111kb Privacy Policy

1. Introduction

1.1 111kb is committed to protecting the privacy and personal data of all players and visitors. This Policy applies to all personal data collected through the 111kb website, mobile browser interface, customer support channels, and any other interaction you have with the 111kb platform.

1.2 We recognise that privacy is of particular importance to our Pakistani user base. 111kb processes personal data with the minimum necessary scope, retains it only for as long as required, and does not monetise player data through third-party advertising networks.

1.3 This Policy is effective as of June 2026 and supersedes all previous versions. The most current version is always available at https://111kb.club/privacy-policy.

2. Data Controller

2.1 For the purposes of applicable data protection law, 111kb is the data controller in respect of personal data collected via the 111kb platform. As data controller, 111kb determines the purposes and means of processing your personal data.

2.2 If you have any questions about how 111kb processes your personal data, or wish to exercise any of your data rights, please contact our support team via live chat on the platform or at the email address provided in Section 15 of this Policy.

3. Data We Collect

3.1 111kb collects the following categories of personal data:

Identity Data

• Full legal name as provided during registration or KYC verification.
• Date of birth (used to verify minimum age of 18 years).
• Government-issued identity document details (CNIC or equivalent), collected as part of KYC where required.

Contact Data

• Email address registered on the 111kb account.
• Pakistani mobile number registered on the 111kb account.
• Correspondence records from support interactions via live chat or email.

Financial Data

• Transaction history (deposits, withdrawals, bonuses) denominated in PKR.
• Payment method identifiers (e.g., JazzCash account reference, bank name) — full payment credentials are not stored by 111kb.

Technical Data

• IP address and approximate geolocation data at time of login.
• Device type, browser type, and operating system.
• Session timestamps and login history.

Usage Data

• Pages visited on the 111kb platform and navigation patterns.
• Game sessions played, bet history, and casino activity logs.
• Interaction with promotional materials and bonus offers.

4. How We Collect Your Data

4.1 111kb collects personal data through the following means:

• Direct submission: Data you provide when registering an account, completing KYC, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you access the 111kb platform, including via cookies, server logs, and session tracking.
• Third-party processors: Identity and payment verification data provided by KYC service providers and payment processors as part of account verification and transaction processing.

5. How We Use Your Data

5.1 111kb processes your personal data for the following purposes:

• To create, maintain, and manage your 111kb account.
• To process deposits and withdrawals via JazzCash, Easypaisa, HBL, UBL, Meezan Bank, Bank Alfalah, and other accepted payment methods.
• To verify your identity and age (18+) in compliance with KYC obligations.
• To detect, investigate, and prevent fraud, money laundering, and prohibited conduct.
• To provide customer support and respond to your queries and complaints.
• To personalise your platform experience and deliver relevant promotional offers where permitted.
• To comply with applicable legal and regulatory obligations, including licensing conditions.
• To monitor responsible gaming indicators and provide appropriate tools and interventions where applicable.
• To analyse platform performance, improve services, and conduct internal audits.

6. Legal Basis for Processing

6.1 111kb processes your personal data on the following legal bases:

• Contractual necessity: Processing required to perform the contract between you and 111kb (account management, payment processing, game provision).
• Legal obligation: Processing required to comply with applicable law, including KYC, anti-money laundering, and licensing regulations.
• Legitimate interests: Processing for fraud prevention, platform security, and service improvement, where these interests are not overridden by your privacy rights.
• Consent: Processing for direct marketing communications, where you have provided explicit consent. You may withdraw consent at any time.

7. Data Sharing & Third Parties

7.1 111kb does not sell, rent, or trade your personal data. We share data only in the following limited circumstances:

• Payment processors: JazzCash, Easypaisa, and other payment providers receive transaction data necessary to process your deposits and withdrawals.
• KYC & identity verification providers: Third-party identity verification services receive the minimum data required to complete verification checks.
• Game content providers: Casino game providers (e.g., Pragmatic Play, PG Soft) receive session data necessary to deliver game services. These providers operate under data processing agreements with 111kb.
• Regulatory and law enforcement authorities: 111kb will disclose personal data when required by applicable law, court order, or regulatory authority.
• Analytics providers: Anonymised and aggregated usage data may be shared with analytics service providers for platform improvement purposes.

7.2 All third-party service providers engaged by 111kb are bound by contractual data protection obligations and are prohibited from using your data for any purpose beyond the specific service they provide to 111kb.

