Privacy Policy — 111pkr Platform

01 Introduction

This Privacy Policy ("Policy") describes how 111pkr ("111pkr", "we", "us", "our"), the operator of the online gaming and sports betting platform at https://111pkr.cam (the "Platform"), collects, processes, stores, shares and protects the personal data of users ("you", "your", "User") who access or register on the Platform.

111pkr is an English-language platform designed for Pakistani users, offering sports betting, cricket and PSL markets, live casino games, slots and table games with PKR currency display. In delivering these services, we necessarily collect and process certain categories of personal information, which are detailed in full in this Policy.

This Policy should be read alongside our Terms & Conditions and our Responsible Gambling Policy, both of which form part of your agreement with 111pkr.

02 Definitions

The following terms carry specific meanings within this Privacy Policy:

• "Personal Data" means any information that identifies or can reasonably be used to identify a living individual, directly or indirectly — including name, email address, date of birth, device identifier and payment details.
• "Processing" means any operation performed on Personal Data, including collection, storage, use, disclosure, deletion and any other handling of the data.
• "Data Controller" means the entity that determines the purposes and means of processing Personal Data — in this context, 111pkr.
• "Data Processor" means a third party that processes Personal Data on behalf of the Data Controller, under instruction and contractual obligation.
• "Cookies" means small text files placed on your device by the Platform to store session information, preferences and analytics data.
• "KYC" means Know Your Customer — the identity verification process under which users provide documentary evidence of identity and address.
• "AML" means Anti-Money Laundering — regulatory requirements relating to the detection and prevention of financial crime, which necessitate certain data collection and monitoring activities.

03 Data We Collect

111pkr collects the following categories of personal data:

04 How We Collect Your Data

111pkr collects personal data through the following means:

• Direct submission: When you complete the registration form, submit KYC documents, contact support or update your account settings, you provide data directly to us.
• Automated collection: Our Platform automatically records Technical Data (IP address, device identifiers, browser information) each time you access the site. This data is collected via server logs and, where cookies are enabled, through browser-based tracking.
• Payment processors: When you make a deposit or request a withdrawal, our payment processing partners transmit relevant transaction and payment method data to us in order to complete the transaction.
• Identity verification providers: Third-party KYC service providers may return identity verification results to us as part of the account verification process.
• Responsible gambling tools: When you set deposit limits, session limits or self-exclusion preferences, that data is recorded and acted upon by our responsible gambling systems.

05 Data Processing

111pkr processes your personal data for the following specific purposes:

• Account creation and management: To register your account, authenticate your identity, maintain your account settings and communicate account-related notices.
• Service delivery: To enable sports betting, casino games, live dealer play, PSL and cricket market access, and all other Platform features available to registered users.
• Payment processing: To facilitate deposits and withdrawals through the payment methods available in the Cashier, including those familiar to Pakistani users such as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank and Bank Alfalah (availability to be confirmed in the Cashier). Payment provider names are referenced as contextual guidance only — 111pkr does not claim endorsement or affiliation.
• KYC & AML compliance: To verify user identity, detect and prevent fraud, money laundering and other financial crime, and to comply with applicable regulatory requirements.
• Responsible gambling: To implement and monitor deposit limits, loss limits, self-exclusion instructions and session controls set by the user or required by our responsible gambling obligations.
• Customer support: To respond to support queries, resolve complaints and maintain records of interactions for quality assurance and dispute resolution purposes.
• Legal compliance: To meet obligations imposed by applicable laws, regulations and licensing conditions, including record-keeping requirements.
• Platform improvement: To analyse aggregated, anonymised usage patterns in order to improve the Platform's design, performance and user experience.
• Marketing communications: Where you have provided explicit consent, to send you promotional offers, bonus notifications and platform updates. You may withdraw consent at any time via your account settings.

06 Legal Basis for Processing

111pkr processes your personal data on one or more of the following legal bases, depending on the purpose of the processing:

• Contractual necessity: Processing required to fulfil our contractual obligations to you — including account operation, game provision and payment processing.
• Legal obligation: Processing required to comply with applicable law — including KYC, AML and record-keeping requirements imposed by our operating licence jurisdiction.
• Legitimate interests: Processing carried out in pursuit of our legitimate business interests — including fraud prevention, platform security, abuse detection and anonymised analytics — where those interests are not overridden by your fundamental rights.
• Consent: Processing for optional purposes — including direct marketing communications — where you have provided explicit, informed and freely given consent. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

07 Third-Party Data Sharing

111pkr does not sell your personal data. We may share personal data with third parties only in the following limited circumstances:

• Payment service providers: To process deposits and withdrawals through available payment channels. These providers act as Data Processors under contractual data processing agreements with us.
• Identity verification providers: To perform KYC checks and age verification as required by our licensing obligations. These providers receive only the data necessary to complete verification.
• Game software providers: Game content providers may receive session and wagering data necessary to deliver game functionality and enforce applicable game rules. This data is provided under strict contractual terms.
• Fraud prevention and security partners: To detect and prevent fraud, money laundering, account takeovers and other security threats, we may share relevant technical and account data with specialised security providers.
• Regulatory and legal authorities: Where required by law, court order, or regulatory instruction, we may disclose personal data to relevant governmental, regulatory or law enforcement authorities. We will notify you of such disclosures where legally permissible to do so.
• Professional advisors: Lawyers, auditors and compliance consultants may access personal data on a strictly confidential and need-to-know basis in connection with their professional services to 111pkr.

