111d Privacy
Policy

1. Introduction

This Privacy Policy ("Policy") describes how 111d ("we", "us", "our", "the Platform") collects, uses, stores, discloses, and protects the personal data of individuals ("you", "the Player") who access or use the 111d platform available at 111d.io and all associated services.

111d is committed to protecting the privacy of its players and handling all personal data responsibly, transparently, and in accordance with applicable data protection principles. By registering an account or using the 111d platform, you acknowledge that you have read and understood this Policy and consent to the processing of your personal data as described herein.

This Policy applies to all personal data collected through the 111d website, mobile-optimised browser experience, customer support channels, and any other interaction you have with the 111d platform. It does not apply to third-party websites or services linked from the platform, which are governed by their own privacy policies.

2. Personal Data We Collect

Depending on how you interact with the 111d platform, we may collect the following categories of personal data:

2.1 Identity and Registration Data

• Full legal name as it appears on your government-issued identification document
• Date of birth (used to verify that you are at least 21 years of age)
• Gender (optional, collected during registration)
• Nationality and country of residence
• Bangladesh National Identity Card (NID) number or passport number, as provided during KYC verification

2.2 Contact Data

• Email address
• Mobile phone number (including the number associated with bKash, Nagad, or Rocket accounts)
• Residential address, including city (e.g., Dhaka, Chittagong, Sylhet, Rajshahi), district, and postal code

2.3 Financial and Transaction Data

• Deposit and withdrawal transaction history
• Payment method details (e.g., bKash wallet number, Nagad account number, Rocket account number, bank account details for Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, Sonali Bank, or Upay)
• Account balance history
• Wagering history, game session records, and bet settlement records

2.4 Technical and Usage Data

• IP address and approximate geographic location derived from it
• Device type, operating system, browser type and version
• Pages visited, time spent on each page, clickstream data
• Session duration and login timestamps
• Error logs and crash reports

2.5 KYC and Verification Documents

• Copies of government-issued photo identification (NID, passport, or driving licence)
• Proof of address documents (utility bills, bank statements)
• Screenshots or confirmations of payment method ownership
• Any additional documentation requested during enhanced due diligence reviews

2.6 Communications Data

• Content of messages sent to the 111d support team via email or live chat
• Records of complaints and their resolution
• Survey responses and feedback submissions

3. How We Collect Your Data

111d collects personal data through the following channels:

• Direct submission: Data you provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting support, or completing any form on the platform.
• Automated collection: Technical and usage data collected automatically when you browse or interact with the 111d website, including via cookies, web beacons, and server logs.
• Third-party payment providers: Transaction confirmations and partial payment account details received from bKash, Nagad, Rocket, Upay, and banking partners as part of processing your deposit or withdrawal requests.
• Identity verification services: Confirmation of identity document validity from third-party KYC verification partners, where applicable.
• Fraud prevention services: Risk signals and fraud indicators from third-party fraud detection providers used to protect the platform and its players.

4. Purposes of Processing

111d processes personal data for the following purposes. The table below summarises the data categories used for each purpose:

5. Legal Bases for Processing

111d processes personal data on the following legal bases:

• Contractual necessity: Processing required to fulfil the agreement between you and 111d when you register an account and use platform services, including account management, transaction processing, and game delivery.
• Legitimate interests: Processing necessary for the legitimate business interests of 111d, including fraud prevention, platform security, responsible gaming monitoring, and service improvement, provided such interests are not overridden by your rights and interests.
• Legal obligation: Processing required to comply with applicable legal and regulatory obligations, including anti-money laundering (AML) requirements and identity verification mandates.
• Consent: Processing for marketing communications and non-essential cookies, where you have provided explicit consent. You may withdraw consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6. Data Sharing and Disclosure

111d does not sell your personal data. We share personal data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

6.1 Payment Processing Partners

We share transaction-relevant data with bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, and Sonali Bank for the sole purpose of processing your deposit and withdrawal requests. These partners receive only the minimum data necessary to complete the transaction.

6.2 Identity Verification Providers

Where third-party KYC verification services are used to validate identity documents, we share the relevant identity data with those providers under strict data processing agreements. These providers are prohibited from using your data for any purpose other than the verification service they are contracted to provide.

6.3 Fraud Prevention and Security Services

We may share technical and identity data with fraud detection and cybersecurity service providers to protect the platform and its players from fraud, money laundering, account takeover, and other security threats.

6.4 Game Content Providers

Game providers such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive anonymised session and wagering data necessary to render games, calculate outcomes, and resolve wager settlements. These providers do not receive personally identifiable information beyond what is technically required for game delivery.

6.5 Legal and Regulatory Authorities

111d may disclose personal data to law enforcement agencies, regulatory bodies, or courts of competent jurisdiction where required to do so by applicable law, court order, or enforceable regulatory demand.

