111xp Privacy Policy — How We Protect Your Personal Data

111xp is committed to protecting the privacy and personal data of every user who interacts with our platform. This Privacy Policy has been prepared to be transparent, direct, and comprehensive — you should be able to read it and come away with a clear understanding of exactly how your data is handled.

This Policy applies to all personal data collected through: the 111xp website and account registration; the gaming, betting, and casino products offered through 111xp; financial transactions processed via JazzCash, EasyPaisa, Raast, bank transfers, and any other payment method supported on 111xp; customer support communications via live chat, email, or any other support channel; and marketing and promotional communications where you have provided consent.

111xp is the operator of the online gaming platform accessible at 111xp.net. 111xp holds a valid international gaming licence that governs its operations, including its data protection and player privacy obligations. As the data controller in respect of personal data collected through the platform, 111xp is responsible for determining the purposes and means by which your personal data is processed.

111xp serves players across Pakistan — including major cities such as Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, Multan, and Peshawar — and processes all account and financial data in accordance with the obligations of its gaming licence and applicable international data protection standards.

111xp collects the following categories of personal data from or about users of the platform:

111xp collects personal data through the following methods and sources:

• Direct submission by you: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or updating your account profile.
• Automated technical collection: Information collected automatically when you access the 111xp platform, including IP address, device identifiers, browser data, session duration, and navigation patterns — collected via server logs, cookies, and similar technologies.
• Payment processors: Transaction confirmation data received from JazzCash, EasyPaisa, Raast, and Pakistani banking partners when you initiate or complete a financial transaction on 111xp.
• Identity verification services: KYC-related data received from third-party identity verification providers engaged by 111xp to verify the authenticity of documents and identity claims.
• Gaming activity: Data generated by your interactions with 111xp gaming products — including cricket sportsbook bets, casino game sessions, slot spins, crash game rounds, and bingo participation.
• Fraud and compliance tools: Data received from third-party fraud detection and anti-money laundering screening services used by 111xp to protect the platform's integrity.

111xp processes your personal data for the following purposes, each supported by a recognised legal basis:

• Account operation and service delivery (Contractual necessity): To create and maintain your 111xp account, process bets and game rounds, credit winnings, manage your PKR wallet, and deliver the gaming products you have signed up to use.
• Identity verification and KYC (Legal obligation): To verify your identity, age (21+), and the source of funds deposited to your account in compliance with 111xp's gaming licence anti-money laundering and know-your-customer obligations.
• Financial transaction processing (Contractual necessity): To process JazzCash deposits, EasyPaisa withdrawals, bank transfers, and all other PKR financial flows associated with your 111xp account.
• Fraud prevention and security (Legitimate interest): To detect and prevent fraudulent account activity, bonus abuse, money laundering, underage gambling, and other prohibited conduct on the platform.
• Responsible gaming monitoring (Legal obligation / Legitimate interest): To monitor gaming patterns for signs of problematic gambling behaviour, enforce player-set limits, process self-exclusion requests, and fulfil responsible gaming obligations under 111xp's gaming licence.
• Customer support (Contractual necessity): To respond to your support queries, resolve disputes, and manage complaints effectively.
• Regulatory compliance (Legal obligation): To fulfil reporting, audit, and record-keeping obligations imposed by 111xp's gaming licence authority and applicable law.
• Marketing communications (Consent): To send promotional offers, bonus notifications, and platform updates — only where you have provided explicit consent. You may withdraw this consent at any time.
• Platform improvement (Legitimate interest): To analyse aggregated usage patterns, improve platform performance, and enhance the user experience for Pakistani players.

