing of your personal data, the exercise of your rights as a data subject, or this Privacy Policy, please contact the Data Protection Officer of 11qp:

• DPO email: privacidade@11qp.click
• General support: suporte@11qp.click
• Live chat: available 24 hours a day through the account dashboard on the platform

Requests related to personal data will be responded to within 15 business days of receiving the complete request, as required by the LGPD. In cases of high complexity, this period may be extended by an equal amount of time, with prior notice to the data subject.

If you are not satisfied with the response from the 11qp to the exercise of your rights, you may file a complaint with the National Data Protection Authority (ANPD), the federal body responsible for overseeing compliance with the LGPD in Brazil.