111x Privacy Policy — How We Handle Your Personal Data in Pakistan

1. About This Privacy Policy

111x is committed to protecting the personal information of every player who registers and uses the platform. This Privacy Policy sets out in clear, straightforward language what personal data 111x collects from Pakistani players, the purposes for which it is used, how it is stored and protected, how long it is kept, and the rights available to you regarding your own data.

We have written this policy to be genuinely readable rather than a wall of legal jargon that most people skip. That said, if anything is unclear after reading it, our support team is available 24/7 and can explain any section in Urdu or English. You can also write to us at support@111x.wine with specific questions about how your personal data is handled.

111x may update this Privacy Policy from time to time in response to legal changes, product developments, or improvements to our data practices. The "Last Updated" date at the top of this page reflects when the most recent changes were made. We will notify you of material changes via email to your registered address before they take effect.

2. What Personal Data 111x Collects

111x collects the minimum amount of data necessary to provide a functional, secure, and legal gaming service. Below is a breakdown of the categories of data we collect and the sources from which they come.

2.1 Registration Data

When you create an account on 111x, we collect: your full legal name, Pakistani mobile number, email address, date of birth, and the password you create. This data is provided directly by you during the sign-up process.

2.2 Identity Verification Data

When you are requested to complete identity verification (KYC), we collect copies of documents such as your CNIC (Computerised National Identity Card) or passport. This data is used solely to verify your identity and comply with applicable regulations.

2.3 Financial and Transaction Data

111x records all deposits, withdrawals, and bet transactions associated with your account. This includes the payment method used (Easypaisa account number, JazzCash number, bank account details, or card details), transaction amounts in PKR, timestamps, and transaction reference numbers.

2.4 Gameplay and Betting Data

We record your activity on the 111x platform, including games played, bets placed, bet outcomes, session durations, and feature interactions. This data is used to manage your account, settle bets correctly, and comply with anti-fraud and responsible gaming obligations.

2.5 Technical and Device Data

When you access 111x, we automatically collect technical data including your IP address, device type, operating system version, browser type, and connection information. This data is used to optimise platform performance and detect potential fraud or security threats.

2.6 Communications Data

If you contact 111x support via live chat or email, we retain records of those communications to ensure continuity of service and for quality assurance purposes.

3. How 111x Uses Your Personal Data

The data 111x collects is used for specific, legitimate purposes. We do not process your data in ways that are incompatible with the purposes described below.

4. Legal Basis for Processing Your Data

111x processes your personal data based on the following legal grounds depending on the purpose:

• Performance of a contract: Most of the data processing on 111x is necessary to fulfil the service you have asked us to provide — operating your account, processing your deposits and withdrawals, and settling your bets correctly.
• Legal obligation: Certain processing is required by law — in particular, identity verification under anti-money laundering regulations and the retention of transaction records for the required statutory period.
• Legitimate interest: Where 111x has a genuine, proportionate business reason to process data — such as fraud detection, platform security monitoring, and aggregated analytics for product improvement — we rely on legitimate interest, balanced against your privacy rights.
• Consent: Where we process data for marketing communications, we do so only on the basis of your explicit consent, which you can withdraw at any time.

5. Cookies and Tracking Technologies

111x uses cookies and similar tracking technologies when you visit and use 111x.wine. Cookies are small text files placed on your device that help us recognise you across sessions, maintain your login state, and understand how the platform is used.

5.1 Essential Cookies

These cookies are required for the 111x platform to function. They manage your login session, remember your preferences within a session, and protect the platform against certain types of attacks. You cannot opt out of essential cookies while using 111x.

5.2 Analytics Cookies

111x uses anonymised analytics data to understand how players navigate the platform — which pages are visited most, where players drop off, and how features are used. This data does not identify individual players and is used solely for product improvement at 111x.

5.3 Performance Cookies

These cookies help us optimise loading times and platform performance for Pakistani users, particularly those on mobile devices and variable 4G connections.

5.4 Managing Cookies

You can manage or delete cookies through your browser settings. Please note that disabling certain cookies may affect the functionality of the 111x platform, including your ability to remain logged in between page loads.

6. Who 111x Shares Your Data With

111x does not sell, rent, or share your personal data with any third party for their own commercial purposes. The only circumstances in which 111x shares your data with external parties are:

6.1 Payment Processing Partners

To process deposits and withdrawals, 111x necessarily shares relevant financial data with your chosen payment provider — Easypaisa, JazzCash, NayaPay, SadaPay, your bank (for IBFT transfers), or your card issuer. The data shared is limited to what is technically required to execute the transaction. These providers have their own privacy policies governing how they handle that data.

6.2 Identity Verification Services

Where third-party identity verification tools are used to process CNIC or passport checks, the minimum necessary data is shared with those services under strict data processing agreements that prohibit them from using your data for any purpose other than the verification requested by 111x.

6.3 Legal and Regulatory Authorities

111x will disclose personal data to law enforcement, regulatory bodies, or courts when required to do so by applicable law — for example, in connection with anti-money laundering investigations, court orders, or other lawful demands. We will tell you about any such disclosures where we are legally permitted to do so.

6.4 Internal Group Companies

111x may share data within its own corporate group for the purposes of fraud prevention, shared platform infrastructure, and consolidated KYC checks. All group entities that access your data are bound by this Privacy Policy and equivalent internal data protection standards.

