x111e Privacy Policy — How We Handle Your Personal Data

1. Introduction

This Privacy Policy ("Policy") describes how x111e ("x111e", "we", "us", "our"), the operator of the online gaming and sports betting platform at x111e.org ("Platform"), collects, uses, stores, shares, and protects personal data relating to registered users, website visitors, and other individuals who interact with the x111e Platform ("you", "your", "User").

x111e is committed to handling personal data responsibly and transparently. This Policy applies to all personal data collected through x111e.org and any related applications, communications, and services, including data provided by users located in Pakistan and other regions.

By registering an account with x111e, making a deposit, or continuing to use the Platform after this Policy has been published or updated, you acknowledge that you have read and understood this Privacy Policy and consent to the data practices described herein.

2. Data Controller

x111e is the data controller responsible for personal data collected and processed through the Platform. x111e operates under an internationally recognised gaming licence and is subject to the data protection obligations imposed by the laws of its licensing jurisdiction.

If you have any questions or concerns about how x111e processes your personal data, or wish to exercise any of your data rights, you may contact our Data Protection team at any time using the details set out in Section 15 of this Policy.

3. Data We Collect

x111e collects the following categories of personal data from users of the Platform:

3.1 Identity & Contact Data

• Full legal name
• Date of birth
• Computerised National Identity Card (CNIC) number (for Pakistani users)
• Residential address, city, and province (e.g., Karachi, Lahore, Islamabad, Faisalabad)
• Email address
• Mobile phone number
• Nationality and country of residence

3.2 Financial Data

• Payment method details (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, Raast account references)
• Deposit and withdrawal history
• Transaction amounts in PKR and other currencies
• Crypto wallet addresses where applicable (e.g., USDT TRC20)
• Bank account or card details used for Visa / Mastercard transactions

3.3 Account & Gaming Data

• x111e username and account ID
• Betting history, game play history, and wagering patterns
• Bonus claims, promotion usage, and loyalty programme activity
• Responsible gaming settings (deposit limits, self-exclusion status, etc.)
• Account correspondence with x111e support

3.4 Technical & Usage Data

• IP address and approximate geographic location
• Device type, operating system, and browser information
• Pages visited, session duration, and navigation patterns on x111e.org
• Login timestamps and session logs
• Cookies and similar tracking technologies (see Section 10)

3.5 Verification Documents

As part of our Know Your Customer (KYC) and Anti-Money Laundering (AML) obligations under our international gaming licence, x111e may request copies of identity documents including your CNIC, passport, utility bills, bank statements, or payment method screenshots to verify your identity and source of funds prior to processing withdrawals.

4. How We Collect Your Data

x111e collects personal data through the following means:

• Direct provision: Information you provide when registering your x111e account, completing KYC verification, making deposits or withdrawals, contacting support, or participating in promotions.
• Automated collection: Technical and usage data collected automatically when you visit or interact with x111e.org, including via cookies, server logs, and analytics tools.
• Third-party sources: Identity verification agencies, fraud prevention services, payment processors, and regulatory databases where necessary to comply with our legal obligations.
• Game providers: Aggregated gaming activity data shared with x111e by licensed third-party game studios whose products are available on the Platform.

5. How We Use Your Data

x111e uses the personal data it collects for the following purposes:

Purpose	Data Used
Account registration and management	Identity, contact, account data
Identity verification (KYC) and fraud prevention	Identity, financial, verification documents
Processing deposits and withdrawals	Financial, identity data
Providing and improving gaming services	Account, gaming, technical data
Responsible gaming monitoring and enforcement	Gaming, account, identity data
Customer support and dispute resolution	Identity, account, correspondence data
Regulatory compliance and AML reporting	Identity, financial, verification documents
Personalised promotions and bonus offers	Gaming, account, contact data
Platform analytics and performance improvement	Technical and usage data
Security monitoring and abuse prevention	Technical, account, identity data

6. Legal Basis for Processing

x111e processes your personal data on one or more of the following legal bases depending on the purpose of processing:

• Contractual necessity: Processing required to create and manage your x111e account, process transactions, and deliver the services you have requested.
• Legal obligation: Processing required to comply with applicable laws, including KYC and AML requirements imposed by our gaming licence and regulatory obligations.
• Legitimate interests: Processing necessary for x111e's legitimate business interests, including fraud prevention, platform security, abuse detection, and service improvement, where those interests are not overridden by your data protection rights.
• Consent: Processing based on your explicit consent, such as the use of non-essential cookies or the sending of marketing communications. You may withdraw your consent at any time without affecting the lawfulness of prior processing.

7. Data Sharing & Disclosure

x111e does not sell, rent, or otherwise commercially exploit your personal data to third parties. x111e may share your personal data with the following categories of recipients strictly on a need-to-know basis:

• Payment processors and banking partners: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, Raast, and card scheme processors, solely to facilitate your deposit and withdrawal requests.
• Identity verification providers: Third-party KYC and AML service providers engaged to verify your identity and screen against regulatory watchlists, as required by our gaming licence.
• Game software providers: Licensed studios such as Evolution Gaming, Pragmatic Play, and others whose games are integrated on the x111e Platform, to the extent required for game delivery and audit purposes.
• Regulatory and law enforcement authorities: Where x111e is legally required to disclose information to a gaming regulator, financial intelligence unit, or law enforcement agency in connection with its regulatory or legal obligations.
• Fraud prevention and security services: Third-party providers engaged to detect and prevent fraud, money laundering, and other prohibited activity on the Platform.
• IT infrastructure and cloud service providers: Hosting, data storage, and technical support providers engaged by x111e to operate and maintain the Platform, subject to strict data processing agreements.

