111xx Privacy Policy

1 Introduction

111xx ("we", "us", "our") is committed to protecting the privacy and personal data of every player who registers and participates on the 111xx online casino and sports betting platform, accessible at 111xx.org. This Privacy Policy sets out in clear, plain language exactly what personal information 111xx collects, why we collect it, how we use and store it, with whom we share it, and what rights you hold as an individual over your own data.

This Privacy Policy applies to all players based in Pakistan as well as any other jurisdiction in which 111xx operates. It covers personal data collected through the 111xx website, mobile-optimised platform, customer support channels, and any promotional or affiliate communications sent by or on behalf of 111xx.

This Privacy Policy should be read alongside the 111xx Terms & Conditions and Responsible Gaming Policy, both of which are published on the platform and are incorporated by reference into this document.

2 Data Controller

For the purposes of applicable data protection law, 111xx is the Data Controller in respect of all personal data collected from players via the 111xx platform. As Data Controller, 111xx determines the purposes for which personal data is processed and the manner in which it is processed.

If you have any questions, concerns, or requests relating to the personal data that 111xx holds about you, you may contact our data protection team directly. Contact details are provided in Clause 17 of this Privacy Policy. 111xx will acknowledge all data-related enquiries within five (5) business days and respond in full within thirty (30) calendar days of receipt.

3 Data We Collect

111xx collects the following categories of personal data from players, in line with our obligations under our international gaming licence and applicable data protection standards:

111xx does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information, except where health-related information is voluntarily provided in the context of a responsible gaming self-exclusion or cool-off request. Any such data is handled with the highest level of confidentiality and used solely for the purpose for which it was provided.

4 How We Collect Your Data

111xx collects personal data through the following channels and methods:

• Direct collection: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting customer support, or participating in a promotion.
• Automated collection: Technical and usage data collected automatically when you access and use the 111xx platform, including via cookies, server logs, and analytics tools. See Clause 11 for full cookie details.
• Third-party sources: Identity and fraud verification data received from KYC service providers, payment verification data received from JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank, and fraud prevention data received from industry-standard fraud detection agencies.
• Publicly available sources: In limited circumstances where required for fraud prevention or regulatory compliance, 111xx may cross-reference publicly available information against the data you have provided.

111xx does not purchase personal data from third-party data brokers or marketing list providers. All data we hold about you is either provided directly by you or collected automatically in the course of your use of the platform.

5 Legal Basis for Processing

111xx processes your personal data on one or more of the following legal bases, depending on the nature and purpose of the processing activity:

• Contractual necessity: Processing required to perform the contract between you and 111xx — i.e., to operate your account, process deposits and withdrawals in PKR, and deliver the gaming services you have requested.
• Legal obligation: Processing required to comply with our obligations under our international gaming licence, including KYC verification, anti-money laundering checks, and responsible gaming requirements.
• Legitimate interests: Processing necessary for 111xx's legitimate business interests, including fraud detection and prevention, platform security, and service improvement — provided those interests are not overridden by your rights and interests.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent — in particular, for the sending of marketing communications and the placement of non-essential cookies. You may withdraw consent at any time without detriment.

6 How We Use Your Data

111xx uses the personal data it collects for the following specific purposes:

• Creating, verifying, and managing your 111xx player account, including processing your registration and KYC documentation.
• Processing deposits and withdrawals in PKR via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and bank transfer.
• Delivering, personalising, and improving the casino games, slot titles, live dealer tables, and PSL cricket betting markets available on the platform.
• Administering bonuses, free spins, and promotional offers, including verifying eligibility and tracking wagering requirement completion.
• Complying with our legal obligations under our international gaming licence, including age verification (21+ requirement), identity verification, anti-money laundering screening, and responsible gaming monitoring.
• Detecting, investigating, and preventing fraud, account abuse, bonus abuse, money laundering, and any other conduct that violates the 111xx Terms & Conditions.
• Providing customer support via live chat and email, maintaining support ticket history, and resolving complaints.
• Sending transactional communications such as deposit confirmations, withdrawal notifications, and security alerts.
• Sending marketing communications, including promotional offers, new game announcements, and PSL betting previews — only where you have opted in to receive such communications.
• Conducting analytics and platform performance monitoring to improve the player experience for users in Karachi, Lahore, Islamabad, Faisalabad, and across Pakistan.

