Privacy Policy – 111com Pakistan Online Casino

1 About This Policy

This Privacy Policy describes how 111com — operating the online gaming platform at https://111com.bet — collects, uses, stores, shares, and protects the personal information of everyone who visits or registers on the Platform. It applies to all players based in Pakistan and to anyone else who accesses the 111com website or any of its services.

By creating an account on 111com, making a deposit, or simply browsing the website, you acknowledge that you have read this policy and that you consent to the data practices described herein. If you do not agree, you should not use the Platform.

This policy forms part of your overall agreement with 111com and should be read alongside the Terms and Conditions and the Responsible Gaming Policy. In the event of any conflict between these documents, the Terms and Conditions shall take precedence on legal and contractual matters, while this Privacy Policy governs all data-specific matters exclusively.

111com is committed to handling your personal data responsibly and in accordance with recognised principles of data protection — including lawfulness, fairness, transparency, purpose limitation, data minimisation, accuracy, storage limitation, and integrity. We collect only what we genuinely need, we use it only for the purposes stated, and we hold it only for as long as necessary.

2 Data We Collect

111com collects personal data in several ways — through information you provide directly, through your use of the Platform, and through technical systems that operate automatically when you visit any page on the website.

Information You Provide Directly

• Registration data: Your full legal name, date of birth, Pakistani mobile number, email address, and chosen username when you create an account.
• Identity verification (KYC) documents: A copy of your CNIC, passport, or driving licence — and in some cases a selfie for liveness verification — submitted as part of the mandatory Know Your Customer process before withdrawals are approved.
• Payment details: Your Easypaisa or JazzCash mobile wallet number, NayaPay or SadaPay account details, bank account number for IBFT transfers, or masked card details for Visa/Mastercard transactions.
• Communications: Any messages you send to 111com support via live chat, email, or any other channel, including the content of your queries and our responses.
• Responsible gaming forms: Any deposit limit requests, cooling-off submissions, or self-exclusion requests you submit through the Responsible Gaming tools.

Information Collected Automatically

• Device and technical data: Your IP address, device type, operating system, browser type and version, and screen resolution when you access 111com.
• Usage and session data: Pages visited, time spent on each page, game titles opened, bet amounts placed, session start and end times, and feature interactions within the Platform.
• Transaction data: A complete record of every deposit, withdrawal, bonus credit, wager, and win or loss on your account, including timestamps and payment method references.
• Cookie and tracking data: As described in Section 7 of this policy.

3 How We Use Your Data

111com uses the personal data it collects for the following purposes. We do not use your data for any purpose not listed here without first obtaining your explicit consent.

• Account management: Creating, verifying, and maintaining your 111com player account. This includes sending account confirmation emails, password reset notifications, and important security alerts.
• Identity verification and fraud prevention: Verifying your identity through KYC to comply with applicable regulations and to protect against account fraud, money laundering, and underage gaming.
• Payment processing: Processing deposits and withdrawals through your chosen Pakistani payment method, and maintaining a complete transaction history for your records and ours.
• Game operation and dispute resolution: Maintaining server-side records of all game rounds to resolve disputes, identify technical errors, and confirm game outcomes where a player contacts support with a concern.
• Bonus and promotion management: Tracking bonus eligibility, wagering requirement progress, and promotion participation to ensure bonuses are applied correctly and to prevent duplicate claims.
• Customer support: Responding to your queries, resolving complaints, and maintaining a record of support interactions to improve service quality over time.
• Responsible gaming: Monitoring gaming patterns to identify potential problem gambling behaviours, applying requested deposit limits and self-exclusion measures, and contacting players whose activity suggests they may benefit from responsible gaming support.
• Platform improvement: Analysing aggregated, anonymised usage data to understand which features and games are most popular, identify technical performance issues, and guide future development priorities.
• Legal and regulatory compliance: Retaining records as required by applicable laws and responding to lawful requests from regulatory or law-enforcement authorities.
• Marketing communications (optional): Sending promotional emails and SMS messages about new games, bonuses, and offers on 111com — but only if you have opted in to receive marketing communications. You can withdraw this consent at any time.

4 Legal Basis for Processing

111com processes your personal data on the following legal grounds:

• Contractual necessity: Processing your registration data, identity verification, payment details, and gaming activity records is necessary to provide you with the services you signed up for. Without this processing, we cannot operate your account.
• Legal obligation: KYC identity verification, transaction record-keeping, and cooperation with lawful regulatory or law-enforcement requests are required by applicable legal and regulatory obligations and are not optional for 111com or for you.
• Legitimate interest: Fraud detection, platform security monitoring, dispute resolution, and aggregated analytics for platform improvement are carried out on the basis of 111com's legitimate business interest, balanced against your privacy rights. We do not process more data than necessary for these purposes.
• Consent: Marketing communications, the use of non-essential cookies, and any processing not covered by the above categories are carried out only on the basis of your explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing that took place before withdrawal.