8. Data Retention

8.1 111kb retains personal data only for as long as necessary to fulfil the purposes for which it was collected, comply with legal obligations, and resolve disputes.

8.2 Account data is retained for the duration of the account's active life and for a minimum of five (5) years following account closure, in accordance with anti-money laundering record-keeping requirements applicable to licensed gambling operators.

8.3 Technical and usage data is retained for a maximum of twenty-four (24) months. Session logs may be retained for shorter periods depending on storage capacity and operational requirements.

8.4 Upon expiry of applicable retention periods, personal data is securely deleted or anonymised in accordance with 111kb's data destruction procedures.

9. Data Security

9.1 111kb implements technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• 256-bit SSL/TLS encryption on all data in transit between your device and the 111kb platform.
• Encryption of sensitive data at rest on 111kb servers.
• Bcrypt hashing of account passwords — plain-text passwords are never stored.
• Role-based access controls limiting staff access to personal data on a need-to-know basis.
• Regular security assessments and penetration testing of the 111kb platform.
• Two-factor authentication available for all player accounts.

9.2 Despite these measures, no internet transmission is entirely secure. 111kb cannot guarantee the absolute security of data transmitted to the platform. You use the platform at your own risk in respect of data transmission security.

9.3 In the event of a data breach that is likely to result in a high risk to your rights and freedoms, 111kb will notify affected users without undue delay and take immediate steps to contain and remediate the breach.

10. Cookies & Tracking Technologies

10.1 The 111kb platform uses cookies and similar technologies for the following purposes:

• Essential cookies: Required for core platform functionality including maintaining your login session and security tokens. These cannot be disabled without impairing platform use.
• Functional cookies: Store your preferences such as language settings and game display options to improve your experience on 111kb.
• Analytics cookies: Anonymised data used to understand how players navigate the 111kb platform, which pages are most visited, and where technical issues may arise.

10.2 111kb does not use third-party advertising or cross-site tracking cookies. You may manage cookie preferences through your browser settings. Disabling essential cookies will impact your ability to use the 111kb platform.

11. Your Data Rights

11.1 Subject to applicable law, you have the following rights in relation to personal data held by 111kb:

• Right of access: Request a copy of the personal data 111kb holds about you.
• Right to rectification: Request correction of inaccurate or incomplete personal data.
• Right to erasure: Request deletion of your personal data where it is no longer necessary, subject to legal retention obligations.
• Right to restriction: Request that 111kb restricts processing of your data in certain circumstances.
• Right to data portability: Request transfer of your data in a structured, machine-readable format.
• Right to object: Object to processing based on legitimate interests, including direct marketing.
• Right to withdraw consent: Where processing is based on consent, withdraw it at any time without affecting prior processing.

11.2 To exercise any of these rights, please contact 111kb's support team via live chat or at [email protected]. Requests will be actioned within thirty (30) days of receipt, subject to identity verification.

12. Children's Privacy

12.1 The 111kb platform is strictly for adults aged 18 years and above. 111kb does not knowingly collect personal data from individuals under the age of 18. If we become aware that personal data has been collected from a minor, we will immediately delete such data and close the relevant account.

12.2 If you believe that a minor has provided personal data to 111kb, please contact us at [email protected] so we can take appropriate action.

13. International Data Transfers

13.1 As an internationally licensed online gaming platform, 111kb may transfer personal data to service providers and infrastructure located outside Pakistan. Where such transfers occur, 111kb ensures that appropriate safeguards are in place to protect your data in accordance with applicable data protection standards.

13.2 By using the 111kb platform, you consent to the transfer of your personal data as described in this section, subject to the protections outlined in this Policy.

14. Updates to This Privacy Policy

14.1 111kb reserves the right to update this Privacy Policy at any time. Material changes will be communicated to registered users via email or a prominent notice on the 111kb platform prior to taking effect.

14.2 Continued use of the 111kb platform following notification of changes to this Policy constitutes your acceptance of the revised Policy. The current version and effective date are always displayed at the top of this page.

15. Contact & Data Requests

For privacy-related enquiries, data access requests, or to exercise any of your data rights, please contact the 111kb data privacy team through the following channels:

• Live Chat: Available 24/7 directly on the 111kb platform. Average response under 5 minutes.
• Email: [email protected] (displayed as plain text — not a clickable link)

Please include your registered email address and a clear description of your request. 111kb will verify your identity before actioning any data request and will respond within thirty (30) days.