111cx Privacy Policy

§01 Introduction & Scope

This Privacy Policy ("Policy") describes how 111cx ("we", "us", "our", "the Platform") collects, processes, stores, and shares personal data relating to individuals ("you", "Player", "User") who access or use the 111cx online gaming platform, including its website at 111cx.pro, any associated mobile-optimised interfaces, customer support channels, and promotional communications.

This Policy applies to all personal data processed by 111cx in connection with the operation of the platform, regardless of whether the data was collected online, via email correspondence, through our live support system, or during the KYC verification process. It covers data relating to registered players, prospective players who have initiated but not completed registration, and general visitors to the 111cx website.

This Policy should be read alongside our Terms & Conditions and Responsible Gaming policy, all of which form part of the contractual framework governing your use of 111cx.

§02 Data We Collect

111cx collects personal data across several categories, depending on your level of interaction with the platform. The table below provides a structured overview of the categories of data we collect and examples of the specific data points within each category.

We do not collect sensitive personal data such as biometric data (other than CNIC photographs required for KYC), health information, religious beliefs, or political opinions unless specifically required by a legal or regulatory obligation. We do not collect full payment card (debit/credit) numbers.

§03 How We Collect Data

3.1 Directly From You

The majority of personal data 111cx holds about you is provided directly by you during the following interactions:

• Completing the account registration form on 111cx;
• Submitting KYC documentation (CNIC, proof of address, source-of-funds documents);
• Initiating or completing a deposit or withdrawal transaction;
• Contacting 111cx via live chat, email, or any other support channel;
• Participating in surveys, promotions, or feedback requests organised by 111cx;
• Updating your account profile or communication preferences.

3.2 Automatically Collected

When you access the 111cx website or platform interface, we automatically collect certain technical data through cookies, server logs, and similar technologies. This includes your IP address, device identifiers, browser type and version, operating system, referral URL, pages visited, session duration, and in-platform click-path data. This data is used for platform security, fraud detection, performance analytics, and responsible gaming monitoring.

3.3 From Third Parties

In certain circumstances, 111cx receives personal data about you from trusted third-party sources, including:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and SadaPay may confirm transaction status, wallet ownership, or account holder name as part of payment processing and fraud prevention workflows;
• KYC Verification Providers: Third-party identity verification services may cross-reference CNIC data against national databases to confirm identity;
• Anti-Fraud & AML Partners: Industry-standard fraud detection platforms may flag IP addresses, device fingerprints, or payment patterns associated with known fraudulent activity.

§04 Legal Basis for Processing

111cx processes your personal data under one or more of the following legal bases, depending on the specific purpose of processing:

• Contractual Necessity: Processing required to perform the contract between you and 111cx — including account creation, deposit processing, game delivery, withdrawal settlement, and KYC verification — is carried out on the basis that it is necessary to fulfil our contractual obligations to you.
• Legal Obligation: Certain processing activities are mandated by applicable law, including anti-money laundering (AML) record-keeping requirements, gaming license compliance obligations, and tax reporting requirements. 111cx is legally required to retain specific records regardless of player consent status.
• Legitimate Interests: 111cx processes some data on the basis of its legitimate interests as an online gaming operator — specifically, fraud prevention, platform security, responsible gaming enforcement, internal analytics, and service improvement. These interests are weighed against your rights and will not override your fundamental privacy interests.
• Consent: Where 111cx sends you direct marketing communications (promotional emails, SMS bonuses, or special offers), we do so on the basis of your explicit opt-in consent. You may withdraw this consent at any time by updating your preferences in Account Settings or by contacting support.

§05 How We Use Your Data

111cx uses the personal data it collects for the following clearly defined purposes:

• Account Management: Creating, maintaining, and administering your 111cx player account, including login authentication, profile updates, and account security;
• Transaction Processing: Facilitating deposits in PKR via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20, and processing withdrawal requests to verified payment methods;
• Identity & Age Verification: Confirming that all players are aged 21 or over and that their identity matches the payment method used, in compliance with our licensing obligations;
• Responsible Gaming: Monitoring gameplay patterns and account behaviour to identify signs of problem gambling, applying player-requested self-exclusion or deposit limit tools, and complying with responsible gaming requirements under our international gaming license;
• Fraud Prevention & AML: Detecting and preventing fraud, money laundering, multi-accounting, bonus abuse, and other prohibited conduct as defined in our Terms & Conditions;
• Customer Support: Responding to your queries, complaints, and requests via live chat, email, and other support channels, and maintaining records of communications for quality assurance and dispute resolution;
• Marketing Communications: Sending promotional offers, reload bonuses, PSL betting promotions, and platform updates where you have provided valid consent to receive such communications;
• Platform Analytics: Understanding how players interact with 111cx features, games, and interfaces in order to improve usability, fix technical issues, and prioritise product development;
• Legal Compliance: Meeting record-keeping, reporting, and cooperation obligations under our gaming license terms and applicable international law.

