Privacy Policy

1Introduction

This Privacy Policy ("Policy") describes how x111a ("Platform", "Operator", "we", "us", "our") collects, uses, stores, discloses and otherwise processes the personal data of individuals ("Users", "you", "your") who access or use the x111a online gaming platform at https://x111a.cam and any associated mobile applications or digital services operated under the x111a brand.

This Policy applies to all Users regardless of location. Where you access x111a from Pakistan, please note that x111a does not hold a Pakistani government data protection or gambling license and does not represent that its data practices are regulated by any Pakistani authority. This Policy is governed by the data protection framework of x111a's operating jurisdiction.

By registering an account or continuing to use the x111a Platform, you acknowledge that you have read and understood this Privacy Policy. If you do not agree to the practices described, you must discontinue use of the Platform and may request Account closure via the support team.

2Definitions

• "Personal Data" — any information relating to an identified or identifiable natural person, including name, email address, device identifiers, IP address, financial information and gaming activity records.
• "Processing" — any operation performed on Personal Data, including collection, recording, storage, adaptation, retrieval, use, disclosure, restriction, erasure or destruction.
• "Data Controller" — the entity that determines the purposes and means of Processing Personal Data. x111a is the Data Controller for data collected through the Platform.
• "Data Processor" — a third party that Processes Personal Data on behalf of the Data Controller, such as payment processors, fraud-detection providers or cloud-infrastructure vendors.
• "Cookies" — small text files stored on your device by the Platform to facilitate functionality, remember preferences and gather analytical data.
• "KYC" — Know Your Customer — identity verification procedures requiring the submission of government-issued documents and proof of payment ownership prior to withdrawal approval.

3Data Controller

x111a acts as the Data Controller in respect of all Personal Data collected through the Platform. x111a is responsible for determining how and why your data is Processed and is accountable for ensuring that such Processing complies with the principles set out in this Policy.

Where x111a engages third-party Data Processors — for example, payment gateway providers familiar to Pakistani users as Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank or Bank Alfalah — those processors are contractually required to handle data only on x111a's documented instructions and in accordance with appropriate security and confidentiality standards.

4Data We Collect

x111a collects Personal Data through several channels, as detailed below.

4.1 Data Provided Directly by You

When you register an Account or interact with the Platform, you may provide:

• Full legal name and date of birth
• Residential address (including city — e.g., Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, Multan or Peshawar)
• Email address and phone number
• Government-issued identity documents submitted for KYC verification
• Payment method details (account names, last four digits of cards or wallet identifiers)
• Source-of-funds declarations where requested
• Support correspondence and chat transcripts

4.2 Data Collected Automatically

When you access or use the Platform, we automatically collect:

• Internet Protocol (IP) address and approximate geolocation derived therefrom
• Device type, operating system and browser information
• Session duration, pages visited and features used
• Betting and gaming activity, including stake amounts in PKR, game titles accessed and bet outcomes
• Login timestamps and authentication events
• Cookie and similar tracking technology data (see Section 7)

4.3 Data Received from Third Parties

We may receive Personal Data about you from:

• Identity verification and fraud-detection service providers
• Payment processors confirming transaction outcomes
• Responsible gambling third-party databases where self-exclusion records are maintained
• Publicly available registers used for regulatory compliance screening

5Purposes & Legal Basis for Processing

x111a processes Personal Data only where there is a lawful basis for doing so. The primary purposes and corresponding legal bases are as follows:

• Account creation and operation — necessary for the performance of the contract between x111a and the User (account services agreement).
• Identity verification (KYC) — compliance with legal obligations under anti-money-laundering and fraud-prevention requirements applicable in x111a's operating jurisdiction.
• Payment processing — necessary for the performance of the contract and to facilitate deposits and withdrawals in PKR and other currencies.
• Fraud detection and security — legitimate interests of x111a in preventing fraudulent activity, protecting Users and the Platform.
• Responsible gambling monitoring — legitimate interests and legal obligations to identify at-risk users and apply appropriate safeguards.
• Marketing communications — based on your explicit consent at the time of opt-in. You may withdraw consent at any time through account preferences or by contacting support.
• Platform analytics and improvement — legitimate interests of x111a in understanding how the Platform is used and improving the user experience for Pakistani and international users.

6Data Sharing & Disclosure

x111a does not sell your Personal Data. We may share your data with the following categories of recipients strictly for the purposes described in Section 5:

6.1 Service Providers (Data Processors)

We engage third-party service providers who process data on our behalf under contractual data-processing agreements. These include payment processing infrastructure, identity verification and fraud-detection vendors, cloud hosting and infrastructure providers, customer support tooling and email delivery services.

6.2 Regulatory and Law Enforcement Authorities

Where required by applicable law, court order or regulatory directive, x111a may disclose Personal Data to licensing authorities, law enforcement agencies, financial intelligence units or other competent public authorities. x111a will notify affected Users of such disclosures where legally permitted to do so.

6.3 Responsible Gambling Databases

Where a User activates self-exclusion on the Platform, x111a may share relevant identifiers with third-party responsible gambling registers to support cross-operator exclusion schemes operated within x111a's licensing jurisdiction, where such schemes exist and are applicable.