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

• Payment processors: JazzCash, EasyPaisa, Raast, HBL, UBL, Meezan Bank, and other payment partners receive only the transactional data necessary to process your specific deposit or withdrawal. These processors operate under their own data protection obligations.
• Identity verification providers: Third-party KYC service providers who verify the authenticity of identity documents submitted for 111xp account verification. These providers process data under strict contractual confidentiality obligations.
• Gaming software suppliers: Game providers who supply live casino, slot, and other gaming products accessible through 111xp receive limited account session data necessary to deliver those games. They do not receive your full personal profile.
• Regulatory authorities: 111xp's gaming licence authority and any competent regulatory body may receive data as required by law, including in response to formal regulatory requests, audits, or investigations.
• Law enforcement: Where legally required, 111xp may disclose personal data to law enforcement authorities in response to valid legal process, court orders, or to prevent or report criminal activity.
• Fraud prevention networks: Aggregated or anonymised fraud indicator data may be shared with industry fraud prevention services to protect the integrity of online gaming platforms across the sector.
• Corporate transactions: In the event of a merger, acquisition, or sale of the 111xp business, personal data may be transferred to the acquiring entity, subject to equivalent data protection obligations being imposed on the recipient.

Given that the majority of 111xp transactions are conducted through JazzCash and EasyPaisa — Pakistan's leading mobile wallet platforms — we want to be specific about how payment-related data is handled:

• When you initiate a JazzCash deposit on 111xp, your mobile number is passed to the JazzCash API to generate a payment request. Your JazzCash PIN and account password are never processed by or visible to 111xp's systems.
• Transaction references, amounts, timestamps, and confirmation statuses received from JazzCash and EasyPaisa are stored in your 111xp account record as part of your PKR transaction history.
• Your PKR wallet balance and full transaction history are accessible to you at any time through your logged-in 111xp account dashboard.
• Payment data is retained by 111xp for a minimum of 5 years following account closure, as required by anti-money laundering regulations applicable under 111xp's international gaming licence.
• 111xp does not store full bank account numbers or EasyPaisa wallet credentials beyond what is required to process and reconcile individual transactions.

111xp uses cookies and similar tracking technologies to operate the platform effectively and to understand how players use the site. The following types of cookies may be placed on your device when you visit 111xp.net:

• Essential cookies: Required for the platform to function — including session management, login state, and security tokens. These cannot be disabled without preventing you from using the platform.
• Functional cookies: Remember your preferences such as language settings, last visited game section, and display preferences to personalise your experience across sessions.
• Analytics cookies: Aggregate data about how users navigate the platform — which pages are visited most, where users drop off, and how long sessions last. This data is used in anonymised form to improve the platform experience for Pakistani players.
• Security cookies: Used to detect unusual login patterns, prevent cross-site request forgery, and protect your account from session hijacking attempts.

You can manage cookie preferences through your browser settings. Please note that disabling essential cookies will impair your ability to log in and use the 111xp platform. Analytics and functional cookies can typically be disabled without affecting core functionality.

111xp retains personal data for the minimum period necessary to fulfil the purpose for which it was collected, and in compliance with applicable regulatory retention requirements. The following retention periods generally apply:

• Active account data: Retained for the duration of your account and for a period of at least 5 years following account closure, as required under anti-money laundering regulations.
• KYC and identity documents: Retained for a minimum of 5 years from the date of submission or account closure, whichever is later, in accordance with gaming licence requirements.
• Financial transaction records: Retained for a minimum of 5 years following each transaction, as required by AML compliance obligations.
• Gaming activity logs: Retained for a minimum of 3 years for responsible gaming monitoring and dispute resolution purposes.
• Customer support records: Retained for 3 years following the resolution of the relevant support interaction.
• Marketing consent records: Retained for 3 years following withdrawal of consent, as evidence of consent management compliance.

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

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

• SSL/TLS encryption: All data transmitted between your device and 111xp servers is encrypted using industry-standard SSL/TLS protocols — the same technology that protects online banking transactions.
• Data encryption at rest: Sensitive personal data stored in 111xp databases — including identity documents and payment references — is encrypted at rest using AES-256 or equivalent standards.
• Access controls: Personal data is accessible only to authorised 111xp personnel who require it to perform their specific job functions. Access is controlled by role-based permission systems and logged for audit purposes.
• Two-factor authentication: All internal 111xp staff systems require multi-factor authentication. Players are strongly encouraged to enable 2FA on their own 111xp accounts.
• Regular security audits: 111xp engages independent security professionals to conduct periodic penetration testing and vulnerability assessments of the platform infrastructure.
• Data breach response: 111xp maintains a documented data breach response procedure. In the event of a breach affecting your personal data, you will be notified in accordance with applicable regulatory requirements.