7 Marketing Communications

111xx may send you marketing communications by email, SMS, or in-platform notification regarding 111xx promotions, new game releases, PSL cricket betting offers, slot tournaments, and other platform news — but only where you have given your explicit consent to receive such communications at the time of registration or subsequently via your account settings.

You may withdraw your consent to receive marketing communications at any time, at no cost, and with no effect on your ability to continue using the 111xx platform. To opt out, you may:

• Use the unsubscribe link included in every marketing email sent by 111xx.
• Update your marketing preferences directly within your 111xx account dashboard under Communication Settings.
• Contact the 111xx support team via live chat or by emailing [email protected] (plain text — not a link) and requesting removal from all marketing lists.

Opting out of marketing communications does not affect the delivery of transactional messages, which are required for the operation of your account and cannot be switched off while your account remains active.

8 Sharing Your Data

111xx does not sell, rent, or trade your personal data to any third party for their own marketing or commercial purposes. Your personal data may be shared only in the following limited and controlled circumstances:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other authorised payment service providers, solely to process your deposits and withdrawals in PKR.
• Identity verification providers: Third-party KYC and age verification service providers who verify the authenticity of the documents you submit as part of the 111xx registration and verification process.
• Fraud prevention agencies: Industry-standard fraud detection and prevention services that help 111xx identify and block fraudulent account activity, money laundering, and bonus abuse.
• Regulatory authorities: Gaming regulators, financial intelligence units, and law enforcement agencies where disclosure is required by applicable law or by the conditions of the 111xx international gaming licence.
• IT and platform service providers: Hosting, cloud infrastructure, and security service providers who process personal data on behalf of 111xx solely in accordance with 111xx's documented instructions and under binding data processing agreements.
• Professional advisers: Legal, financial, and compliance advisers where disclosure is necessary for the conduct of 111xx's legitimate business operations, subject to confidentiality obligations.

All third parties with whom 111xx shares personal data are required to handle that data in accordance with applicable data protection law and are prohibited from using it for any purpose other than the specific purpose for which it was shared.

9 International Data Transfers

111xx operates under an international gaming licence and uses service providers located in multiple jurisdictions. As a result, your personal data may be transferred to and processed in countries outside Pakistan. Where such international transfers take place, 111xx ensures that appropriate safeguards are in place to protect your personal data, including:

• Transfers to countries with an adequate level of data protection as recognised by relevant data protection authorities.
• Use of standard contractual clauses or equivalent binding transfer mechanisms with all international data processors.
• Contractual requirements that international recipients apply data protection standards no less protective than those applied by 111xx itself.

If you would like further information about the specific safeguards applied to any particular international data transfer, please contact our data protection team at the address provided in Clause 17.

10 Data Retention

111xx retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, to comply with our legal and regulatory obligations, or to resolve disputes and enforce our agreements. Specific retention periods are as follows:

• Active account data: Retained for the full duration of your active 111xx account relationship.
• Account and transaction records: Retained for a minimum of five (5) years following account closure, in accordance with our obligations under our international gaming licence and applicable anti-money laundering regulations.
• KYC and identity verification documents: Retained for a minimum of five (5) years following the completion of the verification process or account closure, whichever is later.
• Customer support records: Retained for three (3) years following the resolution of the support interaction, to facilitate resolution of any follow-up queries or disputes.
• Marketing preference records: Retained indefinitely as a record of your consent or opt-out status, to prevent inadvertent re-subscription to marketing communications.
• Technical and log data: Retained for up to twelve (12) months for security monitoring and fraud detection purposes.

Following the expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 111xx's internal data destruction procedures.

11 Cookies & Tracking Technologies

111xx uses cookies and similar tracking technologies on the 111xx platform to ensure the platform functions correctly, to remember your preferences, and to collect analytics data that helps us improve the player experience. The categories of cookies used by 111xx are as follows:

• Strictly necessary cookies: Essential for the platform to function. These include session cookies that keep you logged in during a browsing session and security cookies that protect your account. These cookies cannot be disabled.
• Functional cookies: Remember your preferences such as language settings, preferred deposit method, and responsible gaming tool settings. Disabling these cookies may affect platform functionality.
• Analytics cookies: Collect aggregated, anonymised data about how players interact with the 111xx platform, which pages are most visited, and where technical errors occur. This data is used solely to improve platform performance.
• Marketing cookies: Used to deliver personalised promotional content relevant to your activity on the platform — for example, highlighting a PSL cricket betting offer to a player who frequently uses the sportsbook. These cookies are only placed with your consent.

