x111x Privacy Policy

1. Who We Are

1.1 x111x (referred to as "x111x", "we", "us", or "our") is an online casino and sports betting platform operating at x111x.net, serving registered players in Pakistan and other permitted jurisdictions. x111x operates under an international gaming licence and is committed to maintaining the highest standards of data protection and player privacy.

1.2 For the purposes of this Privacy Policy, x111x is the data controller in respect of all personal data collected from players, visitors, and prospective registrants who interact with the x111x platform, whether via desktop browser, mobile browser, or any other interface provided by x111x.

1.3 This Privacy Policy should be read alongside the x111x Terms & Conditions and the Responsible Gaming Policy, both of which are incorporated herein by reference and form part of the overall agreement between x111x and its registered players.

1.4 If you have any questions about this Privacy Policy or how your data is handled, you may contact our dedicated privacy team at [email protected] with the subject line "Privacy Enquiry".

2. Data We Collect

2.1 x111x collects the following categories of personal data from players and platform visitors. We collect only what is necessary for the lawful and proper operation of the x111x platform.

2.1 Identity & Registration Data

• Full legal name as it appears on your government-issued ID (CNIC, passport, or driving licence);
• Date of birth (used to verify the 21+ age requirement);
• Residential address in Pakistan or your registered jurisdiction;
• Username and encrypted password for your x111x Login;
• Nationality and country of residence.

2.2 Contact Data

• Mobile phone number (used for account verification, OTP, and support communications);
• Email address (used for account management, promotional communications where opted in, and transaction confirmations).

2.3 Financial & Payment Data

• JazzCash or EasyPaisa mobile wallet account numbers;
• Bank account details for HBL, UBL, Meezan Bank, or other registered payment methods;
• Raast ID or 1LINK account reference where applicable;
• Transaction history including deposit amounts, withdrawal requests, and transaction reference numbers.

2.4 KYC Verification Documents

• Copies of government-issued photo identification (CNIC front and back, passport bio-data page, or driving licence);
• Proof of address documents such as a utility bill or bank statement dated within the last three months;
• Selfie photographs where required for liveness verification;
• Source of funds documentation for high-value accounts or as required by licensing obligations.

2.5 Gaming & Activity Data

• Full betting and gaming history across all x111x products (slots, live dealer, cricket betting, table games, Ocean King Jackpot);
• Bonus and promotion participation records;
• Session duration, login timestamps, and platform navigation patterns;
• Responsible gaming tool usage, including self-exclusion applications and deposit limit settings;
• Customer support interaction records and complaint history.

2.6 Technical & Device Data

• IP address at the time of registration and each subsequent login;
• Device type, operating system, and browser version;
• Geolocation data derived from IP address (not GPS-level location tracking);
• Cookie identifiers and session tokens.

3. How We Collect Your Data

3.1 Directly from You. The majority of personal data x111x holds is provided directly by you when you register an account, complete KYC verification, make a deposit or withdrawal, contact customer support, or participate in promotions and tournaments.

3.2 Automatically. When you access and use the x111x platform, certain technical data is collected automatically via cookies, server logs, and similar tracking technologies. This includes your IP address, session duration, pages visited, games played, and device fingerprint information. This automated data collection is necessary for security monitoring, fraud detection, and platform performance optimisation.

3.3 From Third Parties. x111x may receive data about you from the following third-party sources:

• KYC Verification Providers: Identity verification results and fraud screening scores returned by our approved KYC service providers;
• Payment Processors: Transaction confirmation and status data from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and 1LINK;
• Fraud Prevention Services: Risk scoring and device fingerprinting data from fraud detection vendors;
• Responsible Gaming Registries: Where applicable, self-exclusion status data from relevant national or international responsible gaming registries.

3.4 x111x does not purchase personal data from data brokers, social media platforms, or advertising networks.

4. Why We Use Your Data

4.1 x111x processes your personal data for the following specific purposes:

4.2 x111x will not use your personal data for any purpose incompatible with those listed in this section without first obtaining your explicit consent or notifying you of the new purpose in accordance with applicable data protection obligations.

