Privacy Policy
111xx Data Commitment

1 Introduction

111xx ("the Company," "we," "us," "our") is the operator of the online casino and sports betting platform accessible at 111xx.net. We are committed to safeguarding the privacy and personal data of all individuals who interact with our platform, including registered players, account applicants, and website visitors.

This Privacy Policy has been prepared in accordance with internationally recognised data protection principles and the obligations imposed on us by our operating licence. It sets out the legal basis on which we process your personal data, the purposes for which it is used, how long we retain it, and the rights you hold in relation to the information we hold about you.

We do not sell your personal data to third parties for marketing purposes. We do not share your data with advertisers or data brokers. Your information is collected solely to operate the 111xx platform safely, legally, and efficiently — and to provide you with the best possible gaming experience in Pakistan.

2 Data We Collect

When you register for a 111xx account, use our platform, or contact our support team, we collect a range of personal data necessary to provide our services. The categories of data we collect are outlined in the table below:

We do not collect sensitive personal data such as biometric data, racial or ethnic origin, religious beliefs, or health information unless specifically required by applicable law or our regulatory obligations (for example, in cases involving problem gambling support).

3 How We Collect Data

111xx collects personal data through a number of channels, all of which are disclosed transparently to our players:

• Direct interactions: Data you provide when you fill in the registration form, complete KYC verification, update your profile, make deposits or withdrawals, or contact our support team via email or live chat.
• Automated technologies: When you access 111xx.net, our servers automatically record technical data including your IP address, browser, device identifiers, and session activity. This is standard practice across all modern web platforms and is required for security and fraud prevention.
• Payment processors: When you deposit or withdraw funds via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, or Mastercard, our payment processing partners may share transaction confirmation data with us to reconcile your account balance.
• KYC and identity verification providers: Where a third-party identity verification service is used to confirm your identity documents, the outcome of that verification is shared with 111xx as part of our regulatory compliance obligations.
• Cookies and similar technologies: Our platform uses cookies to maintain your session, remember your preferences, and analyse platform performance. See Section 7 for full details of our cookie practices.

4 Purpose of Processing

111xx processes your personal data for the following clearly defined purposes. We do not use your data for any purpose that is incompatible with these stated uses:

• Account management: To register, maintain, and administer your 111xx account, including processing deposits and withdrawals in PKR, applying bonuses, and updating your account preferences.
• Identity verification (KYC): To verify your identity, age (21+ requirement), and address as required by our regulatory obligations. Age verification is mandatory and non-negotiable.
• Security and fraud prevention: To detect and prevent fraudulent activity, money laundering, underage access, multi-accounting, and other prohibited conduct as described in our Terms and Conditions.
• Service delivery: To provide you with access to casino games, sports betting markets, live dealer games, and all other features of the 111xx platform.
• Customer support: To respond to your enquiries, resolve complaints, and provide technical assistance when you contact our 24/7 support team.
• Responsible gaming: To monitor your gaming activity for signs of problem gambling behaviour, to action responsible gaming tool requests (self-exclusion, deposit limits, cooling-off periods), and to fulfil our duty of care obligations.
• Legal and regulatory compliance: To fulfil our obligations under applicable gaming licensing requirements, anti-money laundering legislation, and any directives issued by relevant regulatory or law enforcement bodies.
• Platform improvement: To analyse aggregated, anonymised usage data that helps us improve the 111xx platform, fix bugs, and enhance the player experience for users across Pakistan.

5 Legal Basis for Processing

Every instance of personal data processing at 111xx is grounded in one of the following recognised legal bases under internationally applicable data protection standards:

• Contract performance: Processing that is necessary to fulfil our contractual obligations to you as a registered 111xx player — including account operation, game access, and payment processing.
• Legal obligation: Processing required by law or regulatory directive, including KYC, AML (anti-money laundering) checks, and responsible gaming monitoring.
• Legitimate interests: Processing necessary for our legitimate business interests where those interests are not overridden by your rights — including security monitoring, fraud prevention, and platform analytics. We conduct a balancing assessment before relying on this basis.
• Consent: Where we rely on your consent for a specific processing activity (such as receiving promotional communications), you have the right to withdraw that consent at any time without affecting the lawfulness of processing prior to withdrawal. To withdraw consent, contact us at [email protected].

6 Data Sharing & Disclosure

111xx does not sell, rent, or trade your personal data to any third party. We share personal data only in the limited circumstances described below, and only to the extent strictly necessary:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa, and Mastercard receive transaction data necessary to process your deposits and withdrawals. These providers are bound by their own data protection obligations and do not receive any data beyond what is required to process your payment.
• Identity verification providers: Third-party KYC and age-verification services receive identity document data submitted during the verification process. Results are returned to 111xx and the underlying documents are not retained by us beyond the verification period.
• Regulatory and law enforcement bodies: We are required by law to disclose certain player data to relevant regulatory authorities and law enforcement agencies upon valid legal request. We will notify affected players where we are legally permitted to do so.
• IT and platform service providers: Hosting, security, and platform infrastructure providers may process technical data on our behalf under strict data processing agreements that prohibit any independent use of your data.
• Responsible gaming organisations: In cases of confirmed self-exclusion or escalated problem gambling concerns, limited data may be shared with licensed responsible gaming support organisations as required by our operating obligations.

7 Cookies & Tracking Technologies

111xx uses cookies and similar tracking technologies to maintain platform functionality, protect your session, and analyse how players interact with the site. All cookies used on 111xx.net fall into one of the following categories:

You may adjust cookie preferences through your browser settings at any time. Note that disabling strictly necessary cookies will prevent you from logging into your 111xx account. Disabling analytics or functional cookies will not affect your ability to play but may reduce the quality of your experience.