5 Data Sharing and Third Parties

111com does not sell, rent, or trade your personal data to any third party for commercial or marketing purposes. This is an absolute commitment — not a conditional one.

We do share data with carefully selected third parties where necessary to operate the Platform. All third-party processors are bound by data processing agreements that restrict their use of your data to the specific purpose for which it was shared and require them to maintain appropriate security standards.

Categories of Third Parties We Share Data With

• Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, and banking partners receive the payment account details necessary to process your deposit or withdrawal. They receive only what they need to complete the transaction and are independently regulated financial institutions with their own data protection obligations.
• Game studios: Pragmatic Play, Spribe, Evolution Gaming, Play'n GO, NetEnt, and other studio partners receive anonymised session identifiers to facilitate game connectivity and resolve technical disputes. They do not receive your real name, CNIC, or payment details.
• KYC and identity verification services: Third-party identity verification providers process your KYC documents on our behalf. These providers are contractually required to process your data only for the purpose of verifying your identity and are prohibited from using it for any other purpose.
• Analytics and platform technology: Anonymised, aggregated usage data may be shared with technology partners for the purpose of platform performance monitoring and analytics. No personally identifiable information is included in these data sets.
• Regulatory and law-enforcement authorities: Where required by a valid legal order or regulatory obligation, 111com will disclose the minimum necessary personal data to the relevant authority. We will notify affected players of such disclosures where we are legally permitted to do so.

6 Payment Data and Financial Security

Given the financial nature of the 111com Platform, the security of payment data receives the highest level of protection we apply to any category of personal data.

All payment transactions on 111com are processed through PCI-DSS Level 1 compliant payment gateways. This is the highest level of the Payment Card Industry Data Security Standard and represents the most rigorous set of technical and procedural requirements for any entity that processes financial card data.

111com does not store full card numbers, CVV codes, or PIN details on its own servers. Card transactions are tokenised at the payment gateway level, meaning that 111com receives and stores only a masked reference that allows future transactions to be processed without your card details passing through our systems again.

Mobile wallet transactions through Easypaisa, JazzCash, NayaPay, and SadaPay are processed via encrypted API connections to each provider's verified endpoints. Your mobile wallet PIN is never seen by 111com at any stage of the transaction.

Bank account details provided for IBFT transfers are stored in encrypted form and are used solely for the purpose of processing your withdrawal to the account you have registered. 111com does not initiate debit transactions against your bank account — IBFT transactions on 111com are outbound payments only.

7 Cookies and Tracking Technologies

111com uses cookies and similar tracking technologies on its website. A cookie is a small text file placed on your device by your browser when you visit a website. Cookies allow the website to remember certain information about your visit — such as whether you are logged in — and to collect data about how you use the site.

Types of Cookies We Use

• Strictly Necessary Cookies: These are essential for the Platform to function. They maintain your login session, remember your language and currency preferences, and ensure security features operate correctly. These cookies cannot be disabled without preventing the Platform from working.
• Functional Cookies: These remember your preferences across sessions — such as which games you have recently played or your preferred bet size settings — so you do not have to re-enter them every time you log in.
• Analytics Cookies: These collect anonymised information about how visitors use the 111com website, which pages are visited most frequently, and where users encounter errors. This data is used to improve the Platform. These cookies require your consent and can be declined.
• Marketing Cookies: If you have opted in to receive promotional communications, these cookies help us ensure that our messages are relevant to your gaming preferences. These cookies require your consent and can be declined at any time.

You can manage cookie preferences through the cookie settings panel available on the 111com Platform. Most browsers also allow you to view and delete cookies through their settings menus. Note that disabling strictly necessary cookies will affect your ability to use the Platform.

8 Data Retention

111com retains personal data for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal and regulatory obligations — whichever period is longer.