7. How Long 111x Keeps Your Data

111x retains personal data only for as long as it is needed for the purpose it was collected, or as required by applicable legal obligations. The general retention periods applied on 111x are:

• Account and registration data: For the lifetime of your account, plus a minimum of 5 years after account closure — required for AML compliance.
• Transaction and financial data: Minimum 5 years from the date of each transaction — as required under financial record-keeping obligations.
• Identity verification documents: For the lifetime of your account, plus 5 years post-closure.
• Communications and support records: 2 years from the date of the communication, unless a longer period is required for an ongoing dispute.
• Technical and device data: Retained in anonymised form for up to 2 years for platform analytics.
• Marketing consent records: Until consent is withdrawn or 3 years after last engagement, whichever is earlier.

When data is no longer required for any of the above purposes, it is securely deleted or irreversibly anonymised by 111x. Data that has been fully anonymised — where no individual can be re-identified from it — may be retained indefinitely for aggregate statistical analysis.

8. How 111x Protects Your Data

Data security is treated as a core operational requirement at 111x — not an afterthought. We apply a range of technical and organisational measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure.

8.1 Technical Measures

• SSL/TLS encryption on all data in transit between your device and 111x servers.
• Encryption of sensitive data fields — including payment credentials and identity documents — at rest in our database.
• Firewalls, intrusion detection systems, and automated anomaly monitoring across all platform infrastructure.
• Multi-factor authentication for access to internal systems that handle player data.
• Regular security patching and vulnerability assessments conducted by our engineering team.

8.2 Organisational Measures

• Strict role-based access control — only staff who require access to personal data for their specific job function are granted it.
• All staff with access to player data are trained on data protection obligations and confidentiality requirements.
• Third-party service providers who process data on behalf of 111x are required to sign data processing agreements and meet equivalent security standards.
• A defined incident response plan for data breaches, including notification procedures for affected players.

8.3 Your Responsibility

While 111x takes every reasonable measure to protect your data at our end, you are responsible for keeping your account password secure and for logging out of 111x when using shared devices. Never share your 111x password with anyone, including friends, family, or anyone claiming to be from 111x support. Our team will never ask for your password.

9. Your Data Rights

As a 111x player, you have the following rights regarding your personal data. To exercise any of these rights, contact us at support@111x.wine. We will respond within 30 days of receiving your request.

10. Children and Minors

111x is strictly an adults-only platform. We do not knowingly collect personal data from anyone under 18 years of age. Our registration process requires confirmation that the user is at least 18 years old, and we conduct age verification checks on accounts where there is any indication of underage access.

If a parent or guardian believes that their child has registered an account on 111x or provided personal data to the platform, please contact us immediately at support@111x.wine. We will investigate promptly, close the account, delete the associated personal data, and reverse any financial transactions associated with the minor's account where this is technically possible.

11. Marketing Communications

111x may send you promotional emails, SMS notifications, or in-platform messages about new game launches, deposit bonuses, and other offers relevant to your account. We will only send you marketing communications if you have given your explicit consent during registration or subsequently through your account settings.

11.1 Opting Out

You can withdraw your consent for marketing communications at any time by:

• Clicking the "unsubscribe" link at the bottom of any marketing email from 111x.
• Updating your notification preferences in your 111x account settings.
• Contacting our support team at support@111x.wine and requesting removal from marketing communications.

Opting out of marketing communications will not affect transactional communications — such as bet confirmations, payment receipts, account security alerts, and support responses — which are sent regardless of marketing preference as they relate to the service you have subscribed to.

11.2 Responsible Gaming and Marketing

111x does not send promotional offers to players who have activated responsible gaming limits, cooling-off periods, or self-exclusion. If you have applied any responsible gaming tool on your 111x account, you will automatically be removed from marketing lists for the duration of the restriction.

12. Third-Party Services and External Links

The 111x platform may contain references to third-party services — such as your payment provider's interface when completing a deposit. 111x is not responsible for the privacy practices of third-party services. When you leave the 111x platform to complete a payment through Easypaisa, JazzCash, or a bank portal, you are subject to that provider's own privacy policy for the duration of that interaction.

111x does not embed social media tracking widgets or third-party advertising pixels on 111x.wine. Any links that appear within the 111x platform are exclusively to pages within 111x.wine or to necessary payment or verification services — never to external advertisers or unrelated third parties.

13. Changes to This Privacy Policy

111x may update this Privacy Policy periodically. When we make material changes — meaning changes that significantly affect how your data is processed or your rights under this policy — we will notify you by email to your registered address at least 7 days before the changes take effect.

Minor clarifications or corrections that do not affect your rights may be updated without advance notice, though the "Last Updated" date will always reflect the most recent revision. We encourage you to review this page periodically so you remain informed about how 111x handles your personal data.

Continued use of 111x after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you disagree with any changes, you should stop using 111x and may request account closure and data deletion (subject to applicable retention obligations) by contacting support@111x.wine.

14. Contact Us About Privacy

If you have any questions, concerns, or requests relating to this Privacy Policy or how 111x handles your personal data, please contact us through any of the following channels:

• Email: support@111x.wine — please include "Privacy Request" in the subject line for faster routing.
• Live Chat: Available 24/7 through the 111x platform — our team can handle privacy queries in both Urdu and English.

We aim to respond to all privacy-related enquiries within 24 hours and to resolve substantive data requests within 30 days. For formal complaints that are not resolved to your satisfaction through our support process, you may escalate by emailing support@111x.wine with the subject "Formal Privacy Complaint" and we will ensure a senior review within 5 business days.