111sx Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how 111sx ("the Company", "we", "us", "our"), operator of the online gaming and sports betting platform accessible at 111sx.org, collects, processes, stores, shares, and protects the personal information of individuals ("you", "Player", "User") who register for or use any service on the 111sx Platform.

This Policy applies to all users of the 111sx Platform, including visitors to the website who have not yet registered an account, registered Players based in Pakistan, and any individual whose personal data is processed by 111sx in connection with the Platform's operation. By accessing the 111sx website or creating an account, you confirm your understanding and acceptance of this Privacy Policy.

This Policy must be read alongside the 111sx Terms and Conditions and the Responsible Gaming Policy. Together, these documents form the complete framework governing your relationship with 111sx.

2 Personal Data We Collect

111sx collects personal data across several categories. The data collected depends on how you interact with the Platform — some is provided directly by you, and some is collected automatically during your use of the website.

Category	Examples of Data Collected	When Collected
Identity Data	Full legal name, date of birth, CNIC / passport number, photograph	Registration & KYC verification
Contact Data	Email address, mobile number, residential address (city, province)	Account registration
Financial Data	JazzCash / EasyPaisa account reference, bank account details, USDT wallet address, transaction history	Deposits, withdrawals, KYC
Gaming Activity Data	Wager history, game sessions, win/loss records, bonus usage, betting patterns	Ongoing platform use
Technical Data	IP address, device type, operating system, browser type, session timestamps	Each website visit
Communications Data	Live chat transcripts, support ticket content, email correspondence	When you contact support
Preference Data	Marketing opt-in status, language settings, responsible gaming limits set	Account settings & interactions

We do not intentionally collect sensitive personal data (such as health information, religious beliefs, or political opinions) unless you voluntarily provide such information in the context of a responsible gaming or self-exclusion request.

3 How We Collect Your Data

111sx collects personal data through the following means:

• Direct interactions: Information you enter when registering, completing KYC, depositing funds, submitting a support request, or updating your account profile.
• Automated technologies: Technical data collected automatically when you visit the 111sx website, including cookies, server logs, and analytics tools that record browsing behaviour, page interactions, and session duration.
• Third-party payment processors: When you deposit or withdraw using JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, or USDT TRC20, transaction confirmation data is shared with 111sx by the payment processor to verify and reconcile your account balance.
• Identity verification partners: During KYC checks, 111sx may use third-party document verification services to validate the authenticity of identity documents you submit.
• Fraud prevention and risk services: We may receive data about your device and session from fraud detection services to protect the platform from unauthorised access and financial crime.

4 Legal Basis for Processing

111sx processes your personal data on one or more of the following legal grounds:

1. Contractual necessity: Processing is necessary to fulfil our obligations to you as a registered Player under the 111sx Terms and Conditions — including account management, payment processing, and game provision.
2. Legal obligation: We are required to collect and retain certain data (particularly identity and financial data) to comply with anti-money laundering (AML) regulations, KYC requirements, and directives from our licensing authority.
3. Legitimate interests: We process certain technical and behavioural data to detect fraud, improve platform security, personalise user experience, and conduct internal analytics — provided this does not override your fundamental privacy rights.
4. Consent: Where we process your data for marketing communications or optional personalisation features, we do so on the basis of your explicit opt-in consent, which you may withdraw at any time.

5 How We Use Your Personal Data

111sx uses collected personal data for the following purposes:

• Creating, verifying, and managing your player account;
• Processing deposits and withdrawals in PKR and other accepted currencies;
• Conducting mandatory KYC and age verification to confirm you are 21 or above;
• Providing customer support via live chat and email;
• Detecting and preventing fraud, money laundering, and unauthorised account access;
• Enforcing the 111sx Terms and Conditions and Responsible Gaming Policy;
• Analysing platform usage to improve game offerings, interface design, and performance;
• Sending transactional communications (deposit confirmations, withdrawal updates, security alerts);
• Sending promotional communications, including information about bonuses and new games, where you have consented to receive marketing messages;
• Complying with applicable laws, regulations, and requests from competent regulatory or law enforcement authorities.

6 Sharing Your Personal Data

111sx does not sell, rent, or trade your personal data to any third party for commercial purposes. We share your data only in the following strictly limited circumstances:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT TRC20 wallet infrastructure providers receive transaction data necessary to process your deposits and withdrawals.
• Identity and KYC verification providers: Specialist third-party services that assist with document authentication receive the identity documents and data you submit during the verification process.
• Game software providers: Third-party game studios and live casino operators whose products are available on the 111sx Platform may receive pseudonymised session data (such as a player ID and bet amounts) to operate their games correctly.
• Fraud prevention and security services: External risk management and fraud detection providers receive technical data (device fingerprints, IP addresses, behavioural patterns) to protect the platform from abuse.
• Regulatory and legal authorities: Where required by our gaming licence or applicable law, we may disclose player data to licensing authorities, financial intelligence units, or law enforcement agencies. We will notify you of such disclosures where legally permitted to do so.
• Corporate transactions: In the event of a merger, acquisition, or restructuring of the 111sx business, player data may be transferred to the acquiring entity, subject to equivalent privacy protections.

