111xp Privacy Policy

1 Data Controller

For the purposes of this Privacy Policy, 111xp is the data controller — meaning we are responsible for determining how and why your personal data is processed. When you interact with the 111xp platform, deposit funds, place bets, or contact our support team, the information involved is handled under the responsibility of 111xp.

If you have any questions about how your data is handled, or want to exercise your data rights, you can contact our support team at any time via live chat in the platform or by emailing [email protected].

2 What We Collect

The categories of personal information 111xp collects are listed below. We collect only what is necessary for the purposes described in this policy.

We do not collect sensitive categories of personal data such as biometric data, health information, or political or religious views. If identity verification requires a document such as a national ID, that document is processed solely for the purpose of verifying your identity and is not retained beyond what is necessary.

3 How We Collect Data

Personal data is collected through the following channels:

• Direct from you: When you register an account, complete verification, make a deposit or withdrawal, contact support, or participate in a promotion.
• Automatically: When you use the platform, our systems log technical data including your IP address, device identifiers, session activity, and platform interactions. This is standard practice for online platforms and is used for security and platform improvement.
• From payment processors: When you make a deposit or withdrawal via JazzCash, Easypaisa, Raast, or bank transfer, the payment provider shares transaction confirmation data with us to process your transaction correctly.
• From verification services: If your identity is verified through a third-party KYC service, that provider shares verification outcome data with us — not the raw document images unless required for manual review.

4 How We Use Your Data

Your personal data is used for the following purposes on the 111xp platform:

• Creating and maintaining your account, including login authentication and account recovery.
• Processing deposits and withdrawals in PKR, and maintaining accurate transaction records for your account.
• Verifying your identity when required — at registration, on first withdrawal, or when account activity triggers a routine review.
• Detecting and preventing fraud, money laundering, underage gambling, and other prohibited activities on the platform.
• Providing customer support — our team accesses relevant account data to resolve your queries accurately and efficiently.
• Sending transactional communications: deposit confirmations, withdrawal notifications, security alerts, and account-related updates. These are not marketing emails and cannot be opted out of while your account is active.
• Sending promotional communications about offers and bonuses — only if you have opted in to marketing communications during registration or through your account settings.
• Monitoring platform usage to identify and improve technical issues, and to develop features that better serve players on the platform.
• Meeting responsible gaming obligations — session activity data is used to identify patterns that may warrant outreach or account-level intervention under our responsible gaming commitment.

5 Legal Basis for Processing

We process your personal data under one of the following legal grounds depending on the activity involved:

• Contract performance: Processing necessary to provide the service you signed up for — account management, transaction processing, and support.
• Legal obligation: Processing required to comply with applicable legal requirements, including identity verification and fraud prevention obligations.
• Legitimate interest: Processing for fraud detection, platform security, and responsible gaming monitoring — where these interests are not overridden by your data protection rights.
• Consent: Where you have given explicit consent — for example, opting in to promotional communications. You can withdraw consent for marketing at any time via your account settings.

6 Data Sharing

111xp does not sell your personal data. We share data only with the categories of third parties described below, and only to the extent necessary for the stated purpose:

• Payment processors: JazzCash, Easypaisa, Raast, and banking partners require transaction data to process your deposits and withdrawals. These providers operate under their own privacy policies and data protection standards.
• Identity verification providers: KYC service providers receive identity document data to carry out verification checks. They are contractually bound to process this data solely for verification purposes.
• Game providers: When you play games on 111xp, the game provider's software runs within the platform. Providers may receive your player ID and game session data to operate the game. They do not receive your full identity or financial details.
• Technical service providers: Hosting, security, and analytics providers who support platform operation. These providers act as data processors under contracts that restrict data use to their specific function.
• Law enforcement or regulatory bodies: Where we are legally required to disclose information — for example, in response to a valid court order or to meet anti-money-laundering reporting obligations.

7 Payments & Identity Verification

Because 111xp processes real-money transactions in PKR — via JazzCash, Easypaisa, Raast, bank transfers, and cards — we are required to verify the identity of players at certain points. This is a standard requirement for any platform handling financial transactions and is in place to protect players as much as it is a compliance measure.

