x111d Privacy Policy

1.1 x111d is committed to protecting the personal data of its players. This Policy has been prepared in accordance with internationally recognised data protection principles and the obligations imposed on x111d under its international gaming licence.

1.2 This Policy applies to all personal data collected by x111d through the x111d website, any mobile-optimised version of the platform, and any communications between you and x111d including live chat, email correspondence and support interactions.

1.3 x111d operates as the data controller in respect of the personal data it holds about registered players. As data controller, x111d determines the purposes and means by which your personal data is processed and is responsible for ensuring that processing is carried out lawfully, fairly and transparently.

1.4 This Policy should be read alongside the x111d Terms & Conditions. Terms defined in the Terms & Conditions and not separately defined here carry the same meaning in this Policy.

1.5 If you have any questions about how x111d handles your personal data, or if you wish to exercise any of your data rights, please contact the x111d Data Support team at [email protected]. x111d aims to respond to all data-related queries within five (5) business days.

2.1 x111d collects personal data from you directly when you register an account, make a deposit or withdrawal, contact support, or interact with the x111d platform. We also collect certain data automatically as you use the platform. The categories of personal data x111d collects are set out in the table below.

2.2 x111d does not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, or health data, except where you voluntarily disclose health information in the context of a responsible gaming self-exclusion request. Such information is handled with the highest level of confidentiality.

2.3 Where x111d requests CNIC documentation or other identity documents for KYC purposes, copies of such documents are stored securely in encrypted form and are not used for any purpose other than identity and age verification.

3.1 x111d uses the personal data it collects for the following purposes:

• Account Management: To create, maintain and administer your x111d account, verify your identity and age, and process your x111d login sessions securely.
• Payment Processing: To process PKR deposits and withdrawals via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank and cryptocurrency, and to verify the ownership of payment methods used.
• Platform Provision: To deliver the x111d games, cricket betting markets, PSL wagering, virtual sports, slot titles and live casino services that you have requested access to.
• Regulatory Compliance: To fulfil x111d's obligations under its international gaming licence, including Anti-Money Laundering (AML) screening, Know Your Customer (KYC) requirements, and record-keeping obligations.
• Responsible Gaming: To monitor gaming activity for signs of problem gambling behaviour, enforce self-exclusion and deposit limit settings, and proactively contact players who may be showing indicators of at-risk play.
• Customer Support: To respond to your queries, resolve complaints, and maintain records of support interactions for quality assurance purposes.
• Platform Improvement: To analyse aggregated, anonymised gaming and usage data to improve the x111d platform, identify technical issues and develop new features.
• Marketing Communications: Where you have opted in to receive marketing, to send you x111d promotional offers, bonus notifications and product updates by email or SMS. You may opt out at any time via account settings or by contacting support.
• Fraud Prevention: To detect, investigate and prevent fraudulent activity, multi-account abuse, bonus abuse, money laundering and other prohibited conduct on the x111d platform.

3.2 x111d will not use your personal data for any purpose that is incompatible with the purposes listed above without first obtaining your explicit consent or establishing a separate lawful basis for the new processing activity.

4.1 x111d processes your personal data on the following legal bases:

• Contractual Necessity: Processing that is necessary to fulfil x111d's contractual obligations to you under the x111d Terms & Conditions, including operating your account, processing payments and delivering gaming services.
• Legal Obligation: Processing required to comply with applicable laws and regulatory requirements, including AML obligations, KYC verification, and responsible gaming regulatory requirements imposed under x111d's international gaming licence.
• Legitimate Interests: Processing carried out in pursuit of x111d's legitimate business interests, where those interests are not overridden by your privacy rights. This includes fraud detection, platform security, abuse prevention and platform analytics.
• Consent: Processing based on your freely given, informed and explicit consent — principally for marketing communications. You may withdraw consent for marketing at any time without affecting the lawfulness of prior processing.

4.2 Where x111d processes personal data on the basis of legitimate interests, a balancing assessment is conducted to ensure that the processing does not unduly prejudice your privacy rights. You have the right to object to processing based on legitimate interests by contacting [email protected].