§06 Data Sharing & Disclosure

111cx does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. We share your data only where it is necessary to operate the platform, comply with legal obligations, or protect the rights of 111cx and its players. The categories of third parties who may receive your data include:

6.1 Payment Service Providers

To process deposits and withdrawals, 111cx shares the minimum necessary payment and identity information with the relevant payment provider (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, or USDT TRC20 wallet services). These providers operate under their own privacy policies and are contractually restricted from using your data for any purpose beyond payment processing.

6.2 KYC & Identity Verification Partners

To verify player identity and comply with AML requirements, 111cx may share CNIC data and personal details with licensed identity verification service providers. These partners are bound by strict data processing agreements and are prohibited from using player data for any purpose beyond the scope of identity verification.

6.3 Game Software Providers

Third-party game providers whose casino games, sports data feeds, or instant game products are accessible on the 111cx platform may receive anonymised or pseudonymised session data (such as a player identifier and wager amounts) necessary to deliver and settle game outcomes. Full personal identity data is not shared with game software providers.

6.4 Legal & Regulatory Authorities

111cx will disclose personal data to competent regulatory authorities, law enforcement agencies, or courts where required to do so by applicable law, a valid legal order, or our gaming license obligations. In such cases, 111cx will disclose only the data specifically required and will, where legally permissible, notify the affected player of such disclosure.

6.5 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 111cx's business assets, personal data held by 111cx may be transferred to the acquiring entity as part of that transaction. Affected players will be notified via email prior to their data being transferred and will have the opportunity to request deletion where legally permissible.

§07 International Data Transfers

111cx is an internationally operated platform and, as a result, your personal data may be stored or processed in countries other than Pakistan. Where data is transferred outside of your country of residence, 111cx ensures that appropriate safeguards are in place to protect your data to a standard equivalent to the protections afforded under the applicable data protection framework of our gaming license jurisdiction.

Safeguards for international transfers may include standard contractual clauses, data processing agreements with data importers, or reliance on adequacy decisions where applicable. If you would like further information about the specific safeguards in place for international transfers of your data, please contact 111cx at [email protected].

§08 Data Retention

111cx retains personal data for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, or licensing obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of the active account relationship plus a minimum of 5 years following account closure, in accordance with AML record-keeping requirements;
• Financial transaction records: Retained for a minimum of 5 years from the date of the transaction, as required under applicable financial regulations;
• KYC documentation: Retained for a minimum of 5 years from the date of submission or the date of account closure, whichever is later;
• Customer support communications: Retained for 3 years from the date of the last interaction, unless the communication forms part of an active or potential legal dispute, in which case it is retained until the dispute is fully resolved;
• Gaming activity logs: Retained for 5 years to support responsible gaming obligations and dispute resolution;
• Marketing consent records: Retained for as long as you hold an active account or for 2 years following account closure, whichever is earlier.

Once the applicable retention period expires and there is no remaining legal basis for processing, your data is securely deleted or anonymised so that it can no longer be associated with you as an individual.

§09 Cookies & Tracking Technologies

9.1 What Cookies We Use

111cx uses the following categories of cookies on its platform:

• Strictly Necessary Cookies: Essential for core platform functionality, including login session management, security token storage, and shopping cart equivalents (bet slips). These cannot be disabled without breaking the platform.
• Analytical Cookies: Used to collect anonymised data about how players navigate and interact with the 111cx platform. This data informs performance improvements and UX decisions. No personally identifiable information is included in analytical cookie data.
• Functional Cookies: Store your preferences such as language settings, last-visited game category, and notification preferences to improve your platform experience across sessions.

9.2 What We Do Not Use

111cx does not deploy advertising or targeting cookies. We do not use cross-site tracking pixels, social media trackers, or third-party behavioural advertising technologies. Your 111cx browsing activity is not shared with advertising networks.

9.3 Managing Cookies

You can control and manage cookies via your browser settings at any time. Note that disabling strictly necessary cookies will impair your ability to log in and use the 111cx platform. Disabling analytical or functional cookies will not prevent you from accessing the platform but may affect personalisation features.

