111gam Privacy Policy

111gam operates as Pakistan's premier online casino and sports betting platform, serving players across Karachi, Lahore, Islamabad, Faisalabad, and beyond. In the course of providing our gaming services — including cricket betting, live casino, slot games, and the 111gam VIP loyalty program — we necessarily collect and process certain personal data about the individuals who use our platform.

We recognise that your personal data belongs to you, and that you have every right to understand precisely how it is handled. This Privacy Policy is written in clear, accessible language so that every 111gam player, regardless of technical background, can fully understand our data practices. We have deliberately avoided vague, overly broad language; every data category and processing purpose described in this policy is genuine and specific to 111gam's operations.

By registering for an 111gam account, you acknowledge that you have read and understood this Privacy Policy and that you consent to the processing of your personal data as described herein. If at any point you do not agree with any provision of this policy, you should cease use of the 111gam platform and contact our support team to arrange account closure and data deletion where applicable.

For the purposes of this Privacy Policy, 111gam acts as the data controller in respect of the personal data of all registered players and platform visitors. As data controller, 111gam determines the purposes and means of processing your personal data and bears responsibility for ensuring that processing is carried out lawfully, fairly, and transparently in accordance with applicable data protection legislation.

Where 111gam engages third-party service providers to process data on its behalf — for example, KYC verification partners, payment processors, or fraud prevention services — those providers act as data processors under 111gam's instructions and are bound by data processing agreements that impose equivalent data protection obligations. 111gam remains responsible for the protection of your data throughout the processing chain.

111gam collects only the personal data that is necessary for one or more of the purposes described in Section 5 of this policy. The following table summarises the categories of personal data we collect and a brief explanation of why each category is required:

111gam does not knowingly collect sensitive special-category personal data such as biometric data, health information, racial or ethnic origin, political opinions, or religious beliefs. If any such data is incidentally submitted to 111gam (for example, if a player voluntarily includes it in a support message), it will not be processed beyond what is strictly necessary to respond to the query and will not be retained as a distinct data category.

111gam collects personal data through a combination of direct collection, automated collection, and third-party sourcing. The primary collection channels are as follows:

• Direct Collection: Information you provide during registration, KYC verification, payment transactions, support interactions, and survey or promotion participation. This is the largest category of data collected by 111gam and represents information you actively and voluntarily submit.
• Automated Collection: Technical and usage data is collected automatically as you interact with the 111gam platform via cookies, log files, and session tracking technology. This data is collected passively without requiring any direct input from you. Full details of automated collection are covered in Section 9 of this policy.
• Third-Party Sources: In certain cases, 111gam receives personal data about you from third parties. This includes identity verification data from KYC service providers, fraud risk signals from anti-fraud networks, and payment confirmation data from payment processors such as JazzCash and EasyPaisa. Data received from third parties is handled with the same protections as data collected directly from you.
• Device and Network Data: Your device's IP address, browser fingerprint, and network characteristics are automatically recorded when you access the 111gam platform. This information is used primarily for security monitoring and geographic access control.

111gam does not purchase personal data lists or engage in any data collection practices that involve accessing your personal data from sources without a legitimate legal basis for sharing. We do not scrape social media profiles or use any covert data collection methods.

111gam processes your personal data only where there is a valid legal basis for doing so. The following table outlines the specific purposes for which 111gam processes personal data and the corresponding legal basis in each case:

• Account Registration and Management: Processing is necessary for the performance of the contract between you and 111gam (our Terms and Conditions). Without this processing, we cannot provide you with an 111gam account.
• Identity and Age Verification (KYC): Processing is necessary for compliance with legal obligations applicable to online gaming platforms, including anti-money laundering (AML) regulations and age verification requirements. 111gam is required to verify that all players are at least 21 years of age before allowing withdrawal of funds.
• Deposit and Withdrawal Processing: Processing is necessary for performance of the contract and for compliance with financial transaction regulations.
• Fraud Prevention and Security Monitoring: Processing is in the legitimate interests of 111gam and its players to prevent fraudulent activity, unauthorised account access, and financial crime. This interest is not overridden by your privacy interests given the significant harm that fraud and financial crime causes to all platform users.
• Customer Support: Processing is necessary for performance of the contract and in 111gam's legitimate interest to provide effective support services.
• Responsible Gaming Monitoring: Processing is in 111gam's legitimate interest to identify players who may be exhibiting problem gambling behaviours and to offer appropriate tools and support. This processing is carried out in the best interests of affected players.
• Marketing Communications: Processing is carried out on the basis of your explicit consent. You may withdraw this consent at any time. Withdrawal of marketing consent does not affect the lawfulness of prior processing.
• Platform Analytics and Improvement: Processing is in 111gam's legitimate interest to maintain and improve the quality of the platform and gaming experience. Anonymised or aggregated analytics data is used for this purpose wherever possible.
• Legal Compliance and Regulatory Reporting: Processing is necessary to comply with applicable laws, regulatory requirements, court orders, and law enforcement requests.