You can manage your cookie preferences at any time via the cookie settings panel accessible at the bottom of the 111xx platform, or by adjusting the cookie settings in your browser. Please note that disabling strictly necessary cookies will prevent you from using the platform.

12 Your Privacy Rights

As a 111xx player, you hold the following rights in respect of your personal data. These rights may be exercised by contacting the 111xx data protection team as described in Clause 17:

• Right of access: You have the right to request a copy of all personal data that 111xx holds about you, together with information about how it is being processed.
• Right to rectification: You have the right to request correction of any inaccurate or incomplete personal data held by 111xx. You may also update basic account information directly via your account dashboard.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent, or where 111xx has no overriding legitimate grounds for continued processing. This right is subject to 111xx's legal and regulatory data retention obligations.
• Right to restrict processing: You have the right to request that 111xx restricts the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or where you have objected to processing pending verification of legitimate grounds.
• Right to data portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to request that it be transmitted directly to another controller, where technically feasible.
• Right to object: You have the right to object at any time to the processing of your personal data based on legitimate interests, including profiling for direct marketing purposes.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

13 Data Security

111xx applies appropriate technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or alteration. These measures include:

• TLS/SSL encryption for all data transmitted between your device and the 111xx platform.
• Encryption of sensitive stored data, including financial data and identity verification documents, at rest.
• Strict access controls ensuring that only authorised 111xx personnel with a legitimate business need can access personal data, and only to the extent necessary for their role.
• Regular internal and third-party security audits and penetration testing of the 111xx platform infrastructure.
• Secure destruction protocols for personal data that has reached the end of its applicable retention period.
• Incident response procedures to detect, assess, and respond to personal data breaches in a timely manner.

In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, 111xx will notify you without undue delay via the contact details associated with your account, providing details of the nature of the breach, the data affected, and the steps 111xx is taking in response.

While 111xx applies industry-standard security measures, no online platform can guarantee absolute security against all possible threats. Players are strongly encouraged to use a strong, unique password for their 111xx account and to enable any additional security features available on the platform.

14 Children & Minors

The 111xx platform is strictly intended for adults aged 21 years and over. 111xx does not knowingly collect personal data from any individual under the age of 21. Age verification is conducted as a mandatory step in the 111xx registration and KYC process.

111xx supports parental control tools and internet filtering software for households with minors. We strongly encourage parents and guardians in Pakistan to install appropriate content filtering software to prevent underage access to online gambling platforms.

15 Third-Party Links

The 111xx platform may contain links to third-party websites or services, for example in the context of our game providers or responsible gaming resources. 111xx is not responsible for the privacy practices or content of any third-party website or service. This Privacy Policy applies solely to data collected by and on behalf of 111xx via the 111xx platform.

We recommend that you review the privacy policy of any third-party website you visit via a link from the 111xx platform, as their data collection and use practices may differ significantly from those of 111xx.

16 Policy Updates

111xx reserves the right to update this Privacy Policy at any time to reflect changes in applicable data protection law, our business operations, or our data processing practices. Where any update is material — meaning it significantly affects how we collect, use, or share your personal data — 111xx will notify you via the email address registered to your 111xx account, or via a prominent in-platform notification, at least fourteen (14) days before the updated Privacy Policy takes effect.

For minor or administrative updates, 111 xx will update the "Last Updated" date at the top of this page without sending individual notifications. We encourage all players to review this Privacy Policy periodically to stay informed of how 111xx protects their personal data.

Your continued use of the 111xx platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not accept the updated Privacy Policy, you must cease using the platform and may request account closure by contacting the 111xx support team.

17 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the personal data that 111xx holds about you, please contact our data protection team using the details below. All privacy-related correspondence should be clearly marked "Data Protection Enquiry" to ensure prompt routing to the correct team.

111xx takes all privacy-related communications seriously. If you are not satisfied with the response you receive from our data protection team, you have the right to escalate your complaint to the relevant data protection supervisory authority or to the gaming regulatory authority responsible for the 111xx international gaming licence.