§10 Your Data Rights

Depending on your location and the applicable data protection framework, you may have the following rights with respect to your personal data held by 111cx:

• Right of Access: You have the right to request confirmation of whether 111cx holds personal data about you, and if so, to receive a copy of that data along with information about how it is being processed. Requests will be fulfilled within 30 days.
• Right to Rectification: If any personal data 111cx holds about you is inaccurate or incomplete, you have the right to request that it be corrected. You may also update certain information directly via your Account Settings.
• Right to Erasure ("Right to be Forgotten"): You may request that 111cx delete your personal data. This right is subject to exceptions where retention is required by law — for example, AML record-keeping obligations mean that financial transaction records must be retained for a minimum of 5 years even after account closure.
• Right to Restrict Processing: You may request that 111cx limit the way it processes your data in circumstances such as where you contest its accuracy or where processing is unlawful but you prefer restriction over deletion.
• Right to Data Portability: You have the right to receive the personal data you have provided to 111cx in a structured, commonly used, and machine-readable format, and to transmit that data to another controller where technically feasible.
• Right to Object: You have the right to object to processing of your personal data where that processing is based on legitimate interests, including profiling for responsible gaming purposes. You also have an unconditional right to object to processing for direct marketing at any time.
• Rights Related to Automated Decision-Making: Where 111cx makes automated decisions that have a significant effect on you — such as account suspension triggered by automated fraud detection — you have the right to request human review of that decision.

§11 Children & Minors

The 111cx platform is strictly intended for adults aged 21 years and over. 111cx does not knowingly collect personal data from individuals under the age of 21. If we become aware that a registered account belongs to a person under 21 years of age, we will immediately suspend the account, void any gameplay history, and securely delete all personal data associated with that account, except where retention is required by law.

If you have reason to believe that a person under 21 has registered an account on 111cx, please contact us immediately at [email protected]. 111cx takes underage gambling extremely seriously and cooperates fully with parental, guardian, or regulatory requests to identify and close underage accounts.

§12 Security Measures

111cx implements a range of technical and organisational security measures designed to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include:

• TLS encryption for all data transmitted between players and the 111cx platform;
• Encryption at rest for stored personal and financial data;
• Multi-factor authentication (MFA) for internal staff access to production systems;
• Role-based access controls limiting staff access to data on a strict need-to-know basis;
• Regular penetration testing and security audits conducted by independent third-party specialists;
• Automated threat detection and anomaly monitoring on platform infrastructure;
• Staff training on data protection obligations and secure data handling practices;
• Formal incident response procedures for detecting, containing, and notifying of data breaches.

While 111cx takes all reasonable precautions to protect your data, no online platform can guarantee absolute security. Players are encouraged to use strong, unique passwords for their 111cx accounts and to enable any available two-factor authentication options to further protect their accounts.

§13 Third-Party Services

The 111cx platform may integrate with or link to third-party services, including game software providers, payment processors, and analytical tools. These third-party services operate under their own independent privacy policies. 111cx is not responsible for the privacy practices of third-party services and recommends that you review the privacy policies of any third-party service you interact with in connection with your use of 111cx.

Where 111cx engages third-party data processors who handle personal data on our behalf, we ensure that those processors are bound by written data processing agreements that require them to process personal data only on 111cx's documented instructions, to maintain appropriate security measures, and to assist 111cx in meeting its data subject rights obligations.

§14 Policy Updates

111cx reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or our gaming license obligations. When material changes are made to this Policy, we will notify registered players via email to their registered address and display a prominent notice on the 111cx platform with a minimum of 7 days' advance notice before the updated Policy takes effect.

The "Effective Date" displayed at the top of this document indicates when the current version of this Policy came into force. Continuing to use the 111cx platform after the effective date of an updated Policy constitutes your acceptance of the changes. If you do not agree with any updated terms, you should stop using 111cx and may request account closure by contacting our support team.

We recommend that you review this Privacy Policy periodically to stay informed about how 111cx handles your personal data. Archived versions of prior policies are available upon request.

§15 Contact & Complaints

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 111cx handles your personal data, please contact us using the details below:

If you are not satisfied with the response you receive from 111cx regarding a data privacy concern, you have the right to escalate your complaint to the relevant data protection supervisory authority under the framework of the jurisdiction governing this Policy. Details of the applicable authority will be provided in our written response to your complaint.

This Privacy Policy was last updated on 1 January 2026 and supersedes all prior versions. By continuing to use 111cx after this date, you confirm your understanding of and agreement to the data practices described herein.