This privacy policy forms part of our Website's Terms of Service, by accepting the Terms of Service and the Privacy Policy on the registration page, you consent to provide sensitive personal data or personal information and are aware of the purpose of sharing such information.

The following policy applies to your use of JP Funware Private Limited's (hereinafter referred as "JP Funware" or "we" or "us" "our") website and/or Services, and covers information collected in connection with your access to and use of our website and/or Services.

1. Policy Objective

We respect your privacy and assures you that any information provided by you to JP Funware is protected and will be dealt with according to this Policy and the applicable laws. To avail the services offered on www.XL11.in and application(s) (hereinafter singly referred as the "Platform" and collectively referred as "Platforms"), you may have to provide certain information to us. This Policy provides the procedure followed by JP Funware to gather, uses, store, discloses and manages users' personal data. JP Funware only collects personal data for the purpose of verifying user accounts, maintaining the accounts of the users, completing transactions of the users, for analyzing user behaviour and other related requirements.

2. What Information Do We Collect

We collect or receive information you provide when you use, register on our Platform, access your account, communicate with us, answer our surveys, upload content, or otherwise use our Services. We collect the following information about you:

2.1 Sensitive Personal Data:

• Account password
• Financial information such as Bank account or credit card or debit card or other payment instrument details

2.2 Other Personal Information:

• Name
• Date of birth
• Telephone number
• Postal/Contact address
• PAN number (as applicable)
• The IP address of your computer, browser type and language
• The date and the time during which you accessed the site
• The address of the website which you may have used to link to any Website
• Your photograph for testimonials and other promotions
• Such other information that is defined as sensitive personal data or information in law

3. How We Use Your Information

We may use information about you for number of purposes, including:

a. For Providing Our Services:

All users of JP Funware consent to the use of Sensitive Personal Data and Other Personal Information for verifying user accounts, maintaining the accounts of the users, completing transactions of the users, for analyzing user behavior and other related requirements.

b. Providing, Improving, and Developing our Services:

We may also use software applications for Platform traffic analysis, to gather related statistics, for advertising and for determining the efficacy and popularity of JP Funware among others.

c. Marketing:

Photographs provided as a part of testimonials and promotions by you specifically for marketing purposes give us irrevocable rights to use it for that purpose. We retain the discretion to delete or not use it any further, subject to the User Control of Personal Data and Information clause of this Privacy Policy.

Presently, JP Funware also displays advertising and remarketing through Google Analytics, wherein third party vendors including google, display our ads on sites across the internet and use first party cookies and third party cookies together to inform, optimize and serve ads based on visits of visitors to our website. Our visitors are free to opt out of Google Analytics for display advertising and customize google display network ads using ads preference manager.

d. Sharing Data:

We may be required to share information received from you, with our employees, contracts, agents and regulatory authority(ies). We restrict access of personal information to these abovementioned parties and only allow access to your data on a need-to-know basis in order to process it for providing our Services or otherwise if requested in case of regulatory authority(ies).

e. Cookies:

What is a Cookie: A cookie is a small text file that uniquely identifies your browser when you visit a website. Cookies allow us to retain your preferences and account settings, among other things.

You understand and accept that when you visit our Platform(s), cookies may be left in your computer. These cookies assigned by the servers of JP Funware may be used to personalize your experience on the Platform(s). Additionally, cookies may also be used for authentication, game management, data analysis and security purposes.

f. Email Communication:

When you register your email address with JP Funware, you agree to receive email communication from JP Funware, entities specifically authorized by JP Funware and other users. You also agree and acknowledge that when you use our referral program for referring someone, JP Funware will send emails to such a person referred by you on your behalf and the email headers will carry your email address as the address from which such emails are sent.

4. Data Security

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage and processing practices and security measures. We also undertake measures including appropriate encryption and physical security measures to guard against unauthorized access to systems where we store personal data. JP Funware has a comprehensive information security program and information security policies which contain managerial, technical, operational and physical security control measures adopted by JP Funware for the protection of Sensitive Personal Date and Other Personal Information.

