111win Privacy Policy — How We Protect Your Personal Data

111win ("the Platform," "we," "us," or "our") is the data controller responsible for the personal information you provide when using the 111win website, mobile site, and all associated services. This Privacy Policy applies to all players, visitors, and users of the 111win platform, including those based in Pakistan.

This policy should be read alongside our Terms and Conditions and Responsible Gaming policy. If you have any questions about how 111win handles your personal data, you can reach our privacy team at any time at support@111win.biz.

By registering an account or using the 111win platform in any capacity, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your data as described here.

111win collects different categories of personal data depending on how you interact with the platform. Here is a breakdown of what we collect and when:

Registration Data: When you create a 111win account, we collect your full name, date of birth, Pakistani mobile number, email address (if provided), and a password of your choice. This data is essential to open and maintain your account.

Identity Verification (KYC) Data: To comply with anti-money laundering requirements and to verify your age, we may collect copies of your CNIC (Computerised National Identity Card) or passport, a proof of address document such as a utility bill or bank statement, and a selfie or photograph for identity confirmation. KYC data is handled with the highest level of security and is used only for verification purposes.

Payment Data: When you make deposits or withdrawals on 111win, we collect information related to your payment method — such as your Easypaisa or JazzCash mobile number, bank account details for IBFT transfers, or masked card details for Visa/Mastercard transactions. 111win does not store full card numbers or banking passwords. All payment data is processed through secure, encrypted channels.

Transaction and Betting Data: We maintain records of all deposits, withdrawals, bets placed, games played, bonuses used, and account balance history associated with your 111win account. This data is necessary for account management, dispute resolution, and regulatory compliance.

Device and Technical Data: When you access 111win, our systems automatically collect information about your device and connection — including IP address, device type, operating system, browser type and version, screen resolution, and connection type. This data helps us optimise the platform for your device and detect fraudulent or unusual access patterns.

Behavioural and Usage Data: We collect data on how you use 111win — which pages you visit, how long you spend in each section, which games you play, which bets you place, and how you navigate the platform. This anonymised and aggregated behavioural data is used to improve the platform and personalise your experience.

Communications Data: If you contact 111win's support team via live chat or email, we retain records of those communications. This helps us track the resolution of issues, maintain service quality, and provide context for any follow-up queries.

111win collects personal data only when there is a clear and legitimate reason to do so. We do not collect data speculatively or "just in case." Here are the specific purposes for which we collect each category of personal data:

• Account registration data is collected to create and maintain your player account on 111win and to communicate important account information to you.
• KYC data is collected to verify that you meet the minimum age requirement of 18 years, to comply with anti-money laundering (AML) obligations, and to confirm that the payment methods you use belong to you.
• Payment data is collected to process your deposits and withdrawals securely and accurately.
• Transaction and betting data is retained to maintain an accurate account history, resolve disputes, calculate bonuses and winnings, and meet regulatory reporting requirements.
• Device and technical data is collected to detect fraud, prevent multiple account creation, optimise platform performance on your specific device, and maintain security.
• Behavioural data is collected to improve the platform, personalise your experience, and — where you have opted in — to send you relevant promotional communications.
• Communications data is retained to improve support quality, train our team, and maintain a record of how past queries were handled.

111win processes your personal data on the following legal bases:

• Contract performance: Processing your registration data, payment data, and transaction data is necessary to perform the contract between you and 111win — i.e., to operate your account and process your bets and transactions.
• Legal obligation: KYC verification and transaction record-keeping are required by anti-money laundering laws and other applicable regulations. 111win is legally required to collect and retain this data for specified periods.
• Legitimate interests: Collecting device and technical data for fraud prevention and platform security is in the legitimate interests of both 111win and its player community, provided it does not override your privacy rights.
• Consent: Where 111win sends you optional promotional communications or uses non-essential cookies, we rely on your explicit consent, which you can withdraw at any time.

The personal data 111win holds is used for specific, limited purposes. We do not use your data in ways that would surprise you or that go beyond what is described in this policy. Specific uses include:

• Creating and maintaining your 111win account and all features associated with it.
• Processing your deposits, bets, winnings, and withdrawals accurately and promptly.
• Verifying your identity and age in accordance with KYC requirements.
• Sending you transactional account notifications — such as deposit confirmations, withdrawal receipts, and security alerts. These communications are necessary and cannot be opted out of while your account is active.
• Sending you promotional communications about 111win offers, bonuses, and new games — but only if you have opted in. You can opt out at any time.
• Detecting, investigating, and preventing fraud, money laundering, and any other activity that violates our Terms and Conditions.
• Improving the 111win platform based on anonymised usage patterns and feedback.
• Complying with legal and regulatory obligations applicable to our operations.
• Supporting responsible gaming measures — including monitoring for signs of problem gambling behaviour and providing appropriate tools and interventions.