08 Cookies & Tracking Technologies

111pkr uses cookies and similar tracking technologies to operate the Platform, maintain your session, remember your preferences and analyse aggregated usage patterns. The following categories of cookies are used:

• Strictly necessary cookies: Required for the Platform to function. These cannot be disabled as they are essential to session management, security and core functionality. No consent is required for these cookies.
• Functional cookies: Store your preferences such as language settings, responsible gambling limits and display options so that they persist between sessions.
• Analytics cookies: Collect aggregated, anonymised data about how users navigate the Platform, which pages are visited most frequently and how long sessions last. This data helps us improve the Platform's design and performance.
• Marketing cookies: Used to present relevant promotional offers where you have consented to marketing communications. If you have declined marketing consent, marketing cookies are not set.

You can manage cookie preferences through your browser settings. Disabling functional or analytics cookies will not prevent you from accessing the Platform but may affect certain features and personalisation. Disabling strictly necessary cookies may prevent the Platform from operating correctly.

09 KYC & AML Data

As part of our obligations under applicable licensing and anti-money laundering requirements, 111pkr collects and verifies identity documentation from users as part of the KYC process. This typically includes:

• A valid government-issued photo ID (such as a National Identity Card, passport or driver's licence).
• Proof of address (such as a recent utility bill or bank statement).
• Proof of payment method ownership, where required to verify deposits or process withdrawals.
• Source of funds documentation, where required by applicable AML obligations for high-value transactions.

KYC data is processed solely for identity verification, fraud prevention and AML compliance purposes. It is retained for the period required by applicable law, typically five (5) years from the date of account closure, unless a longer period is required by regulatory instruction.

10 Payment Data

When you make a deposit or withdrawal on 111pkr, payment data is processed by our third-party payment service providers. 111pkr does not store full card numbers or sensitive payment credentials on its own servers. The data we retain in connection with payments includes:

• Transaction reference numbers and timestamps.
• Deposit and withdrawal amounts in PKR.
• Payment method type (e.g., mobile wallet, bank transfer) and anonymised method identifiers.
• Transaction status and any associated notes from the payment processor.

This data is retained as part of your transaction history for account management, withdrawal reconciliation, KYC and AML purposes, and to comply with applicable financial record-keeping requirements.

11 Data Retention

111pkr retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law. The following general retention periods apply:

• Active account data: Retained for the duration of the account's active status plus a post-closure period as required by applicable licensing and AML regulations (typically five years from account closure).
• KYC and identity documents: Retained for the period required by applicable law, typically five years from account closure or from the date of the relevant transaction, whichever is later.
• Transaction records: Retained for five years from the date of the transaction, or longer if required by regulatory instruction.
• Customer support records: Retained for three years from the date of the most recent interaction, unless a longer period is required for ongoing dispute resolution or regulatory compliance.
• Marketing consent records: Retained for the duration of the consent plus a reasonable period thereafter to demonstrate compliance.
• Technical and analytics data: Aggregated, anonymised analytics data may be retained indefinitely. Non-anonymised technical logs are retained for a shorter period, typically 12 months.

Upon expiry of the applicable retention period, personal data is securely deleted or permanently anonymised so that it can no longer be associated with an identifiable individual.

12 User Rights

Subject to applicable law and the conditions of our operating licence, you have the following rights in relation to your personal data held by 111pkr:

To exercise any of the above rights, please contact us at [email protected]. We will respond to verified requests within a reasonable timeframe, typically within 30 days, and will not charge a fee for handling requests in most circumstances.

13 Data Security

111pkr implements industry-standard technical and organisational security measures to protect personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include:

• TLS/SSL encryption for all data transmitted between your device and our servers.
• Restricted access controls ensuring that personal data is accessible only to authorised 111pkr personnel who require it to perform their role.
• Regular security assessments and vulnerability testing of our Platform infrastructure.
• Secure, access-controlled data storage environments.
• Documented data breach response procedures, including user notification where a breach is likely to result in high risk to your rights.

While we take all reasonable steps to protect your data, no internet-based platform can guarantee absolute security. You are responsible for keeping your own login credentials secure and for logging out of your account when using shared devices.

14 Minors

111pkr is strictly an adults-only platform. We do not knowingly collect personal data from individuals under the age of 18, or under the higher minimum age required by the operator's licence jurisdiction, whichever is greater. Age verification is a mandatory component of the registration and KYC process.

If we become aware that personal data has been collected from a minor without verifiable parental or guardian consent, we will take immediate steps to delete that data and close the associated account. If you believe that a minor has registered an account on 111pkr, please contact us immediately at [email protected].

15 International Data Transfers

111pkr operates as an international platform and some of our service providers and technology infrastructure are located outside the country in which you are accessing the Platform. As a result, your personal data may be transferred to, and processed in, countries other than your country of residence.

Where such transfers occur, 111pkr takes reasonable steps to ensure that appropriate safeguards are in place — including contractual data protection obligations on receiving parties — to provide a level of protection for your personal data that is comparable to that provided under applicable data protection law.

16 Policy Amendments

111pkr reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations or regulatory requirements. Material changes will be communicated to registered users via the email address on record or through a prominent notice on the Platform.

The "Last Updated" date at the top of this page will be revised with each update. Continued use of the Platform following the effective date of any amendment constitutes acceptance of the revised Policy.

17 Contact Us

If you have any questions, requests or concerns regarding this Privacy Policy or the handling of your personal data by 111pkr, please contact our support team:

For questions about responsible gambling tools or self-exclusion, please visit our Responsible Gambling page. For general questions about accounts, bonuses and payments, visit our FAQ page.