All third-party recipients of 111sx player data are required to process that data in accordance with applicable data protection standards and are prohibited from using it for any purpose beyond that for which it was shared.

7 Cookies & Tracking Technologies

7.1 What Are Cookies

Cookies are small text files placed on your device when you visit a website. The 111sx Platform uses cookies and similar tracking technologies (such as pixel tags and local storage) to enable core functionality, remember your preferences, and analyse how players use the site.

7.2 Types of Cookies We Use

• Strictly necessary cookies: Essential for the Platform to function — including session management, login authentication, and security. These cannot be disabled without breaking the website.
• Functional cookies: Remember your language preference, account settings, and responsible gaming limits between sessions.
• Analytics cookies: Collect anonymised data about how players navigate the website (pages visited, time spent, click paths) to help us improve the Platform.
• Marketing cookies: Track whether you came to 111sx via a promotional link and help us assess the effectiveness of our campaigns. These are only active if you have consented to marketing communications.

7.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling certain cookies may impair the functionality of the 111sx Platform. For detailed instructions on managing cookies, refer to your browser's help documentation.

8 Data Retention

111sx retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to the following minimum retention periods:

• Account and identity data: Retained for a minimum of five (5) years from the date of account closure, in compliance with AML and KYC regulatory requirements applicable to our gaming licence.
• Financial transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Gaming activity logs: Retained for a minimum of three (3) years from the date of each gaming session.
• Support communications: Retained for two (2) years from the date of the last interaction, unless a longer period is required for ongoing dispute resolution.
• Technical and analytics data: Retained in anonymised or aggregated form for up to two (2) years.

Following the expiry of the applicable retention period, personal data will be securely deleted or anonymised such that it can no longer be associated with an identifiable individual.

9 Data Security

111sx implements a layered approach to data security to protect your personal information against unauthorised access, accidental loss, disclosure, or destruction. Our security measures include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the 111sx servers;
• Encrypted storage of all sensitive personal and financial data at rest;
• Role-based access controls ensuring that only authorised 111sx personnel can access player data, and only to the extent required for their specific job functions;
• Regular security audits, penetration testing, and vulnerability assessments of the Platform infrastructure;
• Two-factor authentication options available for Player accounts to add an additional layer of login security;
• Incident response protocols that include timely notification to affected players and relevant authorities in the event of a confirmed data breach.

Notwithstanding these measures, no internet-based system can guarantee absolute security. You play an important role in keeping your data safe by using a strong, unique password for your 111sx account and by never sharing your login credentials with others.

10 Your Data Rights

As a user of the 111sx Platform, you have the following rights in relation to your personal data. To exercise any of these rights, please contact our support team via live chat or by email at [email protected].

11 Children & Minors

The 111sx Platform is strictly restricted to individuals aged 21 years and above. We do not knowingly collect personal data from persons under the age of 21. If we become aware that personal data has been collected from a minor, we will take immediate steps to delete that data, close the associated account, and return any funds deposited, in accordance with our age verification procedures and responsible gaming commitments.

If you are a parent or guardian and believe that a minor has registered on the 111sx Platform, please contact our support team immediately via live chat. We take underage gambling concerns extremely seriously and will act promptly on all credible reports.

12 Cross-Border Data Transfers

The 111sx Platform operates internationally, and in the course of delivering services to Pakistani players, your personal data may be transferred to and processed in jurisdictions outside Pakistan. Such transfers occur, for example, when data is processed by our server infrastructure, shared with KYC verification partners, or transmitted to game software providers whose servers are located abroad.

111sx ensures that all cross-border transfers of personal data are conducted in a manner that affords an adequate level of protection to your information, through the use of contractual safeguards, data processing agreements, and by engaging only with third-party providers that maintain recognised data protection standards.

13 Third-Party Services & Links

The 111sx Platform may reference or integrate with third-party services, including game software providers, payment processors, and analytics tools. This Privacy Policy applies solely to data processed by 111sx directly. Third-party services operate under their own privacy policies, which 111sx does not control. We encourage you to review the privacy policies of any third-party service you interact with in connection with the 111sx Platform.

111sx is not responsible for the data practices of third-party game studios, payment gateways, or any other external service provider whose products or services are accessible through or integrated into the Platform.

14 Amendments to This Policy

111sx reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or Platform functionality. When material changes are made, we will provide advance notice to registered Players via email or via a prominent banner on the Platform website, clearly stating the effective date of the updated Policy.

The current version of this Privacy Policy, together with its effective date, is always available via the footer of the 111sx website. Continued use of the Platform following the effective date of any amended Policy constitutes your acceptance of the updated terms.

15 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 111sx processes your personal data, please get in touch through one of the following channels:

• Live Chat: Available 24/7 from within your 111sx account dashboard — fastest response for account-related data queries.
• Email: [email protected] — for formal written data access or erasure requests. Please allow up to 30 days for a full response to data rights requests.
• Coverage: Our support team serves players across Pakistan, including Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, and all other cities and regions.