111gam does not sell, rent, lease, or otherwise transfer your personal data to any third party for their independent marketing or commercial purposes. Personal data is shared only in the limited circumstances described below, and only to the extent strictly necessary for the relevant purpose:

• KYC and Identity Verification Partners: We share identity documents and personal details with certified KYC service providers to verify your identity and age as required. These providers process data under our instruction and are contractually prohibited from using your data for their own purposes.
• Payment Processors: Transaction data is shared with JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Allied Bank, SadaPay, NayaPay, and USDT network processors as necessary to process deposits and withdrawals. Each processor is subject to its own privacy and data security standards.
• Fraud Prevention Networks: Anonymised or pseudonymised risk signals may be shared with industry fraud prevention networks to protect the integrity of the platform and prevent the use of stolen financial credentials.
• Game Software Providers: Game session data (but not full identity or payment data) is shared with 111gam's certified game software providers as technically necessary to deliver the games you play and to resolve technical disputes.
• Legal and Regulatory Authorities: We will disclose personal data to law enforcement, regulatory bodies, or courts where we are legally required to do so or where disclosure is necessary to protect the rights, safety, or property of 111gam or other users.
• Corporate Transactions: In the event of a merger, acquisition, or sale of all or part of 111gam's business, personal data may be transferred to the relevant acquiring entity, subject to equivalent data protection commitments.

Given the global nature of online gaming infrastructure, some of the third-party service providers used by 111gam — including cloud hosting providers, KYC platforms, and game software providers — may process data in jurisdictions outside Pakistan. Where such international transfers occur, 111gam ensures that appropriate safeguards are in place to protect your personal data to a standard equivalent to that provided under this Privacy Policy.

Safeguards employed by 111gam for international data transfers include: contractual data processing agreements with standard data protection clauses; transfers only to jurisdictions that maintain adequate data protection frameworks; and technical controls including encryption of data in transit and at rest.

If you would like specific information about the international transfer safeguards applicable to any particular data processing activity, please contact our support team. We will respond within 30 days with the relevant details.

111gam retains personal data for no longer than is necessary to fulfil the purpose for which it was collected, subject to any overriding legal obligation that requires retention for a longer period. The following retention periods apply:

• Account and Identity Data: Retained for the duration of the active account relationship plus a minimum of 5 years following account closure, to satisfy AML record-keeping obligations and to respond to any regulatory enquiries.
• Financial Transaction Data: Retained for a minimum of 7 years from the date of each transaction, in compliance with standard financial record-keeping requirements.
• KYC Verification Documents: Retained for 5 years following account closure or the most recent verification event, whichever is later.
• Gaming Activity Logs: Retained for 3 years from the date of each gaming session, for dispute resolution and responsible gaming monitoring purposes.
• Support Communications: Retained for 2 years from the date of the most recent interaction, for quality assurance and dispute record purposes.
• Marketing Consent Records: Retained for the duration of the consent plus 2 years following withdrawal, to evidence compliance.
• Technical and Usage Data: Retained for 12 months in identifiable form; thereafter retained in anonymised, aggregated form for analytical purposes with no defined expiry.

On expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where deletion is not immediately practical due to backup or archiving processes, the data is isolated from active processing systems pending secure deletion at the next scheduled cycle.

The 111gam platform uses cookies and similar tracking technologies to ensure the platform functions correctly, to remember your preferences, to maintain session security, and to analyse how the platform is used. This section explains the types of cookies used and how you can manage your preferences.

• Strictly Necessary Cookies: These cookies are essential for the platform to function. They include session authentication cookies, security tokens, and load balancing cookies. These cookies cannot be disabled without breaking core platform functionality.
• Functional Cookies: These cookies remember your preferences such as language settings, display preferences, and last visited game categories. They improve your experience but are not strictly necessary.
• Analytics Cookies: These cookies collect anonymised data about how players use the platform, including pages visited, time spent, and navigation paths. This data helps 111gam identify areas for improvement. Analytics cookies are activated only with your consent.
• Security Cookies: Cookies used for device fingerprinting, anomaly detection, and bot prevention. These cookies help protect your account against unauthorised access.

You may manage your cookie preferences at any time via the Cookie Settings panel accessible from the footer of the 111gam platform. Please note that disabling functional or analytics cookies may affect your experience but will not prevent you from accessing core platform features. Strictly necessary and security cookies cannot be disabled.

