111game Privacy Policy

111game is an online gaming and sports betting platform accessible at 111game.app, serving players across Pakistan — including Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, Multan, Peshawar, and Hyderabad — as well as international players. We are fully committed to protecting the privacy and personal data of every individual who interacts with our platform.

This Privacy Policy sets out, in plain and transparent language, what personal information 111game collects from you, why we collect it, how we use and store it, who we share it with, and what rights you have over your own data. We have written this policy to be as clear and straightforward as possible — no confusing legal jargon where it can be avoided.

This Privacy Policy should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which form part of your overall agreement with 111game. In the event of any conflict between this Privacy Policy and the Terms & Conditions regarding data matters, this Privacy Policy shall take precedence.

111game collects personal data from you in several ways — directly when you provide it during registration or account management, automatically through your use of the platform, and in some cases from third-party verification providers. The categories of personal data we collect include:

We do not collect sensitive personal data such as racial or ethnic origin, religious beliefs, political opinions, or biometric data (other than the photograph contained within CNIC or passport documents submitted for identity verification purposes).

111game processes your personal data for the following specific and legitimate purposes:

• Account management: Creating, maintaining, and managing your registered player account on the 111game platform.
• Identity verification (KYC): Verifying your identity, age (21+ requirement), and address to comply with regulatory obligations and prevent fraudulent account registrations.
• Payment processing: Facilitating deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other supported payment methods in PKR.
• Service delivery: Providing access to sports betting markets (including PSL cricket and international events), live casino, slots, and all other gaming products available on 111game.
• Fraud prevention and security: Detecting and preventing fraudulent activity, money laundering, bonus abuse, multi-accounting, and other prohibited behaviour on the platform.
• Responsible gaming: Monitoring betting patterns to identify potential problem gambling behaviour and enforcing responsible gaming tools such as deposit limits and self-exclusion.
• Customer support: Responding to queries, complaints, and requests submitted via live chat or email.
• Legal compliance: Meeting our obligations under applicable laws and regulations, including anti-money laundering (AML) and counter-terrorist financing (CTF) requirements.
• Platform improvement: Analysing anonymised usage data to improve the performance, design, and content of the 111game platform.
• Marketing communications: Sending promotional offers, bonus notifications, and platform news to players who have consented to receive marketing communications.

111game relies on the following legal bases for processing your personal data, in line with internationally recognised data protection principles:

• Contractual necessity: Processing your identity, contact, and financial data is necessary to perform the contract between you and 111game — i.e., to provide you with a functional, funded gaming account.
• Legal obligation: KYC verification, AML monitoring, and transaction record-keeping are required by applicable laws and regulations governing online gaming and financial services.
• Legitimate interests: Fraud detection, security monitoring, platform analytics, and responsible gaming oversight are carried out under 111game's legitimate interest in operating a safe, fair, and secure platform — provided that these interests do not override your fundamental rights.
• Consent: Marketing communications are sent only where you have given explicit consent. You may withdraw this consent at any time without affecting the processing carried out prior to your withdrawal.

111game does not sell or rent your personal data to any third party for commercial or marketing purposes. We may share your personal data with third parties only in the following limited circumstances:

• Payment processors: Financial data is shared with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and other payment service providers solely to process your transactions. These providers operate under their own privacy policies and applicable financial regulations.
• KYC and identity verification providers: Identity documents and personal details may be shared with regulated third-party KYC verification services to confirm your identity and age in compliance with regulatory requirements.
• IT and platform service providers: We work with trusted technology partners who provide hosting, security, analytics, and customer support infrastructure. These partners process data strictly on 111game's instructions and under appropriate data processing agreements.
• Regulatory and law enforcement authorities: We may be required by law, court order, or regulatory instruction to disclose personal data to competent authorities, including in connection with AML investigations or fraud detection.
• Corporate transactions: In the event of a merger, acquisition, or restructuring of the 111game operating entity, personal data may be transferred to the acquiring entity as part of that transaction, subject to equivalent privacy protections.

All deposits and withdrawals on 111game are denominated in Pakistani Rupees (PKR). When you make a financial transaction on the platform, the following data handling practices apply:

• 111game does not store full JazzCash wallet numbers, EasyPaisa account numbers, or complete bank account details on its own servers after a transaction is processed. Only a masked reference sufficient to identify your payment method for future transactions is retained.
• Transaction records — including amounts, timestamps, and payment method references — are retained for a minimum of five years to meet anti-money laundering regulatory requirements.
• All payment data in transit between your device and the 111game platform is encrypted using TLS 1.3 or higher.
• Withdrawals are only processed to a payment method registered in the same name as your 111game account, providing an additional layer of financial security.

111game uses cookies and similar tracking technologies to provide a functional, personalised, and secure experience on the platform. Cookies are small text files placed on your device when you visit a website. They do not harm your device and do not contain personally identifiable information on their own.