8 Data Retention

111xx retains your personal data for as long as is necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying legal, regulatory, accounting, or reporting obligations.

• Active account data: Retained for the full duration your 111xx account is active and for a minimum of five (5) years after account closure, as required by anti-money laundering legislation.
• KYC and identity documents: Retained for a minimum of five (5) years from the date of verification, in accordance with our regulatory obligations.
• Transaction records: Full transaction histories including deposits, withdrawals, bets, and bonus activations are retained for a minimum of five (5) years.
• Support communications: Support tickets, email correspondence, and chat transcripts are retained for three (3) years from the date of last interaction.
• Responsible gaming records: Self-exclusion records, deposit limit histories, and problem gambling support interactions are retained indefinitely where required by our responsible gaming obligations.
• Technical and analytics data: Anonymised analytics data may be retained for up to two (2) years. Raw technical logs containing IP addresses are retained for up to twelve (12) months.

When your data is no longer required for any of the above purposes, it is securely deleted or anonymised in accordance with our internal data disposal procedures.

9 Data Security

111xx takes the security of your personal data seriously and implements a range of technical and organisational measures designed to protect it against unauthorised access, accidental loss, destruction, or disclosure:

• 256-bit SSL/TLS encryption: All data transmitted between your device and the 111xx platform is encrypted using industry-standard TLS protocols. You will always see a padlock indicator in your browser when connected to 111xx.net.
• Access controls: Personal data is accessible only to authorised 111xx staff who require it to perform their specific job functions. Access is governed by role-based permissions and reviewed regularly.
• Password hashing: Your account password is stored as a one-way cryptographic hash. 111xx staff cannot read your password in plain text under any circumstances.
• Regular security audits: Our platform infrastructure is subject to periodic vulnerability assessments and penetration testing conducted by qualified security professionals.
• Two-factor authentication: Players are encouraged to enable two-factor authentication on their 111xx accounts as an additional layer of protection against unauthorised access.

10 Your Data Rights

As a player on the 111xx platform, you hold the following rights in relation to the personal data we hold about you. To exercise any of these rights, please contact our data team at [email protected] with your full name, registered email address, and a clear description of your request.

• Right of access: You have the right to request a copy of all personal data 111xx holds about you. We will respond to access requests within 30 days of receipt.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. For basic profile corrections, you can update your details directly in your account settings.
• Right to erasure: In certain circumstances, you have the right to request the deletion of your personal data. Note that this right may be limited where we are required by law to retain your data (for example, AML obligations require us to retain transaction records for five years).
• Right to restriction: You have the right to request that we restrict the processing of your personal data in certain situations — for example, while a dispute about data accuracy is being resolved.
• Right to data portability: You have the right to receive a copy of your personal data in a structured, machine-readable format, and to request that it be transmitted to another controller where technically feasible.
• Right to object: You have the right to object to processing based on our legitimate interests or for direct marketing purposes. If you object to marketing communications, we will cease sending them promptly.
• Right to withdraw consent: Where our processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of prior processing.

11 Children & Minors

The 111xx platform is strictly intended for adults aged 21 years and above. We do not knowingly collect, process, or retain personal data from individuals under the age of 21.

Age verification is a mandatory step in the 111xx registration and KYC process. Any account found to belong to a person under 21 will be immediately closed, all balances will be forfeited, and the matter will be escalated in accordance with our regulatory obligations. Where deposits have been made by a minor, the Company will work with relevant authorities to ensure an appropriate resolution.

If you are a parent or guardian and believe that a minor in your care has accessed or registered on the 111xx platform, please contact us immediately at [email protected]. We will investigate and act on confirmed cases without delay.

12 Third-Party Links

The 111xx platform does not contain links to third-party websites, social media platforms, or external services beyond those strictly necessary for payment processing. Should any contextual reference to a third-party service appear on the platform, please be aware that 111xx has no control over the privacy practices of external sites and is not responsible for their content or data handling.

This Privacy Policy applies solely to data collected by 111xx through the 111xx.net platform. We strongly recommend that players review the privacy policies of any third-party payment providers they use to deposit or withdraw funds on the platform.

13 Changes to This Policy

111xx reserves the right to update or amend this Privacy Policy at any time. When material changes are made — meaning changes that significantly affect how your data is collected, used, or shared — we will notify registered players via their registered email address and publish the updated policy on this page with a revised "Last Updated" date.

Your continued use of the 111xx platform following the publication of an updated Privacy Policy constitutes your acknowledgement of the changes. If you do not agree with any updates to this policy, you should cease using the platform and may request account closure in accordance with the provisions of our Terms and Conditions.

We encourage all players to review this Privacy Policy periodically. The version published at 111xx.net/privacy-policy is always the current, binding version.

14 Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy or to the personal data 111xx holds about you, please contact our Data and Privacy team using the details below. We are here to help and will respond to all privacy-related enquiries promptly and professionally.

• Email: [email protected]
• Subject Line: Please include "Privacy Request" or "Data Rights" in the subject of your email so it is routed to the correct team.
• Support Hours: 24 hours a day, 7 days a week, 365 days a year
• Response Time: Acknowledgement within 5 business days; substantive response within 30 calendar days

For matters related to responsible gaming — including self-exclusion, deposit limit requests, or problem gambling support — please visit our dedicated Responsible Gaming page.