5. Legal Basis for Processing

5.1 Contractual Necessity. Much of the data processing carried out by x111x is necessary to perform the contract between x111x and you as a registered player. This includes processing your registration data, managing your account, processing deposits and withdrawals, and delivering the gaming services you have requested.

5.2 Legal Obligation. x111x is required by its international gaming licence to conduct KYC verification, maintain anti-money laundering (AML) records, monitor for problem gambling behaviours, and retain certain data for specified periods. Processing personal data for these purposes is a legal requirement we cannot waive.

5.3 Legitimate Interest. Where we process data to prevent fraud, secure the platform against abuse, or improve platform performance, we do so on the basis of our legitimate interests as an online gaming operator — provided those interests are not overridden by your privacy rights.

5.4 Consent. Where x111x processes your data for optional purposes — such as sending promotional emails about new bonuses, PSL cricket betting markets, or new slot releases — we do so on the basis of your explicit consent. You may withdraw this consent at any time by contacting support or updating your communication preferences in your account settings. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

6. Data Sharing & Third Parties

6.1 x111x does not sell, rent, or trade your personal data to any third party for their own commercial purposes. Data sharing is strictly limited to the categories of recipients described in this section.

6.2 Service Providers. x111x engages trusted third-party service providers who process data on our behalf under binding data processing agreements. These include:

• KYC & Identity Verification Providers: To verify your identity documents, date of birth, and screen against sanctions lists;
• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and 1LINK, solely to process your deposit and withdrawal instructions;
• Fraud & Risk Management Vendors: To protect players and the platform against fraudulent activity and multi-accounting;
• Cloud Infrastructure & Hosting Providers: To store and process platform data securely under strict access controls;
• Customer Support Platforms: To manage and record support interactions.

6.3 Regulatory & Law Enforcement Disclosure. x111x may disclose personal data to gaming regulators, financial intelligence units, or law enforcement agencies where required to do so by applicable law, court order, or regulatory directive. Such disclosures are made on a strictly need-to-know basis and are logged internally.

6.4 Business Transfers. In the event that x111x or any part of its business is acquired, merged, or restructured, personal data held by x111x may be transferred to the acquiring entity as part of that transaction. Affected players will be notified in advance of any such transfer that materially affects how their data is processed.

7. Cookies & Tracking Technologies

7.1 x111x uses cookies and similar tracking technologies to operate the platform securely, remember your preferences, and improve your overall experience as a Pakistani player on x111x.net.

7.2 Types of Cookies Used:

7.3 x111x does not use third-party advertising cookies or cross-site tracking technologies that share your browsing behaviour with external advertising networks.

7.4 You may manage your cookie preferences at any time via your x111x account settings. Disabling non-essential cookies will not affect your ability to log in, deposit, withdraw, or play on the platform, but may reduce certain personalisation features.

8. Data Retention

8.1 x111x retains personal data for no longer than is necessary to fulfil the purpose for which it was collected, subject to any longer retention periods required by our international gaming licence or applicable anti-money laundering regulations.

8.2 The following general retention periods apply:

• Account & identity data: Retained for the duration of your account plus 5 years following account closure, as required by AML and licensing obligations;
• Transaction & financial records: Retained for 7 years from the date of the transaction in accordance with financial record-keeping requirements;
• KYC documents: Retained for 5 years from account closure or the date the document was submitted, whichever is later;
• Gaming activity logs: Retained for 5 years for audit, dispute resolution, and responsible gaming monitoring purposes;
• Customer support records: Retained for 3 years from the date of the interaction;
• Marketing consent records: Retained for 3 years from the date consent was given or last renewed.

8.3 Upon expiry of applicable retention periods, personal data is securely deleted or anonymised so that it can no longer be associated with any individual player. Anonymised, aggregated data may be retained indefinitely for statistical and platform improvement purposes.