111win does not sell your personal data to any third party. Full stop. We may share your data only in the following specific and limited circumstances:

All third parties with whom 111win shares personal data are bound by data processing agreements that require them to use your data only for the stated purpose and to maintain appropriate security standards. We do not permit our service providers to use your data for their own marketing purposes.

111win retains personal data only for as long as it is necessary for the purposes described in this policy or as required by law. Specific retention periods include:

• Account data (name, contact details, login history): retained for the duration of your account plus 5 years after account closure, to comply with legal obligations.
• KYC and identity documents: retained for a minimum of 5 years after account closure, in accordance with anti-money laundering regulations.
• Transaction records (deposits, withdrawals, bets): retained for a minimum of 5 years for regulatory compliance and dispute resolution.
• Communications with support: retained for 2 years after the last interaction, to support quality monitoring and dispute resolution.
• Cookie and tracking data: retained for periods specified in the cookie table in Section 9 of this policy.

After the applicable retention period expires, your personal data is securely deleted or anonymised so that it can no longer be linked to you individually. Anonymised, aggregated data (which cannot identify you) may be retained indefinitely for analytical and improvement purposes.

111win takes data security seriously and implements a layered approach to protecting your personal information. The security measures in place include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the 111win platform, including all account pages, payment pages, and support communications.
• Encryption at rest for all sensitive personal data stored on 111win servers, including KYC documents and payment details.
• Access controls: access to personal data within 111win is restricted on a strict need-to-know basis. Staff are granted access only to the minimum data necessary to perform their role and all access is logged and audited.
• Regular security assessments including vulnerability scanning and penetration testing by independent security professionals.
• Two-factor authentication (2FA) available for all 111win accounts and mandatory for all internal staff systems.
• Incident response procedures to detect, investigate, and notify affected users in the event of a data breach within legally required timeframes.

111win uses cookies and similar tracking technologies when you access the platform. A cookie is a small text file placed on your device by a website that helps the website function correctly and remember your preferences. Here is what we use and why:

You can manage your cookie preferences through your browser settings at any time. Note that disabling essential or security cookies may prevent parts of 111win from working correctly. You will not be able to use your 111win account without essential cookies enabled.

111win does not use third-party advertising or retargeting cookies. We do not allow advertising networks to place cookies on our platform.

You have clear rights over the personal data that 111win holds about you. Here is a plain-language description of each right and how to exercise it:

111win is strictly for adults aged 18 and over. We do not knowingly collect personal data from individuals under the age of 18. If 111win becomes aware that a minor has provided personal data — for example, during a registration attempt — we will immediately close the account, delete all associated data, and refund any deposits made. If you believe a minor has created an account on 111win, please contact us immediately at support@111win.biz so we can take prompt action. Full details of 111win's age verification process are available in our Responsible Gaming policy.

111win's primary servers and operations are based in Asia. In certain circumstances, data may be processed by service providers operating in other jurisdictions — for example, cloud infrastructure providers. When such transfers occur, 111win ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this policy. This includes contractual data processing agreements with all international service providers. If you have questions about international data transfers related to your 111win account, please contact support@111win.biz.

111win reviews and updates this Privacy Policy periodically to reflect changes in our practices, platform features, or applicable legal requirements. When material changes are made, we will notify registered players via email or an in-platform notification at least 7 days before the changes take effect. The effective date at the top of this page will always reflect when the current version was last updated. Continued use of 111win after the effective date of an update constitutes acceptance of the revised policy. If you do not agree with any change, you may close your account and request deletion of your data in accordance with your rights in Section 10.

If you have any questions about this Privacy Policy or about how 111win handles your personal data, or if you wish to exercise any of your data rights, please get in touch:

• Email: support@111win.biz (subject: "Privacy Policy Query" or "Data Rights Request")
• Live Chat: Available 24/7 directly on the 111win platform
• Response time: Privacy queries acknowledged within 48 hours, fully resolved within 30 days

If you believe that 111win has mishandled your personal data and you are not satisfied with our response to a complaint, you may have the right to escalate your complaint to an applicable supervisory authority. 111win takes all data-related complaints seriously and will always make every reasonable effort to resolve them fairly and promptly before formal escalation is necessary.