Privacy Policy — 111sx Platform

1. Introduction

This Privacy Policy ("Policy") sets out how 111sx ("we", "us", "our", "the Platform") collects, processes, stores, and protects the personal data of individuals ("Player", "User", "you") who access and use the 111sx website, mobile platform, gaming products, payment services, and all associated features.

111sx is committed to handling all personal data with care, transparency, and in accordance with applicable data protection standards. This Policy applies to all 111sx players across Pakistan, including those accessing the platform from Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, Multan, Peshawar, Quetta, and all other cities and regions throughout the country.

By registering an account on 111sx or otherwise using the platform, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree with this Policy, you should discontinue use of the 111sx platform immediately.

2. Data We Collect

111sx collects personal data from players through a variety of interactions with the platform. The categories of personal data we collect are set out below.

Category	Examples	When Collected
Identity Data	Full legal name, date of birth, CNIC number, passport details	Registration & KYC verification
Contact Data	Email address, phone number, residential address	Registration & account updates
Financial Data	JazzCash / EasyPaisa account references, bank account details, transaction history	Deposits, withdrawals, payment processing
Technical Data	IP address, device type, browser type, operating system, session tokens	Platform access & login
Gaming Data	Bet history, game activity, session duration, win/loss records	During gameplay & betting activity
Communication Data	Support chat transcripts, email correspondence, feedback submissions	Customer support interactions

111sx does not collect any sensitive categories of personal data — such as racial or ethnic origin, political opinions, religious beliefs, or biometric data — beyond what is strictly required for identity verification purposes under applicable anti-money laundering and know-your-customer obligations.

3. How We Use Your Data

The personal data collected by 111sx is used exclusively for the purposes described in this Policy. We do not use your data for purposes that are incompatible with those listed below without first obtaining your explicit consent.

• Account Registration and Management: To create, maintain, and administer your 111sx player account, including processing identity verification and maintaining accurate account records.
• Payment Processing: To process deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other supported Pakistani payment methods, and to maintain financial transaction records.
• Platform Security: To detect, investigate, and prevent fraudulent activity, money laundering, bonus abuse, unauthorised account access, and other prohibited activities.
• Legal and Regulatory Compliance: To comply with applicable anti-money laundering (AML) regulations, know-your-customer (KYC) requirements, and any other legal or regulatory obligations applicable to 111sx's international gaming licence.
• Customer Support: To respond to player enquiries, resolve disputes, process complaints, and deliver technical assistance through the 111sx support team.
• Responsible Gaming: To monitor player activity patterns for signs of problem gambling behaviour and to administer responsible gaming tools such as deposit limits, session reminders, and self-exclusion arrangements.
• Platform Improvement: To analyse aggregated, anonymised usage data for the purpose of improving platform performance, user experience, and the quality of gaming products available on 111sx.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to players who have provided consent to receive such communications. Players may withdraw this consent at any time.

4. Legal Basis for Processing

111sx processes personal data on one or more of the following legal bases, depending on the purpose of the processing activity:

• Contractual Necessity: Processing required to fulfil the contract between 111sx and the player — including account management, payment processing, and game delivery.
• Legal Obligation: Processing required to comply with applicable legal and regulatory requirements, including AML and KYC obligations.
• Legitimate Interests: Processing carried out in the legitimate interests of 111sx — such as platform security, fraud prevention, and service improvement — where those interests are not overridden by the player's data protection rights.
• Consent: Processing carried out on the basis of the player's explicit consent, including the sending of direct marketing communications. Consent may be withdrawn at any time without affecting the lawfulness of processing carried out before withdrawal.

5. Data Sharing and Disclosure

111sx does not sell, rent, or trade your personal data to any third party. Personal data is shared only in the limited circumstances described below, and only to the extent strictly necessary for the stated purpose.

• Payment Service Providers: Financial data is shared with payment processors — including JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank — solely for the purpose of processing player transactions.
• Identity Verification Providers: Identity and document data may be shared with licensed KYC and identity verification service providers to fulfil age and identity verification obligations.
• Technology and Hosting Providers: Technical data is processed by 111sx's infrastructure and hosting partners, who operate under strict data processing agreements and are prohibited from using player data for any purpose other than service provision.
• Gaming Software Providers: Game activity data may be shared with 111sx's licensed gaming software providers — such as Ezugi and slot game developers — to the extent required for game functionality and dispute resolution.
• Law Enforcement and Regulatory Authorities: Personal data may be disclosed to law enforcement agencies, financial intelligence units, or regulatory authorities where 111sx is legally required or compelled to do so — for example, in connection with AML reporting obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of 111sx's business assets, player data may be transferred to the acquiring entity, subject to the same data protection standards outlined in this Policy.

6. Cookies and Tracking Technologies

The 111sx platform uses cookies and similar tracking technologies to deliver core platform functionality, improve user experience, and analyse aggregate usage patterns. A cookie is a small text file placed on your device when you access the platform.

