Your Privacy Matters at 111k — Here Is How We Protect It

1 Data Controller Information

For the purposes of this Privacy Policy, 111k acts as the data controller in respect of personal data collected from players who access the platform at https://111k.io. As data controller, 111k determines the purposes and means of processing your personal information and is responsible for ensuring that such processing is carried out lawfully, fairly, and transparently.

111k operates under an international offshore gaming licence and serves players located across Bangladesh, including Dhaka, Chittagong, Sylhet, Rajshahi, Khulna, Barisal, Rangpur, and Mymensingh. All data-related enquiries, access requests, and complaints should be directed to our support team using the contact details provided in Section 14 of this Policy.

2 Information We Collect

111k collects several categories of personal data in connection with your use of the platform. The specific data collected depends on the nature of your interaction with 111k.

2.1 Identity and Contact Data

• Full legal name
• Date of birth (for age verification purposes — players must be 21 or older)
• Gender (optional, for personalisation)
• Residential address
• Email address
• Mobile phone number
• National identification number or passport number (where provided for KYC)

2.2 Financial and Transaction Data

• bKash, Nagad, Rocket, or Upay mobile wallet numbers registered to your account
• Bank account numbers (Dutch-Bangla Bank, City Bank, BRAC Bank, Islami Bank, Sonali Bank) where applicable
• Deposit and withdrawal history, including transaction timestamps and amounts in BDT (৳)
• Bonus and promotional credit activity
• Account balance snapshots for regulatory record-keeping

2.3 Technical and Usage Data

• IP address and approximate geolocation (city/region level)
• Device identifiers (device type, operating system, browser type and version)
• Session start and end timestamps
• Pages and game titles accessed, including duration and frequency of play
• Clickstream data and navigation paths within the platform
• Error logs and crash reports used for platform stability diagnostics

2.4 Identity Verification Documents

Where KYC verification is required, 111k may collect copies or scans of:

• National Identity Card (NID)
• Passport (photo page)
• Utility bills or bank statements as proof of address
• Selfie photographs taken for liveness verification purposes

2.5 Communications Data

• Records of live chat conversations with the 111k support team
• Email correspondence relating to account management, disputes, or complaints
• Feedback and survey responses submitted voluntarily

3 How We Collect Your Data

111k collects personal data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting support, or participating in a promotion.
• Automated technical collection: Data collected automatically as you interact with the platform, including IP addresses, device data, and session activity logs via server-side logging and cookies.
• Payment service providers: Transaction confirmation data received from bKash, Nagad, Rocket, Upay, and partner banks to reconcile deposits and withdrawals with your 111k wallet balance.
• Identity verification partners: Where 111k uses a third-party KYC provider to verify the authenticity of identity documents, that provider may return a verified status flag and a risk score to 111k alongside the document data you submitted.
• Fraud prevention services: 111k may receive flagging data from third-party fraud prevention and anti-money-laundering screening providers where your account activity triggers an automated review.

4 How We Use Your Information

The table below summarises the primary purposes for which 111k uses your personal data, alongside the corresponding legal basis for each use:

111k will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or identifying a new lawful basis for the processing.

5 Legal Basis for Processing

111k processes personal data in accordance with recognised lawful bases for data processing. Depending on the activity, the applicable legal basis is one or more of the following:

• Contract performance: Processing is necessary to enter into or perform the contract between 111k and the player, including account creation, bet settlement, and payment processing.
• Legal obligation: Processing is required to comply with applicable laws and regulations, including anti-money-laundering obligations, age verification requirements, and record-keeping mandates under the terms of 111k's gaming licence.
• Legitimate interests: Processing is carried out for legitimate business interests, such as fraud prevention, platform security, responsible gaming monitoring, and service improvement, provided those interests are not overridden by your fundamental rights and freedoms.
• Consent: Where 111k seeks to send you marketing communications or use your data for optional personalisation features, we will first obtain your explicit consent. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 Sharing and Disclosure of Your Data