As an internationally licensed online gaming operator serving Pakistani players, 111xp may process or store personal data on servers located outside of Pakistan. Such international data transfers are conducted in accordance with appropriate safeguards, which may include:

• Standard contractual clauses approved by data protection authorities in relevant jurisdictions, which impose binding data protection obligations on all data recipients.
• Transfers to countries or territories recognised as providing an adequate level of data protection by applicable regulatory standards.
• Data processing agreements with third-party service providers that include mandatory data protection and security obligations equivalent to those 111xp observes internally.

111xp's gaming licence jurisdiction provides the overarching regulatory framework governing these international processing arrangements. Players with questions about specific transfer mechanisms may raise these through the contact channels set out in Section 16.

The 111xp platform is strictly intended for adults aged 21 years or older. 111xp does not knowingly collect personal data from individuals under the age of 21 and does not permit underage persons to register or use the platform.

All registration attempts require confirmation of age, and KYC verification includes date-of-birth verification against government-issued identity documents. Any account subsequently found to belong to a person under the age of 21 will be immediately closed and all personal data associated with that account will be deleted, except where retention is required by law.

111xp actively encourages users to use available parental controls and internet filtering tools to prevent underage family members from accessing online gambling platforms.

Where you have provided explicit consent during registration or subsequently updated your preferences, 111xp may send you marketing communications relating to:

• New games and game categories added to the 111xp platform.
• Promotional offers, bonus credits, free spins, and reload promotions.
• PSL season and cricket tournament special offers relevant to the 111xp sportsbook.
• Platform updates and new feature announcements.
• Responsible gaming reminders and account security notifications.

You may opt out of marketing communications at any time by: updating your communication preferences in your 111xp account settings; following the unsubscribe link included in any marketing email; or contacting 111xp support via live chat. Opting out of marketing communications does not affect the receipt of essential account or security communications, which will continue to be sent regardless of marketing preferences.

To exercise any of the privacy rights described in this Policy — including access, correction, erasure, restriction, portability, or consent withdrawal — please submit your request through one of the following channels:

• Live chat: The fastest way to submit a privacy rights request. Identify yourself as making a data rights request and provide your registered mobile number for account verification. Available 24/7.
• Email: Send your request to [email protected] with the subject line "Privacy Rights Request" and include your registered mobile number and the nature of your request.

111xp will acknowledge receipt of your request within 5 business days and respond substantively within 30 calendar days. Where a request is complex or involves large volumes of data, this period may be extended by up to a further 60 days, in which case you will be notified of the extension and the reason for it.

To protect your data, 111xp will require identity verification before processing any privacy rights request. This is to ensure your data is only released to or acted upon at the instruction of the account holder.

111xp may update this Privacy Policy from time to time to reflect changes in our data processing practices, regulatory requirements, or platform services. When material changes are made, 111xp will:

• Update the "Last Updated" date at the top of this Policy.
• Where practicable, notify registered players by email or platform notification prior to the changes taking effect.
• Make the revised Policy available on 111xp.net with clear indication that a new version has been published.

Your continued use of the 111xp platform following publication of a revised Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with any changes, you may close your account and request deletion of your data (subject to legal retention requirements) by contacting support.

For any privacy-related queries, data rights requests, or concerns about how 111xp handles your personal data, please contact us through the following channels:

• Live Chat: Available 24/7 directly on the 111xp platform — the fastest channel for privacy queries.
• Email: [email protected] — for formal written correspondence and data rights requests.

If you have submitted a privacy concern to 111xp and are not satisfied with the response received through our internal process, you may escalate your complaint to the data protection supervisory authority relevant to 111xp's gaming licence jurisdiction, or to the consumer protection authority in your country of residence where applicable mandatory law provides this right.

111xp takes all privacy complaints seriously. Our goal is to resolve any concern you raise fairly, promptly, and transparently. We treat every privacy query — from a player in Karachi asking about their account data to a regulatory inquiry regarding our AML processes — with the same level of attention and care.