The following categories of cookies are used by 111sx:

• Essential Cookies: Required for the platform to function correctly — including session management, login authentication, and security controls. These cookies cannot be disabled without affecting core platform functionality.
• Functional Cookies: Used to remember your preferences such as language settings, display options, and previously viewed game categories to improve your experience on subsequent visits.
• Analytics Cookies: Used to collect anonymised, aggregated data about how players interact with the 111sx platform — including pages visited, session duration, and feature usage — to identify areas for improvement.
• Security Cookies: Used to detect and prevent fraudulent activity, unauthorised access attempts, and other platform security threats.

You may control your cookie preferences through your browser settings. Please note that disabling certain categories of cookies may affect the availability or performance of some 111sx platform features. 111sx does not use third-party advertising cookies or tracking pixels from external advertising networks.

7. Data Retention

111sx retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, or licensing obligations. The following general retention periods apply:

• Active Account Data: Retained for the duration of the player's active relationship with 111sx, plus a minimum period of five years following account closure to satisfy AML and regulatory record-keeping requirements.
• Financial Transaction Records: Retained for a minimum of five years from the date of the transaction in accordance with applicable financial record-keeping requirements.
• Identity Verification Documents: Retained for a minimum of five years following the completion of the verification process or the closure of the player account, whichever is later.
• Support and Communication Records: Retained for a minimum of two years from the date of the last communication, or longer where required in connection with a dispute or legal proceeding.
• Gaming Activity Records: Retained for a minimum of three years for responsible gaming monitoring purposes and dispute resolution.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised in accordance with 111sx's internal data lifecycle management procedures.

8. Your Data Rights

As a player on the 111sx platform, you hold the following rights in relation to your personal data. These rights may be exercised by contacting the 111sx support team, with requests processed within a reasonable timeframe.

• Right of Access: You have the right to request a copy of the personal data that 111sx holds about you, along with information about how that data is being used.
• Right to Rectification: You have the right to request correction of any personal data held by 111sx that is inaccurate or incomplete.
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 111sx's legal obligations to retain certain data for regulatory or licensing compliance.
• Right to Restrict Processing: You may request that 111sx restrict the processing of your personal data in certain circumstances — for example, where you contest the accuracy of the data or where processing is unlawful.
• Right to Data Portability: Where processing is carried out on the basis of consent or contract, you may request a copy of your personal data in a commonly used, machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data where that processing is carried out on the basis of 111sx's legitimate interests, including direct marketing.
• Right to Withdraw Consent: Where processing is based on your consent, you have the right to withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

9. Children and Minors

The 111sx platform is strictly intended for adults aged 21 years and over. 111sx does not knowingly collect personal data from individuals under the age of 21. If 111sx becomes aware that personal data has been collected from a minor, that data will be deleted immediately and the associated account closed.

Parents and guardians who believe that a minor may have registered on the 111sx platform should contact the support team immediately. 111sx takes underage access extremely seriously and has age verification procedures in place to prevent it. 111sx also supports the use of parental control software on shared devices to prevent underage access to gambling platforms.

10. Data Security

111sx implements a range of technical and organisational security measures to protect player data against unauthorised access, disclosure, alteration, loss, or destruction. These measures include, but are not limited to:

• SSL/TLS encryption for all data transmitted between the player's device and the 111sx platform.
• Encryption of sensitive personal data and financial records stored on 111sx's servers.
• Strict access controls limiting employee and system access to personal data on a need-to-know basis.
• Regular security audits, vulnerability assessments, and penetration testing of platform infrastructure.
• Multi-factor authentication for sensitive account actions and administrative access.
• Incident response procedures to detect, investigate, and address data security breaches promptly.

While 111sx takes all reasonable precautions to protect player data, no system can be entirely immune from security threats. Players are also responsible for maintaining the security of their own account credentials and should notify 111sx immediately if they suspect unauthorised access to their account.

11. Third-Party Services

The 111sx platform integrates with third-party service providers to deliver certain features — including payment processing, identity verification, and gaming content. These third parties are carefully selected and are required to handle player data in accordance with applicable data protection standards and the terms of their data processing agreements with 111sx.

111sx is not responsible for the privacy practices of third-party websites or services that are not operated by 111sx. Players should review the privacy policies of any third-party services they interact with independently. The 111sx platform does not include links to external websites, and any third-party integrations are limited to those necessary for core platform functionality.

12. Updates to This Privacy Policy

111sx reserves the right to update or amend this Privacy Policy at any time. Where changes are material, 111sx will make reasonable efforts to notify registered players via their registered email address or through a prominent notice on the platform prior to the changes taking effect.

The effective date displayed at the top of this Policy will be updated to reflect the date of the most recent revision. Players are encouraged to review this Policy periodically to stay informed about how 111sx protects their personal data. Continued use of the 111sx platform following publication of a revised Policy constitutes acceptance of the updated terms.

For any questions, concerns, or requests relating to this Privacy Policy or the personal data held by 111sx, please contact the support team through the 111sx Support page.