• Account data: Retained for the duration of your active account, plus a minimum of 5 years after account closure to comply with financial record-keeping obligations.
• KYC documents: Retained for a minimum of 5 years from the date of submission or from the date of account closure, whichever is later, in compliance with anti-money laundering regulations.
• Transaction records: Complete deposit, withdrawal, and gaming activity records are retained for a minimum of 5 years from the date of each transaction.
• Support communications: Chat and email records are retained for 2 years from the date of the most recent interaction in the same thread, unless a longer retention period is required by an ongoing dispute or legal matter.
• Marketing consent records: Records of when you gave or withdrew consent for marketing communications are retained for the duration of your account plus 1 year, to allow us to demonstrate compliance.
• Inactive accounts: Where an account has been inactive for 12 months with no balance, anonymised usage data may be retained for analytics purposes but personally identifiable data is removed or pseudonymised.

When data is no longer required to be retained, it is securely deleted or irreversibly anonymised using industry-standard data disposal procedures.

9 Data Security Measures

111com applies a layered security architecture to protect all personal data on the Platform. The measures we have in place include:

• Encryption in transit: All data transmitted between your device and the 111com Platform is encrypted using TLS 1.2 or higher. This applies to account logins, game sessions, payment transactions, and support communications.
• Encryption at rest: Sensitive data stored on 111com servers — including KYC documents, financial records, and account credentials — is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data within 111com's internal systems is restricted on a strict need-to-know basis. Team members only access the specific data required for their role, and all access is logged and audited.
• Regular security assessments: 111com conducts regular penetration testing and security audits by independent third-party security firms to identify and remediate vulnerabilities before they can be exploited.
• Two-factor authentication: Internal systems with access to player data require two-factor authentication for all staff logins.
• Incident response: 111com maintains a documented data breach response plan. In the event of a security incident that affects player data, we will notify affected players without undue delay and take all necessary steps to contain and remediate the incident.

10 Your Rights Over Your Data

As an 111com player, you have the following rights with respect to your personal data. To exercise any of these rights, contact us at support@111com.bet with your account username and the specific right you wish to exercise. We will respond within 30 days of receiving your request.

Please note that some requests — particularly erasure requests — may not be fulfilled in full where data retention is required by law (for example, KYC and financial records). In such cases we will explain exactly what can and cannot be deleted and why.

11 Children and Minors

The 111com Platform is strictly for adults aged 18 and above. We do not knowingly collect personal data from anyone under 18. If you are under 18, do not attempt to register or use the Platform.

If we discover or are informed that an account belongs to a person under the age of 18, we will immediately suspend the account, delete all associated personal data to the extent permitted by law, and refund any deposits made to the payment method used, net of any amounts already wagered.

If you are a parent or guardian and you believe your child has created an account on 111com, please contact us immediately at support@111com.bet. We treat reports of underage account usage as the highest priority and will act within 24 hours of receiving a verified report.

12 Third-Party Links and Services

The 111com Platform may contain links to or integrations with third-party services — including game studios' game interfaces, payment provider portals, and customer support tools. Once you navigate to a third-party service, this Privacy Policy no longer applies and you are subject to that third party's own privacy practices.

111com selects third-party partners carefully and requires all partners to maintain appropriate data protection standards as a condition of our working relationship. However, we cannot be held responsible for the data practices of independent third parties beyond the contractual obligations we have imposed on them.

We recommend reviewing the privacy policies of any third-party services you interact with through or alongside the 111com Platform — particularly payment providers, as they maintain their own records of your transaction history in accordance with their own regulatory obligations.

13 Changes to This Privacy Policy

111com may update this Privacy Policy from time to time to reflect changes in our data practices, legal obligations, or the services we offer. When material changes are made, registered players will be notified via the email address associated with their account at least 7 days before the changes take effect.

The "Last Updated" date at the top of this page reflects the most recent revision. We encourage you to review this page periodically. Continued use of the 111com Platform after the effective date of any revised Privacy Policy constitutes your acceptance of that revision.

If you have any concerns about a proposed change to this policy, please contact us before the effective date. We welcome feedback and will explain our reasoning for any material changes.

14 Contact Us About Privacy

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data that 111com holds about you, please contact us through one of the following channels:

• Live Chat: Available 24/7 directly on the 111com Platform — click the chat icon in the bottom corner of any page. This is the fastest way to receive a response to a privacy query.
• Email: support@111com.bet — please include "Privacy Query" in the subject line and your registered username in the message body. We aim to respond to all privacy-related emails within 5 business days.

All privacy-related requests are handled by a dedicated member of our team who is trained in data protection requirements and has the authority to act on your request without unnecessary escalation delays.

We treat the security and privacy of your personal data as a fundamental obligation — not a compliance checkbox. If something in this policy is unclear, if you have a concern about how your data has been handled, or if you want to exercise any of the rights described in Section 10, please do not hesitate to reach out. 111com is committed to responding promptly and transparently to every privacy enquiry we receive.