9. Data Security

9.1 x111x implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and x111x servers;
• Encryption of sensitive data fields — including passwords and payment identifiers — at rest using industry-standard encryption algorithms;
• Role-based access controls ensuring that only authorised x111x personnel can access personal data, and only to the extent required by their specific job function;
• Regular independent security audits and penetration testing of the x111x platform;
• Multi-factor authentication (MFA) requirements for all x111x administrative system access;
• Real-time fraud and anomaly detection systems monitoring for suspicious account activity;
• Segregated player fund accounts held separately from x111x operational funds.

9.2 Despite these measures, no internet-based platform can guarantee absolute security. In the event of a data breach that is likely to result in a risk to your rights and freedoms, x111x will notify affected players and relevant authorities without undue delay, in accordance with our licensing obligations.

9.3 You are also responsible for maintaining the security of your own x111x Login credentials. Use a strong, unique password and do not share your login details with any other person. Enable two-factor authentication if offered via your account settings.

10. Your Rights

10.1 As a registered player on x111x, you have the following rights in respect of your personal data. To exercise any of these rights, contact [email protected] with the subject line "Data Rights Request". x111x will respond within 30 days of receiving a valid request.

11. Children & Minors

11.1 The x111x platform is strictly restricted to individuals who are 21 years of age or older in accordance with international gaming licensing standards applicable to x111x. x111x does not knowingly collect or process personal data from any individual under the age of 21.

11.2 Age verification is conducted as part of the registration process and is reinforced at the point of withdrawal via KYC document checks. Any account discovered to belong to a person under 21 years of age will be closed immediately, all associated data will be securely deleted to the extent permitted by legal obligations, and any balance in the account will be forfeited without recourse.

11.3 If you are a parent or guardian and believe that a minor in your care has registered on x111x, please contact [email protected] immediately with the subject line "Underage Account Report". x111x will investigate and act on all such reports within 24 hours.

12. International Data Transfers

12.1 x111x operates as an international gaming platform. In order to provide our services to Pakistani players, certain personal data may be transferred to and stored on servers or processed by service providers located outside Pakistan. Such transfers may include transfers to countries within and outside the jurisdiction of x111x's primary licensing authority.

12.2 Where personal data is transferred internationally, x111x ensures that appropriate safeguards are in place to protect your data. These safeguards may include:

• Contractual clauses with service providers requiring them to maintain data protection standards equivalent to those applied by x111x;
• Transfers to jurisdictions that maintain recognised standards of data protection under applicable international frameworks;
• Data processing agreements with all third-party processors specifying the permissible scope of data use and required security measures.

12.3 By registering an account and using the x111x platform, you acknowledge that your personal data may be processed internationally in accordance with this section and the protections described herein.

13. Changes to This Privacy Policy

13.1 x111x reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable legal requirements, or the services offered on the platform. All changes will be posted on this page with a revised effective date.

13.2 Where changes are material — meaning they significantly affect how your personal data is processed or your rights in relation to that data — x111x will notify registered players via email and/or a prominent notice on the platform at least 14 days before the revised policy takes effect.

13.3 Your continued use of the x111x platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the revised terms. If you do not agree with the updated policy, you should close your account before the effective date and contact support to request deletion of your data to the extent permitted by applicable retention obligations.

13.4 Previous versions of the x111x Privacy Policy are available upon written request to [email protected].

14. Contact & Complaints

14.1 If you have any questions, concerns, or requests relating to this Privacy Policy or the way x111x handles your personal data, please contact us:

• Privacy Enquiries: [email protected] — Subject: "Privacy Enquiry"
• Data Rights Requests: [email protected] — Subject: "Data Rights Request"
• Underage Account Reports: [email protected] — Subject: "Underage Account Report"
• Response Target: All privacy-related requests are acknowledged within 48 hours and resolved within 30 days
• Support Hours: 24 hours a day, 7 days a week

14.2 If you are not satisfied with x111x's response to a privacy complaint, you have the right to escalate your complaint to the relevant data protection authority or the independent dispute resolution body specified under x111x's international gaming licence. Details of the applicable authority will be provided upon request.