Verification typically requires you to provide a copy of a valid identity document. This document is reviewed by our KYC team or verification partner, and the outcome — verified or not verified — is recorded on your account. Document images are not retained beyond what is necessary for the verification process.

111xp does not store full card numbers. Card transactions are handled through certified payment processors that operate under their own data security standards. We receive only a transaction reference and the last four digits of a card for record-keeping purposes.

8 Cookies & Tracking Technologies

111xp uses cookies and similar technologies on the website and in the app. Here's what they're used for:

• Essential cookies: Required for the platform to function — maintaining your login session, remembering your language preference, and enabling core account features. These cannot be disabled without breaking platform functionality.
• Security cookies: Used to detect and prevent fraud and suspicious activity — for example, flagging unusual login patterns or repeated failed authentication attempts.
• Analytics cookies: Used to understand how players navigate the platform so we can identify areas for improvement. This data is aggregated and does not identify you individually.
• Performance cookies: Used to optimise loading times and video stream quality — relevant particularly for live casino and sports betting, where fast loading directly affects the experience.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not affect your ability to play or manage your account, though some personalisation features may not work as intended.

9 Data Retention

We retain personal data for as long as your account is active and for a defined period after closure. Specific retention periods vary by data type:

• Account and identity data is retained for the duration of your account and for a period after closure to meet legal and financial record-keeping obligations.
• Transaction records are retained for the period required under applicable financial record-keeping requirements.
• Support communications are retained for a period sufficient to resolve any disputes that might arise from those interactions.
• Technical and usage logs are retained for a shorter period, typically 12 months, unless retained longer for an active security investigation.

When data is no longer required, it is permanently deleted or anonymised so that it can no longer be linked back to you as an individual. If you request account deletion, we will process the deletion of personal data not required for legal or financial obligations within a reasonable timeframe.

10 Security Measures

Protecting your personal data is something we take seriously. The technical and organisational measures in place at 111xp include:

• Encryption of personal data in storage using industry-standard protocols.
• TLS encryption on all data transmitted between your device and our servers — the padlock in your browser confirms this is active.
• Access controls ensuring only authorised staff can access personal account data, and only the portions of that data relevant to their specific role.
• Regular security reviews and monitoring of our systems for vulnerabilities or unusual activity.
• Two-factor authentication available for player accounts — we strongly recommend enabling this in your account settings.

11 Your Rights

As a player on 111xp, you have the following rights over your personal data. To exercise any of them, contact support via live chat or email.

12 Minors

111xp is strictly an adults-only platform. Players must be 18 years of age or older to register and use the platform. We do not knowingly collect personal data from anyone under 18.

If we become aware that an account has been registered by someone under 18, that account will be suspended immediately. Any balance held will be subject to review, and the situation will be handled in line with our responsible gaming policy. Funds deposited by an underage player may be returned to the payment method used, minus any amounts used in play.

If you are a parent or guardian and have reason to believe a minor has registered on 111xp, please contact support immediately so we can address it promptly.

13 Changes to This Policy

This Privacy Policy may be updated from time to time to reflect changes in how we operate the platform, changes to legal requirements, or improvements to how we describe our data practices. When updates are made, the "Last updated" date at the top of this page will be revised.

For significant changes that affect how your personal data is used, we will notify registered players via the email address on their account or via an in-platform notification, giving you an opportunity to review the changes before they take effect.

Continued use of 111xp after a policy update constitutes acceptance of the revised terms. If you disagree with any changes, you can request account closure before the updated policy takes effect.

14 Contact Us

If you have questions about this Privacy Policy, want to exercise your data rights, or need to raise a data-related concern, please reach out to the 111xp team:

• Live chat: Available 24/7 within the 111xp platform. This is the fastest way to reach us.
• Email: [email protected] — for formal data requests, please mark your email with "Data Request" in the subject line.

We aim to acknowledge all formal data requests within 48 hours and to resolve them within 30 days. For complex requests that require additional time, we will notify you of the expected timeline.