5. User Control on Personal Data or Information

You have control over your data in the following ways:

a. Updating Your Information

You shall be entitled to update the information provided by you by contacting us at support@XL11.in. Your information shall be updated subject to reasonable checks and confirmation by JP Funware.

b. Withdrawal of Consent

Users are entitled to withdraw consent for use of their Sensitive Personal Data or Other Personal Information by emailing a specific request to support@XL11.in, as the case may be. Withdrawal of consent of all or any part of Sensitive Personal Data and Other Personal Information may result in immediate withdrawal of any right to avail the services provided by JP Funware.

c. Deletion of Data

Users may raise a request for deletion of any or all personal data or information stored with JP Funware by following the Other details tab in My account section after login to your account. Once your request for deletion has been received and confirmed, JP Funware will delete your personal data or information from our records.

6. Data Retention Policy

JP Funware shall retain the information provided by the users for such period of time as is required to fulfil the purposes for which such information is collected, as outlined in this Privacy Policy, subject to such longer time periods of retention as may be required under any applicable laws.

7. Exclusions

JP Funware may share Sensitive Personal Data and Other Personal Information if sharing of such information is necessary:

• to comply with legal processes or governmental request;
• to enforce the Terms of Service and this Privacy Policy;
• for prevention of fraud;
• for issues involving information security, or
• to protect:
  • your rights;
  • rights of JP Funware; and
  • rights of the general public.

8. Limitation of Liability

JP Funware confirms that this Privacy Policy is only a description of its operation regarding user information. This Policy is not intended to and does not create any legal rights in your favour or in the favour of any other person. JP Funware reserves the right to change this Policy at any time without giving you prior notice. The liability of JP Funware shall be limited to removal of Sensitive Personal Data from the system of the Platforms and removal of personally identifiable elements of the Other Personal Information. Notwithstanding anything to the contrary contained in this Policy and elsewhere, the aggregate liability of JP Funware for all claims for damages pursuant to provisions of services on the Platforms, including claims in respect to the violation of this Policy, shall be limited to the aggregate maximum amount of liability as provided in the Terms of Service.

We, at XL11, believe in a high level of user protection and responsible gaming and prioritize this over other interests. We actively promote responsible game play for our users believing that gaming is and should be done purely for entertainment. We take our users' well-being very seriously and in order to ensure their safety, this Responsible Gaming Policy describes the Company's commitments, and your responsibility to promote responsible gaming practices and minimize the negative effects of excessive gaming.

Guidelines for Safe Gaming

If you choose to play on our Platform, there are some general guidelines that can help make your playing experience safer, and avoid risk that you may indulge in excessive gaming:

• Games may be habit-forming or may involve an element of financial risk. Please play responsibly.
• Do not chase your losses.
• Set deposit limits for each day/month.
• Do not play with the sole intention to make money or to escape problems. Play in moderation and only for entertainment.
• Keep track of the time and monitor the amount of money you spend.
• Have a disciplined strategy and play within your bankroll. Add money to the XL11 Wallet only with money that you can afford to spend i.e. set a specific spending capacity for gaming.
• Never add money to the XL11 Wallet with money that you need for important or essential things.
• Pre-plan your purchases and the time you will spend playing on XL11 and stick to that limit, regardless of your performance.
• Don't play when you are upset, tired, or depressed. It is difficult to make informed choices when you are feeling down. Play games only for utilizing and enhancing your skills.
• Balance your gameplay duration with other activities that might interest you.
• Do not borrow money in order to make purchases on XL11.
• Avoid using all of the monies in the XL11 Wallet in a single game or session.
• Only participate in games that are commensurate with your competence level and financial capabilities. Do not get tempted to participate in high stakes tables despite winning consistently.