7. Data Retention

111d 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 data: Retained for the duration of your account's active status, plus a minimum of five years following account closure to satisfy AML record-keeping obligations.
• Transaction and wagering records: Retained for a minimum of five years from the date of the transaction.
• KYC documents: Retained for a minimum of five years following account closure or the completion of the KYC process, whichever is later.
• Customer support communications: Retained for a minimum of two years from the date of the last communication in each support case.
• Technical and usage logs: Retained for up to 12 months, after which they are either deleted or anonymised for analytics purposes.

Once the applicable retention period has expired, personal data is securely deleted or irreversibly anonymised in accordance with our internal data deletion procedures.

8. Security Measures

111d implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction:

• Encryption in transit: All data transmitted between your browser and the 111d platform is encrypted using TLS 1.2 or higher (256-bit SSL). Look for the padlock icon in your browser's address bar to confirm the secure connection.
• Encryption at rest: Sensitive personal data and KYC documents stored on 111d servers are encrypted at rest using AES-256 encryption.
• Access controls: Access to player personal data is strictly role-based. Only authorised personnel with a documented business need may access player records. All access is logged and audited.
• Network security: The platform infrastructure is protected by firewalls, intrusion detection systems, and DDoS mitigation services.
• Incident response: 111d maintains a documented data breach response procedure. In the event of a confirmed breach affecting player data, affected players will be notified promptly with details of the incident and recommended protective actions.

9. Cookies and Tracking Technologies

111d uses cookies and similar tracking technologies to operate the platform effectively and deliver a consistent user experience. The categories of cookies we use are as follows:

111d does not use advertising cookies, retargeting pixels, or any third-party tracking technology that shares your browsing behaviour with external advertising networks. You may manage or delete cookies at any time through your browser's privacy settings. Disabling strictly necessary cookies may impair your ability to use the platform.

10. Your Data Rights

As a player on the 111d platform, you hold the following rights in relation to your personal data. To exercise any of these rights, contact us at [email protected] with the subject line "Data Rights Request" and your registered account username:

• Right of Access: You may request a copy of the personal data 111d holds about you at any time. We will provide this within a reasonable timeframe, typically within 30 days of receiving your request.
• Right to Rectification: If any personal data held on your account is inaccurate or incomplete, you have the right to request that it be corrected. You may also update basic contact information directly through your account settings.
• Right to Erasure: You may request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to 111d's legal retention obligations (such as AML record-keeping requirements) which may require us to retain certain data regardless of your request.
• Right to Data Portability: You may request a copy of the personal data you have provided to 111d in a structured, commonly used, machine-readable format.
• Right to Restrict Processing: In certain circumstances, you may request that 111d restrict the processing of your personal data (for example, while the accuracy of the data is being contested).
• Right to Object: You have the right to object to processing carried out on the basis of legitimate interests, including profiling. You also have an unconditional right to object to direct marketing at any time.
• Right to Withdraw Consent: Where processing is based on your consent (such as marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of any processing that took place before withdrawal.

11. Third-Party Links

The 111d platform does not contain links to third-party websites or services as a general design principle. In the event that a third-party link appears on the platform (for example, within a game provider's interface), 111d has no control over the privacy practices of that third party. We strongly recommend that you review the privacy policy of any third-party service before providing personal data to it. 111d accepts no responsibility or liability for the privacy practices of third-party websites or services.

12. Children's Privacy and Age Restriction

The 111d platform is strictly for adults aged 21 years and above. 111d does not knowingly collect personal data from any individual under the age of 21. Age verification is a mandatory step in the account registration process, and 111d applies additional identity checks where any doubt exists regarding a player's age.

If you are a parent or guardian and believe that a person under the age of 21 has registered an account on the 111d platform, please contact us immediately at [email protected]. Upon confirmation, the account will be suspended immediately, all activity will be investigated, and any balance will be handled in accordance with our underage gambling policy.

13. Updates to This Privacy Policy

111d reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform features. When material changes are made, we will update the "Last Updated" date at the top of this document and, where appropriate, notify registered players by email.

We encourage you to review this Privacy Policy periodically to remain informed of how 111d handles your personal data. Your continued use of the platform following the publication of an updated Policy constitutes your acceptance of the revised terms. If you do not agree with any changes to this Policy, you should cease using the platform and contact [email protected] to request account closure.

14. Contact Us

If you have any questions, concerns, or complaints regarding this Privacy Policy or the way in which 111d handles your personal data, please contact our data team using the following details:

• Email: [email protected] (plain text — not a clickable link)
• Subject Line: Please include "Privacy Enquiry" or "Data Rights Request" for faster routing
• Response Time: Within 24 hours on Business Days; within 48 hours on weekends and Bangladesh public holidays
• Support Hours: 24 hours a day, 7 days a week
• Language: English
• Time Zone: Bangladesh Standard Time (BST, UTC+6)

We treat all privacy enquiries seriously and aim to resolve complaints at the first point of contact wherever possible. If you are not satisfied with our response to a privacy complaint, you may have the right to escalate the matter to a supervisory authority in your jurisdiction.