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

• 256-bit SSL/TLS Encryption: All data transmitted between your browser or app and 111gam's servers is encrypted in transit using industry-standard SSL/TLS protocols.
• Encrypted Data at Rest: Sensitive personal data, including identity documents and financial data, is stored in encrypted form. Encryption keys are managed under strict access control procedures.
• Access Controls: Access to personal data within 111gam's systems is restricted to authorised personnel on a strict need-to-know basis. All internal access events are logged and auditable.
• Two-Factor Authentication: 111gam offers optional two-factor authentication (2FA) for all player accounts and requires 2FA for all administrative access to internal systems handling personal data.
• Intrusion Detection and Monitoring: 111gam's infrastructure is monitored 24/7 for anomalous activity, intrusion attempts, and data exfiltration signals. Automated alerts are configured to trigger immediate incident response.
• Penetration Testing: 111gam engages independent security specialists to conduct regular penetration testing of platform infrastructure. Critical findings are remediated within defined SLA timelines.
• Staff Training: All 111gam employees who handle personal data undergo data protection training and are subject to confidentiality obligations by contract.

While 111gam takes all commercially reasonable steps to protect your personal data, no online platform can guarantee absolute security against all threats. In the event of a data security incident that poses a risk to your rights, 111gam will notify affected players without undue delay and will take all appropriate remediation steps.

As a data subject, you hold a number of rights in relation to your personal data held by 111gam. These rights are described below. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request". We will respond within 30 calendar days of receiving a verified request.

Please note that some rights are not absolute and may be subject to limitations where 111gam has a legitimate legal reason to retain or continue processing the relevant data — for example, where retention is required by AML regulations regardless of an erasure request. In such cases, 111gam will explain the limitation clearly in its response to your request.

The 111gam platform is strictly intended for adults aged 21 years and above. 111gam does not knowingly collect, process, or retain any personal data from individuals under the age of 21. Age verification is a mandatory step in the 111gam registration and withdrawal process precisely to prevent underage access to gaming services.

If 111gam becomes aware that personal data has been collected from an individual under the age of 21 — whether through a misrepresentation during registration or by any other means — the relevant account will be immediately suspended, all data will be securely deleted beyond the minimum retention required by applicable law, and any deposits will be returned via the original payment method. No winnings accumulated on an underage account will be paid out under any circumstances.

Parents and guardians who have reason to believe that a minor in their household may have registered with 111gam are strongly encouraged to contact our support team immediately at [email protected]. 111gam will investigate and take appropriate action without delay.

111gam sends promotional and marketing communications — including bonus offers, VIP event invitations, new game announcements, and platform news — only to players who have explicitly opted in to receive such communications during registration or at a later point via account settings.

Marketing communications are delivered via email and SMS to the contact details registered on your 111gam account. The frequency and content of marketing communications vary depending on your VIP tier and stated preferences. Black Diamond and Platinum VIP tier players may receive personalised communications from their dedicated account manager.

You may opt out of marketing communications at any time by:

• Using the unsubscribe link present in every marketing email sent by 111gam
• Updating your communication preferences in the 111gam account settings panel
• Contacting 111gam customer support via live chat or at [email protected] and requesting removal from marketing lists

Opting out of marketing communications has no effect on transactional or service communications, which are sent regardless of marketing preference. Transactional communications include deposit confirmations, withdrawal notifications, security alerts, and essential account notices.

The 111gam platform may, from time to time, contain references or informational links to third-party websites or services — for example, responsible gaming resources or payment provider information pages. This Privacy Policy applies solely to data collected and processed by 111gam. It does not extend to any third-party websites, platforms, or services that may be accessible from or referenced on the 111gam platform.

111gam has no control over and accepts no responsibility for the privacy practices, data collection methods, or content of any third-party websites. If you follow a link to a third-party website, we strongly recommend that you review the privacy policy of that website before providing any personal data. The inclusion of a reference to a third-party resource on 111gam does not constitute an endorsement of that resource or its privacy practices.

111gam reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform services. When material changes are made, registered players will be notified by email to their registered address prior to the changes taking effect. Minor or clarificatory amendments may be made without specific advance notification.

The effective date at the top of this document will be updated whenever changes are made. We recommend reviewing this Privacy Policy periodically to stay informed of how 111gam protects your data. Continued use of the 111gam platform following the effective date of any revised Privacy Policy constitutes your acceptance of the updated terms.

All prior versions of this Privacy Policy are retained in 111gam's internal records and are available upon request for reference purposes.

If you have any questions, concerns, or requests relating to this Privacy Policy or to the personal data that 111gam holds about you, please contact our support team. All data protection enquiries are handled by trained staff and are escalated to the 111gam Data Protection team where appropriate.

You may reach us via the 24/7 live chat feature on the 111gam platform for general account queries, or by email for formal data protection requests. The support email address is provided below as plain text — please copy it into your email client:

Please include your registered 111gam username, registered mobile number, and a clear description of your request or query. For identity verification purposes, we may ask you to provide a copy of your CNIC or other ID document before processing a data rights request. This is a security measure to ensure we do not disclose or delete data at the request of an unauthorised third party.