Privacy Policy

1. Introduction

This Privacy Policy ("Policy") describes how 111gam ("111gam", "we", "us" or "our"), operated under the domain https://111gam.cam, collects, uses, stores, shares and protects the personal data of individuals ("Users", "you" or "your") who access or use the 111gam platform, including its website, mobile interface and associated services.

This Policy is incorporated into and must be read alongside our Terms & Conditions and Responsible Gambling Policy. By registering an account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and consent to the data practices described herein.

111gam is committed to handling personal data responsibly and in accordance with applicable data protection standards in the jurisdictions where it operates. We apply privacy principles of transparency, purpose limitation, data minimisation, accuracy, storage limitation, integrity and confidentiality across all data processing activities.

2. Definitions

• "Personal Data" means any information that identifies or could reasonably identify a living individual, directly or in combination with other data held by 111gam.
• "Processing" means any operation performed on Personal Data, including collection, recording, storage, use, disclosure, erasure or destruction.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, 111gam.
• "Data Processor" means any third party that processes Personal Data on behalf of and under the instructions of 111gam.
• "KYC Data" means identity and age verification documents collected for Know Your Customer compliance, including CNIC, passport and proof-of-address materials.
• "Cookies" means small text files placed on your device by the Platform to enable functionality, analytics and personalisation.
• "Sensitive Personal Data" means a sub-category of Personal Data that warrants heightened protection, including financial data, identity documents and information about health or gambling behaviour.

3. Data We Collect

111gam collects the following categories of personal data, as applicable to the context of your use:

3.1 Registration & Account Data

• Full legal name
• Date of birth (for age verification)
• Email address
• Username and encrypted password
• Country and city of residence (e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan, Peshawar)
• Mobile phone number (where provided)
• Preferred currency (e.g., PKR)

3.2 Identity Verification (KYC) Data

• Copies of government-issued identity documents (CNIC, passport)
• Proof of address documentation
• Selfie or liveness-check images submitted through the secure verification portal

3.3 Financial & Transaction Data

• Deposit and withdrawal history, including amounts in PKR or other currencies
• Payment method identifiers (e.g., masked card numbers, wallet references) — note that full payment credentials are processed by the payment provider, not stored directly by 111gam
• Transaction timestamps and processing status

3.4 Betting & Gaming Activity Data

• Bets placed, stakes, outcomes and game history
• Sports and game category preferences
• Bonus and promotional activity
• Responsible gambling tool usage (deposit limits set, self-exclusion requests)

3.5 Technical & Device Data

• IP address and approximate geolocation
• Device type, operating system and browser version
• Session logs, page interaction data and error reports
• Cookie identifiers and similar tracking technologies

3.6 Communications Data

• Support tickets, live-chat transcripts and email correspondence
• Survey responses and feedback submissions
• Marketing preferences and opt-in/opt-out records

4. How We Collect Your Data

We collect personal data through the following means:

• Directly from you — during registration, KYC submission, deposit and withdrawal requests, and when you contact support.
• Automatically — through cookies, server logs and analytics tools when you browse or interact with the Platform.
• From third-party service providers — including payment processors, identity verification services, fraud-detection tools and sports-data providers, each operating under their own privacy frameworks.
• From publicly available sources — where permitted for fraud prevention or due-diligence purposes.

5. Data Processing & Legal Bases

We process your personal data only where a valid legal basis exists. The primary bases we rely on are:

6. How We Use Your Information

111gam uses your personal data for the following purposes:

1. Account management — creating, maintaining and securing your account; processing login and authentication.
2. Service delivery — enabling you to place bets, access games, claim bonuses and request withdrawals.
3. Identity and age verification — confirming you meet the minimum age requirement (18+, or higher where required) and are eligible to use the Platform.
4. Financial processing — processing deposits and withdrawals through appropriate payment channels, including verifying transactions with payment providers.
5. Fraud prevention and security — detecting, investigating and preventing fraudulent activity, money laundering and misuse of the Platform.
6. Responsible gambling — monitoring activity patterns to identify potential problem gambling behaviours and activating protective measures where appropriate.
7. Legal and regulatory compliance — fulfilling AML, KYC and record-keeping obligations under applicable licensing requirements.
8. Customer support — responding to queries submitted via Live Chat, Help Centre or email in English or Urdu.
9. Platform improvement — analysing usage data to improve navigation, performance and content quality.
10. Marketing communications — sending promotional information where you have opted in. You may opt out at any time.

7. Data Sharing & Disclosure

111gam does not sell your personal data. We share personal data only in the following limited circumstances:

• Technology and service partners: Game providers, platform infrastructure providers, payment processors and identity verification services that process data on our behalf as Data Processors under binding data processing agreements.
• Payment providers: Transaction data is shared with payment processors to facilitate deposits and withdrawals. References to providers such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are as familiar Pakistani payment references — these providers process data under their own privacy policies and do not endorse 111gam.
• Regulatory and law-enforcement authorities: Where we are legally required to disclose personal data in response to a valid court order, regulatory request or law enforcement inquiry.
• Business transfers: In the event of a merger, acquisition or sale of assets, user data may be transferred as part of that transaction, subject to the same or equivalent privacy protections.
• Fraud-prevention networks: Where sharing with industry fraud-prevention databases is necessary to protect the Platform and its users.