111k does not sell your personal data. We share personal information only in the following defined circumstances:

6.1 Essential Service Providers

111k engages carefully selected third-party service providers who process data on our behalf and under our instruction. These include:

• Payment processing partners (bKash, Nagad, Rocket, Upay, and partner banks) — to execute deposit and withdrawal transactions
• Identity verification and KYC providers — to authenticate player identity documents and return a verification status
• Anti-money-laundering screening services — to fulfil our compliance obligations under the gaming licence
• Cloud hosting and infrastructure providers — to store platform data securely on encrypted servers
• Customer support software providers — to manage live chat and email communications

All third-party processors are bound by data processing agreements that prohibit them from using your data for any purpose beyond the specific service they provide to 111k.

6.2 Game Providers

When you play a game powered by a third-party studio such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, or Ezugi, limited technical data (including a pseudonymous player identifier and session token) is transmitted to that provider's game server to enable the game session. No directly identifying personal data such as your name, address, or payment details is shared with game providers.

6.3 Legal and Regulatory Disclosures

111k may disclose personal data to regulatory authorities, law enforcement bodies, or other government agencies where required by law, court order, or the terms of 111k's gaming licence. Such disclosures will be limited to the minimum information necessary to comply with the applicable legal requirement.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of 111k's business, personal data held by 111k may be transferred to the acquiring entity. Players will be notified of any such transfer by email and/or a prominent notice on the platform, and the receiving entity will be bound by privacy obligations equivalent to those set out in this Policy.

7 International Data Transfers

111k is an internationally operated platform. As a result, personal data collected from players in Bangladesh may be processed on servers located in jurisdictions outside Bangladesh. Where such international transfers occur, 111k implements appropriate safeguards to ensure that your data receives a level of protection equivalent to that applied within Bangladesh, including:

• Contractual clauses with data processors that require them to apply adequate data protection standards
• Transfer only to service providers operating in jurisdictions with recognised data protection frameworks
• Encryption of all data in transit using TLS 1.2 or higher protocols regardless of the destination jurisdiction

If you have questions about the specific safeguards applied to cross-border transfers of your personal data, please contact us at [email protected].

8 Data Retention

111k retains personal data for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable legal, regulatory, or contractual obligations. The following indicative retention periods apply:

Following the expiry of the applicable retention period, personal data will be securely deleted from live systems and any backup storage within a reasonable operational timeframe, or anonymised in a manner that permanently prevents re-identification.

9 Security Measures

111k employs a layered security architecture designed to protect personal data against unauthorised access, accidental loss, alteration, or disclosure. Key security measures in place include:

• Transport Layer Security: All data transmitted between your device and 111k servers is encrypted using TLS 1.2 or TLS 1.3 protocols. The 111k platform carries a valid SSL certificate, and any attempt to access the site over an unencrypted HTTP connection is automatically redirected to HTTPS.
• Data encryption at rest: Sensitive data categories — including identity documents, payment credentials, and password hashes — are encrypted at rest using AES-256 encryption on secured servers.
• Access controls: Access to personal data within 111k systems is restricted on a strict need-to-know basis. Staff with authorised access undergo regular security training and are subject to confidentiality obligations.
• Intrusion detection and monitoring: 111k employs automated monitoring systems that flag anomalous access patterns, brute-force login attempts, and other potential security incidents for immediate review by the security team.
• Password security: Player passwords are never stored in plain text. All passwords are hashed using a one-way cryptographic algorithm before storage, meaning 111k staff cannot view or retrieve your password.
• Incident response: In the event of a data breach that is likely to result in a risk to player rights and freedoms, 111k has an incident response procedure in place to contain the breach, assess the impact, and notify affected players without undue delay.

10 Cookies and Tracking Technologies

111k uses cookies and similar tracking technologies to operate the platform, maintain session continuity, and improve the user experience. A cookie is a small text file placed on your device when you visit the 111k website.