5.1 x111d may share your personal data with the following categories of third parties:

• Payment Service Providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank and cryptocurrency network processors receive the minimum transaction data required to process your deposits and withdrawals.
• Identity Verification Providers: Third-party KYC service providers who assist x111d in verifying the identity and age of players, and conducting AML screening. These providers operate under strict data processing agreements.
• Game Content Providers: Third-party slot studios, live casino operators and virtual sports providers who supply games accessible through the x111d platform. These providers receive only the session and wagering data necessary to operate game rounds.
• Regulatory Authorities: x111d's licensing authority and any relevant law enforcement or regulatory body, where x111d is legally required to disclose player data in connection with an investigation, court order or regulatory obligation.
• IT and Security Providers: Cloud hosting, cybersecurity and platform infrastructure providers who process data on x111d's behalf under strict data processing agreements and who have no independent right to use that data.
• Professional Advisers: Legal counsel, auditors and compliance consultants, where disclosure is necessary in connection with x111d's legal or regulatory obligations.

5.2 x111d does not share player personal data with third-party advertising networks, data brokers, social media platforms or any other party for commercial marketing purposes.

5.3 In the event of a corporate restructuring, merger or acquisition involving x111d, player personal data may be transferred to the acquiring entity, subject to that entity assuming the same data protection obligations described in this Policy. Players will be notified of any such transfer in advance where required by law.

6.1 x111d retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting or reporting obligations that apply to x111d as an internationally licensed gaming operator.

6.2 The general retention periods applied by x111d are as follows:

• Account and Identity Data: Retained for the duration of your x111d account plus a minimum of five (5) years following account closure, to satisfy AML record-keeping requirements.
• Financial Transaction Data: Retained for a minimum of five (5) years from the date of each transaction, in accordance with financial record-keeping obligations under x111d's gaming licence.
• Gaming Activity Data: Retained for three (3) years from the date of activity, unless required for longer periods to resolve a dispute or comply with a regulatory request.
• Support Communications: Retained for two (2) years from the date of the communication, for quality assurance and dispute resolution purposes.
• Marketing Preferences: Retained until you withdraw your consent or opt out of marketing, plus a reasonable period to document your preference for compliance purposes.
• Self-Exclusion Records: Retained indefinitely to prevent re-registration by self-excluded players, even after account closure.

6.3 On expiry of the applicable retention period, x111d will securely delete or anonymise your personal data such that it can no longer be associated with you. Where anonymisation is not technically feasible within a specific dataset, data will be isolated from active processing systems until deletion is possible.

7.1 x111d uses cookies and similar technologies (including session tokens and local storage) on the x111d platform. Cookies are small text files placed on your device that help the platform function correctly and enable x111d to understand how Players interact with the site.

7.2 x111d uses the following categories of cookies:

• Strictly Necessary Cookies: Essential to the operation of the x111d platform. These cookies enable your x111d login session, remember your account preferences and ensure the security of your session. They cannot be disabled without impairing the core functionality of the platform.
• Performance & Analytics Cookies: Used to collect aggregated, anonymised information about how players use the x111d platform, including which pages are visited most frequently and where technical errors occur. This data is used solely to improve the platform.
• Functional Cookies: Used to remember your display preferences such as language, currency display and responsible gaming settings between sessions.

7.3 x111d does not use advertising cookies or third-party tracking pixels that enable external ad networks to build a profile of your browsing behaviour across other websites.

7.4 You may manage cookie preferences through your browser settings. Please be aware that disabling strictly necessary cookies will prevent you from logging in to your x111d account and may impair the security of your session. Instructions for managing cookies in the most common browsers are available through your browser's help documentation.

8.1 x111d implements a layered security architecture to protect your personal data against unauthorised access, accidental loss, destruction or alteration. The security measures applied include:

• TLS 1.3 and 256-bit SSL encryption for all data transmitted between your device and x111d servers;
• AES-256 encryption for sensitive personal data stored at rest, including CNIC document copies and payment references;
• Role-based access controls ensuring that x111d staff can only access player personal data where strictly necessary for their job function;
• Multi-factor authentication requirements for all internal x111d staff accounts with access to player data systems;
• Regular penetration testing and vulnerability assessments conducted by independent security specialists;
• Automated fraud detection and anomaly monitoring systems that flag unusual account activity in real time.