The cookies used by 111game fall into the following categories:

• Strictly necessary cookies: Essential for the platform to function — including session management, login state, and security tokens. These cannot be disabled without breaking core platform functionality.
• Functional cookies: Remember your preferences such as language settings, preferred payment methods, and display options to provide a more personalised experience.
• Analytical cookies: Allow 111game to understand how players use the platform — which pages are visited most, where players encounter issues, and how the overall flow can be improved. Data from analytical cookies is processed in aggregate and anonymised form.
• Security cookies: Help detect and prevent fraudulent activity, including bot detection, anomalous login behaviour, and suspicious transaction patterns.

You can control non-essential cookies through your browser settings. Note that disabling certain cookies may affect the functionality of the 111game platform. 111game does not use third-party advertising tracking cookies or cross-site behavioural advertising technologies.

111game retains personal data only for as long as it is needed for the purpose for which it was collected, or for as long as we are legally required to retain it. The following retention periods apply:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Anonymised data — from which you cannot be identified — may be retained indefinitely for statistical and analytical purposes.

111game implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• AES-256 encryption for all personal and financial data stored at rest in our databases.
• TLS 1.3 encryption for all data transmitted between your device and the 111game platform.
• Two-factor authentication (2FA) available for all player accounts via SMS OTP, strongly recommended for all registered players.
• Role-based access controls ensuring that internal staff can only access personal data that is necessary for their specific role — a principle of least privilege.
• Regular security audits and penetration testing of the platform's infrastructure, conducted by independent security specialists.
• Automated anomaly detection systems that flag unusual account activity, suspicious login patterns, and potential data breach indicators in real time.
• Data breach response plan — in the unlikely event of a personal data breach affecting your rights, 111game will notify affected players without undue delay in accordance with applicable notification requirements.

As a registered player on 111game, you have the following rights in relation to the personal data we hold about you. To exercise any of these rights, contact our support team via live chat or at [email protected].

• Right of access: You may request a copy of the personal data that 111game holds about you. We will respond to verified access requests within 30 days.
• Right to rectification: If any personal data held by 111game is inaccurate or incomplete, you have the right to request that it be corrected. Minor corrections (such as a misspelled name) can often be made directly through your account settings.
• Right to erasure ("right to be forgotten"): You may request deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent, or where you object to processing. Note that we may be required by law to retain certain data (e.g., financial transaction records) and cannot delete it during the applicable retention period.
• Right to restriction of processing: You may request that 111game restricts processing of your data in certain circumstances — for example, while a dispute about the accuracy of your data is resolved.
• Right to data portability: Where processing is based on your consent or on a contract, and is carried out by automated means, you may request a copy of your personal data in a structured, machine-readable format.
• Right to object: You have the right to object to processing of your personal data where it is based on legitimate interests, including profiling for responsible gaming purposes. We will assess your objection and cease processing unless we have compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.

111game is strictly an adults-only platform. Registration and use of the platform is prohibited for any person under the age of 21 years. We take our responsibility to prevent underage gambling very seriously, and age verification is a mandatory step in the account registration and KYC process.

111game does not knowingly collect personal data from individuals under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to close the account, return any deposited funds to the payment source, and permanently delete all associated personal data from our systems.

111game may send you promotional emails, SMS messages, or in-platform notifications about bonuses, new games, PSL cricket betting offers, and platform news — but only where you have given explicit consent to receive such communications during registration or at any subsequent point in your account settings.

• You can opt out of marketing communications at any time by updating your notification preferences in your 111game account settings, clicking the unsubscribe link in any marketing email, or contacting the support team directly.
• Opting out of marketing communications will not affect the delivery of transactional messages — such as deposit confirmations, withdrawal notifications, and security alerts — which are necessary for the operation of your account.
• 111game does not share your contact details with third-party marketing organisations. All promotional communications you receive will come directly from 111game.
• SMS marketing messages are sent only to the mobile number registered on your account. Reply STOP to any SMS to opt out of future SMS marketing from 111game.

111game reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, legal obligations, or platform features. When we make material changes — those that significantly affect how we use your personal data or your rights — we will notify you via email to your registered address or via an in-platform notification, with a minimum of 14 days' notice before the changes take effect.

For minor amendments, such as clarifications or corrections that do not materially affect your rights, the updated Privacy Policy will be published on this page and will take effect from the date shown in the "Last Updated" field at the top of the document. It is your responsibility to review this page periodically.

Your continued use of the 111game platform after the effective date of any updated Privacy Policy constitutes your acceptance of the revised terms. If you do not agree with the updated Privacy Policy, you should cease using the platform and may request account closure by contacting our support team.

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

• Live Chat: Available 24/7 directly on the 111game.app platform. Average response time is 3–5 minutes — the fastest way to get a response for urgent data matters.
• Email: [email protected] — for formal data rights requests, privacy complaints, or detailed queries. We aim to acknowledge all emails within 48 hours and provide a full response within 30 days.
• Languages: Our support team is able to assist in both English and Urdu, making it easy for players across Karachi, Lahore, Islamabad, Faisalabad, and beyond to communicate their privacy concerns comfortably.