Types of Cookies Used

• Strictly necessary cookies: Required for the platform to function. These include session authentication cookies, load-balancing tokens, and anti-fraud security cookies. These cannot be disabled without preventing access to the platform.
• Functional cookies: Store your preferences such as language settings, display options, and last-visited game categories to personalise your experience on return visits.
• Analytics cookies: Used by 111k to understand how players navigate the site, which pages are most visited, and where technical issues occur. Analytics data is aggregated and does not identify individual players.
• Performance cookies: Used to measure page load times and platform responsiveness across different devices and network conditions, helping 111k engineers prioritise improvements for players in Bangladesh.

Managing Cookies

You may configure your browser to refuse cookies or to alert you when cookies are being placed. However, disabling strictly necessary cookies will prevent you from logging in and using the 111k platform. Instructions for managing cookies in major browsers are available in each browser's help documentation. 111k does not currently support a cookie preference centre within the platform interface.

11 Your Data Rights

As a 111k player, you have the following rights in respect of your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request":

• Right of access: You may request a copy of the personal data 111k holds about you, along with information about how it is used and with whom it is shared. We will respond within 30 days of receipt of a valid request.
• Right to rectification: If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected. Updates to your account details can also be made directly from within your account settings panel.
• Right to erasure ("right to be forgotten"): You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you have withdrawn consent, or where you object to processing based on legitimate interests. This right is subject to overriding legal retention obligations (see Section 8).
• Right to restriction of processing: You may request that 111k temporarily restricts the processing of your personal data while a dispute about its accuracy or the lawfulness of its processing is resolved.
• Right to data portability: Where processing is based on your consent or a contract, you may request that 111k provides your personal data in a structured, commonly used, machine-readable format so that you can transfer it to another provider.
• Right to object: You have the right to object to processing based on legitimate interests, including profiling. You may also object to marketing communications at any time by following the unsubscribe instructions in any marketing email or by contacting our support team.
• Right to withdraw consent: Where processing is based on your consent, you may withdraw that consent at any time without affecting the lawfulness of processing that occurred before withdrawal.

12 Children and Minors

The 111k platform is strictly for adults aged 21 years and above. 111k does not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the KYC process for all registered players, and accounts found to be held by individuals under 21 will be closed immediately in accordance with our Terms & Conditions.

If a parent or guardian believes that their child under the age of 21 has submitted personal data to 111k, they should contact us immediately at [email protected]. Upon receipt of a verified request, 111k will promptly delete all personal data associated with the underage account and return any deposits to the originating payment method.

We encourage parents and guardians to make use of internet filtering and parental control tools to prevent minors from accessing gambling platforms. Further guidance on responsible gaming is available on our Responsible Gaming page.

13 Changes to This Privacy Policy

111k reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, operational requirements, or applicable law. When material changes are made, 111k will notify registered players via the email address associated with their account and/or via a prominent notice displayed on the platform for a minimum of seven (7) days prior to the changes taking effect.

The most current version of this Privacy Policy is always available at https://111k.io/privacy-policy. The "Last Updated" date at the top of the Policy indicates when the most recent revision was made. Your continued use of the 111k platform following the effective date of any amendment constitutes your acceptance of the updated Policy. If you do not agree to the revised Policy, you must close your account and cease using the platform.

14 Contact and Data Requests

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 111k handles your personal data, please reach out to us through any of the following channels:

• Email: [email protected] — include "Privacy Request" or "Data Rights Request" in the subject line for fastest routing
• Live Chat: Available 24/7 via the live chat widget on the 111k platform — ask to be connected to the Data Privacy team
• Response Times: We aim to acknowledge all privacy-related enquiries within 48 hours (Bangladesh Standard Time, UTC+6) and to provide a substantive response within 30 calendar days of receipt of a valid, verified request

If you are dissatisfied with our response to a data rights request or believe that 111k is processing your personal data unlawfully, you have the right to escalate your complaint to the relevant data protection authority in your jurisdiction or to seek legal remedies through the courts.