111cx Privacy Policy

1. Introduction

111cx is committed to protecting the privacy and personal data of every player who uses our platform. This Policy sets out in clear, honest terms what personal information we collect from you, how we use it, the legal grounds on which we process it, with whom we may share it, and how long we retain it.

We have written this Policy to be as plain and direct as possible. At 111cx, we recognise that Pakistani players trust us not just with their gaming activity but with meaningful personal information — their contact details, identity documents, and financial data. That trust is not taken lightly. Every data practice described in this Policy reflects a deliberate, considered decision about what is genuinely necessary to operate a safe, fair, and legally compliant gaming platform.

If you have questions about anything in this Policy, please do not hesitate to contact us. Our support team in available around the clock and is able to address data privacy queries in both English and Urdu.

2. Data Controller

For the purposes of applicable data protection law, 111cx is the data controller responsible for your personal data. As data controller, 111cx determines the purposes and means of processing your personal information and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

111cx operates under an international gaming licence and processes personal data in accordance with the data protection requirements applicable under that licensing jurisdiction. Where data protection law in your home jurisdiction applies in addition to or instead of the governing jurisdiction, 111cx takes reasonable steps to comply with such additional obligations.

3. Personal Data We Collect

111cx collects the following categories of personal data from our users. The specific data collected from any individual user depends on their interactions with the platform and the services they use:

4. How We Collect Your Data

111cx collects personal data through the following means:

4.1 Direct Collection

Data you provide directly to 111cx when you register an Account, complete identity verification, make deposits or withdrawal requests, contact our support team, respond to promotions, or update your Account settings. This is the primary source of the personal data we hold about you.

4.2 Automated Collection

Technical and usage data collected automatically when you visit and interact with the 111cx platform, including through cookies, web beacons, log files, and similar tracking technologies. This data is collected whether or not you are logged in to your Account.

4.3 Third-Party Sources

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

• Payment service providers such as JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank, for the purpose of processing and reconciling your transactions;
• Identity verification services used to assist with KYC compliance and fraud prevention;
• Anti-fraud and anti-money laundering screening services;
• Analytics providers used to aggregate and anonymise platform usage data.

Where 111cx receives data from third parties, it does so only to the extent necessary to fulfil our service obligations to you and our regulatory compliance requirements.

5. Legal Basis for Processing

111cx processes your personal data on one or more of the following legal grounds under applicable data protection law:

• Contractual Necessity: Processing required to perform our contract with you — including operating your Account, processing deposits and withdrawals, and delivering gaming services;
• Legal Obligation: Processing required to comply with our obligations under applicable law, including anti-money laundering requirements, gaming licence conditions, and age verification obligations;
• Legitimate Interests: Processing necessary for 111cx's legitimate business interests, such as fraud prevention, platform security, and improving our services, where those interests are not overridden by your rights and interests;
• Consent: Where processing is based on your freely given, specific, informed, and unambiguous consent — for example, for certain marketing communications. You may withdraw consent at any time by contacting [email protected].

6. How 111cx Uses Your Personal Data

111cx uses your personal data for the following purposes:

6.1 Account Management & Service Delivery

To create and maintain your 111cx Account, verify your identity, process transactions, and provide access to all gaming services on the platform, including cricket betting, live casino, slot games, Big Hammer, and Ludo Quick.

6.2 Payment Processing

To process your deposits via JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank, and to process your withdrawal requests. Financial data is shared with relevant payment service providers only to the extent necessary to complete transactions.

6.3 Identity Verification and KYC Compliance

To verify your identity, confirm your age (21+), and comply with our anti-money laundering and gaming licence obligations. KYC documentation may be shared with regulated third-party verification service providers acting on our behalf.

6.4 Fraud Prevention and Platform Security

To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, multi-accounting, and other activities that breach our Terms & Conditions or applicable law. This includes automated screening and monitoring of account and transaction patterns.

6.5 Responsible Gaming

To monitor gaming activity for indicators of problem gambling behaviour and to provide appropriate responsible gaming interventions, including account restrictions, limit-setting tools, and support referrals where warranted.

6.6 Customer Support

To respond to your queries, complaints, and requests. Communications with our support team are recorded and retained as part of our quality assurance and dispute resolution processes.

6.7 Marketing Communications (Consent-Based)

To send you promotional communications, bonus notifications, and platform updates — but only where you have consented to receive such communications. You may withdraw consent at any time by contacting [email protected]. We do not send unsolicited marketing communications.

6.8 Legal and Regulatory Compliance

To fulfil our obligations under applicable law, respond to legal requests from competent authorities, and cooperate with regulatory investigations where required under our international gaming licence.

7. Data Sharing and Disclosure

111cx does not sell your personal data to third parties. We share your data only in the following limited circumstances:

7.1 Service Providers

We share necessary data with carefully selected third-party service providers who act as data processors on our behalf, including payment processors (JazzCash, EasyPaisa, banking partners), identity verification services, technology infrastructure providers, and customer support software providers. All service providers are contractually bound to process your data only as instructed by 111cx and to maintain equivalent data security standards.

7.2 Regulatory and Legal Authorities

We may disclose personal data to regulatory bodies, law enforcement agencies, or courts where we are legally required to do so under applicable law, court order, or our gaming licence conditions. Where possible, we will notify you of such disclosure unless prohibited from doing so by law.