8. Cookies & Tracking Technologies

111gam uses cookies and similar tracking technologies to enable core Platform functionality, maintain your session state, analyse usage patterns and, where you have consented, to personalise content and deliver relevant promotional information.

8.1 Types of Cookies We Use

• Strictly Necessary Cookies: Essential for the Platform to function. These cannot be disabled without breaking core features such as login and session management.
• Analytical / Performance Cookies: Collect anonymised data about how users interact with the Platform to help us improve usability and performance. Used only with your consent where required.
• Functionality Cookies: Remember your preferences such as language, currency (PKR) and responsible gambling settings across sessions.
• Marketing Cookies: Used only where you have provided explicit consent to receive tailored promotional information. You may withdraw consent at any time.

You can manage or delete cookies through your browser settings at any time. Disabling certain cookies may limit Platform functionality.

9. International Data Transfers

111gam's infrastructure and service partners may be located in multiple jurisdictions. Where personal data is transferred outside of the jurisdiction in which it was collected, we apply appropriate safeguards — such as contractual clauses, equivalent data protection standards or other lawful transfer mechanisms — to ensure your data remains protected to a standard consistent with this Policy.

Pakistani users should be aware that data may be processed on servers located outside Pakistan. We take reasonable steps to ensure that any such transfers are conducted under terms that provide equivalent protection to those described in this Policy.

10. Data Retention

We retain personal data for as long as your account remains active and for a reasonable period thereafter, in accordance with the following general principles:

• Account and transaction records: Retained for a minimum period required by the applicable licensing and AML regulatory framework — typically five years from the date of account closure or the last transaction, whichever is later.
• KYC documentation: Retained for the period required by AML compliance obligations, following the closure or verification of the relevant account.
• Communications and support records: Retained for a period sufficient to resolve disputes and maintain service quality records, typically up to three years.
• Marketing and consent records: Retained for as long as necessary to demonstrate compliance with consent obligations.

Upon expiry of the applicable retention period, personal data is securely deleted or anonymised such that it can no longer be attributed to an identifiable individual.

11. Data Security

111gam implements a range of technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include:

• TLS (Transport Layer Security) encryption for all data transmitted between your device and our Platform.
• Encryption at rest for sensitive personal data, including financial records and KYC documents.
• Role-based access controls ensuring that only authorised personnel with a demonstrated operational need can access personal data.
• Regular security assessments and vulnerability testing.
• Two-factor authentication (2FA) support for user accounts.

12. User Rights

Subject to applicable law and any overriding legal obligations (such as AML record-keeping requirements), you have the following rights in relation to your personal data held by 111gam:

• Right of Access: You may request a copy of the personal data we hold about you.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where we no longer have a legal basis for retaining it.
• Right to Restrict Processing: You may request that we limit processing of your personal data in certain circumstances.
• Right to Data Portability: Where processing is based on consent or contract and carried out by automated means, you may request a machine-readable copy of your personal data.
• Right to Object: You may object to processing based on legitimate interests, including direct marketing.
• Right to Withdraw Consent: Where processing is based on your consent (e.g., marketing emails), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of these rights, please contact our support team through Live Chat or by email at [email protected] (plain text — not a clickable link). We aim to respond to all valid requests within 30 days of receipt.

13. Minors & Age Restrictions

The 111gam Platform is strictly intended for individuals aged 18 years or older, or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect personal data from persons below the applicable minimum age.

If we become aware that personal data has been collected from an underage individual, we will take immediate steps to delete such data and close the relevant account. If you are a parent or guardian and believe that a minor has registered on the Platform using your details or their own, please contact us immediately at the address provided in Section 16.

14. Pakistani Users — Specific Notice

111gam serves English-speaking users across Pakistan, including cities such as Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan and Peshawar. The following points are particularly relevant for users based in Pakistan:

• 111gam does not hold or claim a Pakistan gambling license and does not represent that its services comply with or are authorised under Pakistani law, including the Prevention of Gambling Act, 1977.
• Personal data processed by 111gam may be stored and handled on servers located outside Pakistan. By using the Platform, Pakistani users acknowledge this international processing.
• References to payment providers such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah are made purely as examples of familiar Pakistani payment options. These providers operate under their own independent privacy policies and do not endorse 111gam or any gambling activity.
• Users in Pakistan are responsible for understanding their rights and obligations under applicable Pakistani data-protection legislation, which continues to develop.

15. Changes to This Policy

111gam reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, legal obligations or operational structure. Where changes are material, we will provide reasonable notice by email to the registered address on your Account or by displaying a prominent notice on the Platform.

The "Last Updated" date at the top of this page indicates when the most recent revision was made. Continued use of the Platform following the effective date of any revision constitutes your acknowledgement of the updated Policy.

16. Contact Us

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

• Live Chat: Available directly on the Platform during operating hours.
• Help Centre: Accessible 24/7 via the Platform's Help section for self-service privacy queries.
• Email: [email protected] (plain text — not a clickable link). Please include "Privacy Request" in the subject line for fastest routing.

English-language support is available as standard. Urdu-language assistance is available upon request for Pakistani users.