6.4 Business Transfers

In the event of a merger, acquisition, restructuring or sale of all or part of x111a's business, Personal Data held by the Platform may be transferred to the acquiring entity. Users will be notified of any such transfer via a platform notice or email communication prior to the transfer taking effect.

7Cookies & Similar Technologies

x111a uses cookies and similar client-side technologies to operate core Platform functionality, remember User preferences, maintain authenticated sessions and gather anonymised analytical data about Platform usage patterns.

7.1 Essential Cookies

These cookies are strictly necessary for the Platform to function. They include session-management cookies that keep you logged in and security tokens that prevent cross-site request forgery. Essential cookies cannot be disabled without disabling Platform functionality.

7.2 Analytics Cookies

With your consent, x111a may use analytics tools to collect anonymised data on how Users navigate the Platform — which game categories are most accessed, typical session durations, device types and geographic regions (at city level, e.g., Karachi, Lahore or Islamabad). This data is used in aggregate form only and is not linked to individual identifiable profiles.

7.3 Managing Cookies

You can manage or disable non-essential cookies through your browser settings. Please note that disabling cookies may affect the functionality of certain Platform features. Your browser's "Help" function will provide guidance specific to your browser version.

8Data Retention

x111a retains Personal Data only for as long as is necessary for the purposes for which it was collected, subject to any overriding legal retention obligations. The following general retention parameters apply:

• Active Account data — retained for the duration of the active account relationship and for a period thereafter as required by applicable anti-money-laundering and record-keeping obligations.
• KYC and identity documents — retained for a minimum period as mandated by the regulatory framework applicable in x111a's operating jurisdiction, typically five (5) years from account closure.
• Financial transaction records — retained for a period necessary to comply with financial record-keeping requirements, including audit and dispute-resolution purposes.
• Support communications — retained for a period sufficient to resolve ongoing disputes and meet complaint-handling obligations.
• Marketing consent records — retained for as long as your consent remains active and for a reasonable period thereafter as evidence of prior consent.

Upon expiry of the applicable retention period, Personal Data is securely deleted or anonymised in a manner that prevents re-identification.

9Data Security

x111a implements appropriate technical and organisational security measures to protect your Personal Data against unauthorised access, accidental loss, destruction or alteration. These measures include:

• TLS encryption for all data in transit between your device and the Platform
• Encrypted storage for sensitive data fields at rest
• One-way hashing of account passwords — x111a staff cannot retrieve your password in plain text
• Role-based access controls limiting internal access to Personal Data on a need-to-know basis
• Regular security assessments of the Platform infrastructure
• Two-factor authentication options for User accounts

Despite these measures, no online platform can guarantee absolute security. You are responsible for keeping your login credentials confidential and for notifying x111a immediately if you suspect unauthorised access to your Account. x111a will not be liable for losses arising from your failure to maintain adequate Account security on your own devices.

10International Data Transfers

x111a operates internationally. Your Personal Data may be transferred to and processed in countries other than your country of residence — including countries that may not provide the same level of data protection as the jurisdiction from which you access the Platform.

Where such transfers occur, x111a takes steps to ensure that appropriate safeguards are in place — including contractual protections with Data Processors in the form of standard data-protection clauses — to maintain a comparable standard of protection for your Personal Data.

11Your Rights

Subject to applicable data protection law in x111a's operating jurisdiction, registered Users hold the following rights in relation to their Personal Data. Requests should be submitted to the x111a support team using the contact details in Section 14.

x111a will respond to verified data rights requests within thirty (30) calendar days of receipt. Where a request is complex or high-volume, we may extend this period by a further sixty (60) days, in which case we will notify you of the extension and the reasons for it.

Please note that certain rights are subject to exemptions — for example, we cannot erase data that we are legally required to retain under anti-money-laundering obligations, nor data that remains necessary to resolve an active dispute.

12Minors

x111a is strictly an adults-only platform. We do not knowingly collect Personal Data from individuals under the age of 18, or the higher minimum age required by the operator's licensing jurisdiction. If you are a parent or guardian and believe that a minor has registered an Account or provided Personal Data to x111a, please contact us immediately at the email address in Section 14.

Upon receiving a verified notification that an Account belongs to a minor, x111a will promptly close the Account, delete the associated Personal Data in accordance with applicable law, and return any deposits made to the payment method of origin after identity verification of the account holder.

13Amendments to This Policy

x111a reserves the right to update this Privacy Policy at any time. Where changes are material — for example, where we introduce a new data-processing purpose or change the categories of third parties with whom we share data — we will notify registered Users via email or a prominent in-Platform notice prior to the changes taking effect.

The updated Policy will be identified by a revised "Last updated" date at the top of this page. We encourage you to review this Policy periodically. Your continued use of the Platform following notification of changes constitutes your acceptance of the updated Policy.

14Contact Us

If you have questions, concerns or requests relating to this Privacy Policy, the data x111a holds about you, or your rights under applicable data protection law, please contact us through the following channel:

For urgent data concerns — including suspected unauthorised access to your Account data or a potential data breach — please contact the x111a live chat support team directly through the Platform for immediate assistance.