8.2 Despite these measures, no online platform can guarantee absolute security. x111d recommends that you take reasonable steps to protect your own x111d account, including using a strong unique password, enabling SMS OTP two-factor authentication, and never sharing your login credentials with any third party.

8.3 In the event of a personal data breach that is likely to result in a risk to your rights or interests, x111d will notify affected players without undue delay and will take all reasonable steps to contain and remediate the breach. x111d will also fulfil its obligations to notify the relevant regulatory authority where required.

9.1 As a registered x111d player, you have the following rights in respect of your personal data. To exercise any of these rights, contact x111d at [email protected]. x111d will respond within thirty (30) days of receiving a verified request.

10.1 The x111d platform is designed and marketed exclusively for adult players aged 21 and over. All registration flows include an age confirmation step, and x111d conducts CNIC-based age verification as part of its standard KYC process.

10.2 If you believe that a minor has registered an x111d account or accessed the platform, please notify x111d immediately at [email protected]. x111d will investigate and take appropriate action, including account suspension and referral to relevant authorities where necessary.

10.3 Parents and guardians in Pakistan are encouraged to use internet filtering and parental control tools to prevent minors from accessing online gaming platforms. x111d supports responsible access measures at the household level.

11.1 The x111d platform may contain references to third-party payment providers such as JazzCash and EasyPaisa. When you leave the x111d platform to complete a payment transaction on a third-party service, that service's own privacy policy governs how your data is handled during that interaction. x111d is not responsible for the data practices of third-party platforms.

11.2 x111d game content is provided in part by third-party studio providers who operate their own game servers. Data exchanged during a game session is governed by the data processing agreements between x111d and those providers. x111d ensures that all such agreements include adequate data protection obligations.

11.3 x111d does not endorse or take responsibility for the privacy practices of any third-party service referenced on or accessible through the x111d platform.

12.1 As an internationally licensed gaming operator serving players across Pakistan, x111d may process or store personal data on servers located outside Pakistan. Where personal data is transferred outside Pakistan, x111d takes steps to ensure that appropriate safeguards are in place to protect that data to a standard equivalent to the protections described in this Policy.

12.2 Transfers to third-party service providers in other jurisdictions are governed by data processing agreements that impose binding data protection obligations on those providers, including requirements to implement appropriate technical and organisational security measures.

12.3 By registering an x111d account, you acknowledge and consent to the transfer of your personal data to x111d's server infrastructure and service providers in accordance with this Policy.

13.1 x111d reserves the right to update or revise this Privacy Policy at any time. The most current version of this Policy will always be available at x111d.org/privacy-policy and will display the effective date at the top of the document.

13.2 Where x111d makes a material change to this Policy — for example, introducing a new category of data use or a new type of third-party sharing — x111d will provide advance notice to registered players via a notification displayed on the x111d platform or by email to your registered address, where practicable, not less than seven (7) days before the change takes effect.

13.3 Your continued use of the x111d platform following the effective date of any updated Privacy Policy constitutes your acceptance of the updated Policy. If you do not accept the updated Policy, you must cease using the platform and close your x111d account before the effective date.

13.4 This Privacy Policy was last reviewed and updated on 1 January 2026. Prior versions are available on request by contacting x111d support.

14.1 For any questions, concerns or requests relating to this Privacy Policy or the personal data x111d holds about you, please contact the x111d Data Support team through any of the following channels:

• Email: [email protected]
• Live Chat: Available 24 hours a day, 7 days a week via the x111d platform
• Response Time: x111d aims to respond to all data-related queries within 2 hours for general support and within 30 days for formal data subject access requests

14.2 When submitting a data subject access request or a request to exercise any other data right, please provide sufficient information to allow x111d to verify your identity before disclosing or acting on personal data. This may include providing your registered email address, x111d account username, and the last four digits of your registered CNIC number.

14.3 x111d will not charge a fee for processing legitimate data rights requests. However, where requests are manifestly unfounded or excessive, x111d reserves the right to charge a reasonable administrative fee or to decline to act on the request, with written reasons provided.