7.3 Anti-Fraud Networks

In cases of suspected fraud, money laundering, or other financial crime, 111cx may share relevant data with industry anti-fraud networks, payment scheme operators, or financial intelligence units in accordance with our legal obligations.

7.4 Business Transfers

In the event of a merger, acquisition, or sale of all or substantially all of 111cx's assets, personal data held by 111cx may be transferred to the acquiring entity. Users will be notified of any such transfer and any material change to the privacy practices applicable to their data.

8. Data Retention

111cx retains personal data for the minimum period necessary to fulfil the purposes for which it was collected and to comply with our legal obligations. The following retention guidelines apply:

• Account and identity data: Retained for the duration of your Account plus a minimum of five (5) years following Account closure, as required by gaming licence and anti-money laundering regulations;
• Financial transaction records: Retained for a minimum of five (5) years from the date of the transaction, in accordance with applicable financial record-keeping requirements;
• Gaming activity records: Retained for the duration of your Account and for at least three (3) years post-closure for regulatory audit purposes;
• Customer support communications: Retained for three (3) years from the date of the communication;
• KYC verification documents: Retained for the period mandated by our gaming licence and applicable AML law, typically five (5) years post-relationship end;
• Technical and usage data: Retained for a maximum of twenty-six (26) months from collection, after which it is anonymised or deleted.

Following the expiry of applicable retention periods, personal data is securely deleted or permanently anonymised so that it can no longer be attributed to any individual.

9. Data Security

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

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 111cx platform;
• Encryption at rest for sensitive personal data stored in 111cx systems;
• Access controls restricting data access to authorised personnel on a strict need-to-know basis;
• Multi-factor authentication for internal system access by 111cx staff;
• Regular security assessments and penetration testing conducted by independent security professionals;
• Secure data disposal procedures ensuring that deleted data is rendered irrecoverable.

10. Cookies & Tracking Technologies

10.1 What Cookies Are

Cookies are small text files placed on your device when you visit a website. They allow the website to recognise your device on subsequent visits and to store certain preferences or session information. 111cx uses cookies and similar tracking technologies to operate the platform effectively and improve your experience.

10.2 Types of Cookies 111cx Uses

• Strictly Necessary Cookies: Essential for the platform to function — including session cookies that keep you logged in to your 111cx Account during your visit. These cannot be disabled without preventing core platform functionality.
• Functional Cookies: Remember your preferences, language settings, and past interactions to provide a more personalised experience on 111cx.
• Analytics Cookies: Collect anonymised data about how users interact with the 111cx platform, including which pages are visited most frequently and how users navigate between sections. This data helps us improve the platform.
• Security Cookies: Used for fraud prevention and to detect unusual login patterns or access attempts on your 111cx Account.

10.3 Managing Cookies

You may manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 111cx platform. Strictly necessary cookies cannot be disabled without impacting your ability to use the platform, including the 111cx login functionality.

11. Minors and Age Protection

The 111cx platform is strictly for adults aged 21 years and above. 111cx does not knowingly collect, process, or retain personal data from individuals under the age of 21. If we become aware that personal data from an underage individual has been collected, we will delete it immediately, suspend the associated Account, and refund any deposits to the original payment method.

111cx encourages parents and guardians to use reputable parental control tools to prevent minors from accessing online gaming platforms. While 111cx implements its own age verification measures, parental supervision and technical controls at the household level provide an important additional layer of protection.

12. International Data Transfers

As 111cx operates on an international platform with data infrastructure that may be located in multiple jurisdictions, your personal data may be transferred to and processed in countries outside Pakistan. Where such transfers occur, 111cx ensures that appropriate safeguards are in place to protect your data to a standard at least equivalent to that required under our licensing jurisdiction's data protection framework.

Safeguards for international data transfers may include:

• Contractual clauses with data processors that impose equivalent data protection standards;
• Transfers to jurisdictions that maintain adequate data protection laws as recognised by applicable international standards;
• Other legally approved transfer mechanisms as required by applicable data protection law.

13. Exercising Your Data Rights

To exercise any of your data subject rights as described in the summary section above and as provided for under applicable data protection law, please contact 111cx at [email protected]. We recommend using the subject line "Data Rights Request" so your message reaches the correct team without delay.

When submitting a data rights request, please include:

• Your full name as registered on your 111cx Account;
• Your registered mobile number or email address;
• A clear description of the right you wish to exercise and the specific data concerned;
• Any other information that will help us locate your records promptly.

111cx will respond to all data rights requests within thirty (30) calendar days. Where a request is complex or involves a large volume of data, we may extend this period by a further thirty (30) days, in which case we will notify you of the extension and the reason for it. We do not charge a fee for processing data rights requests unless a request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.

14. Changes to This Privacy Policy

111cx reserves the right to update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or regulatory requirements. When we make material changes to this Policy, we will notify registered users through appropriate channels, which may include in-Platform notifications or contact via your registered mobile number or email address.

The "Effective Date" at the top of this Policy reflects the date on which the current version came into force. We encourage you to review this Policy periodically. Continued use of the 111cx platform following notification of updates constitutes your acceptance of the revised Policy.

15. Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or the way in which 111cx processes your personal data, please contact us using the details below. Our data protection team is available to assist you and will respond to all privacy-related queries as a priority.