All third parties with whom x111e shares personal data are contractually required to handle that data in accordance with applicable data protection law and x111e's privacy standards. x111e does not authorise any third party to use your personal data for their own independent marketing or commercial purposes.

8. Data Retention

x111e retains personal data for as long as is necessary to fulfil the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting obligations. The following general retention periods apply:

• Active account data: Retained throughout the period your x111e account remains open and active.
• KYC and identity verification documents: Retained for a minimum of five (5) years from the date of account closure, in accordance with AML regulatory requirements.
• Transaction records: Retained for a minimum of five (5) years from the date of each transaction.
• Support correspondence: Retained for three (3) years from the date of resolution of the relevant query or complaint.
• Technical and usage data: Typically retained for up to thirteen (13) months in aggregate analytics form.

Upon expiry of the applicable retention period, x111e will securely delete or anonymise your personal data so that it can no longer be associated with you as an identifiable individual.

9. Data Security

x111e implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, disclosure, or destruction. These measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and x111e servers;
• Encryption at rest for all sensitive personal and financial data stored on x111e infrastructure;
• Role-based access controls ensuring that x111e staff can only access personal data where strictly necessary for their role;
• Regular penetration testing and vulnerability assessments of the x111e Platform;
• Two-factor authentication options available to all registered x111e users;
• Continuous monitoring of x111e systems for suspicious activity, intrusion attempts, and data anomalies;
• Staff training on data protection obligations and secure data handling practices.

10. Cookies & Tracking Technologies

x111e uses cookies and similar tracking technologies (such as web beacons and local storage) on x111e.org to make the Platform function correctly, improve user experience, and gather anonymised analytics data. The following categories of cookies are used:

• Strictly necessary cookies: Essential for the Platform to operate. These enable core functions including user authentication, session management, and security features. These cookies cannot be disabled without impairing Platform functionality.
• Functional cookies: Used to remember your preferences, language settings, and personalisation choices on x111e.org to provide a more tailored experience.
• Analytics cookies: Used to collect anonymised information about how visitors use x111e.org, including pages visited, time spent, and navigation paths, in order to improve the Platform. No personally identifiable information is collected through analytics cookies.
• Marketing cookies: Used to deliver relevant promotional content and track the effectiveness of x111e marketing campaigns. These cookies are only placed with your consent.

You can manage or disable non-essential cookies at any time through your browser settings. Please note that disabling certain cookies may affect the functionality of the x111e Platform. For full details on managing cookies in your browser, refer to your browser's help documentation.

11. Your Data Rights

Subject to applicable law and certain exceptions related to our legal and regulatory obligations, you have the following rights regarding your personal data held by x111e:

• Right of access: You have the right to request a copy of the personal data x111e holds about you.
• Right to rectification: You have the right to request that inaccurate or incomplete personal data is corrected. You can update many account details directly within your x111e account settings.
• Right to erasure: You have the right to request deletion of your personal data where it is no longer necessary for the purposes for which it was collected, subject to x111e's legal and regulatory retention obligations.
• Right to restriction of processing: You have the right to request that x111e restricts the processing of your personal data in certain circumstances, for example while a rectification request is being resolved.
• Right to data portability: You have the right to receive a copy of personal data you have provided to x111e in a structured, commonly used, machine-readable format.
• Right to object: You have the right to object to x111e processing your personal data on the basis of legitimate interests, including for direct marketing purposes.
• Right to withdraw consent: Where processing is based on your consent, you have the right to withdraw that consent at any time without affecting the lawfulness of processing carried out before withdrawal.

To exercise any of these rights, please contact x111e's support team via live chat or by emailing [email protected]. x111e will respond to all valid data rights requests within thirty (30) days of receipt. In complex cases this period may be extended by a further two months, in which case x111e will notify you of the extension and the reasons for it.

12. Minors & Age Restriction

The x111e Platform is strictly intended for users who are 21 years of age or older. x111e does not knowingly collect personal data from individuals under the age of 21. If x111e becomes aware that personal data has been collected from a person under 21 years of age, that account will be immediately suspended and all associated personal data will be deleted or anonymised, subject to any legal retention obligations.

If you are a parent or guardian and believe that a minor has provided personal information to x111e, please contact our support team immediately at [email protected] so that appropriate action can be taken without delay.

13. International Data Transfers

x111e operates internationally and may transfer your personal data to countries outside of Pakistan and the European Economic Area in the course of providing its services. Where personal data is transferred to a country that does not provide an equivalent level of data protection, x111e will ensure that appropriate safeguards are in place, such as standard contractual clauses approved by relevant data protection authorities, to protect your personal data during and after the transfer.

By using the x111e Platform, you acknowledge and consent to the transfer of your personal data outside your country of residence in accordance with this Policy and the safeguards described herein.

14. Changes to This Privacy Policy

x111e reserves the right to update or modify this Privacy Policy at any time. When material changes are made, x111e will notify registered users by email or by posting a prominent notice on the Platform prior to the changes taking effect. The "Last Updated" date at the top of this document will always reflect the date of the most recent revision.

We encourage you to review this Privacy Policy periodically to stay informed about how x111e is protecting your personal data. Your continued use of the x111e Platform following the posting of any changes constitutes your acceptance of the revised Policy.

15. Contact & Complaints

If you have any questions, concerns, or complaints about x111e's data practices or this Privacy Policy, or if you wish to exercise any of your data rights, please contact the x111e Data Protection team through any of the following channels:

• Live Chat: Available 24/7 directly on the x111e Platform at x111e.org
• Email: [email protected]

x111e aims to resolve all privacy-related enquiries and complaints promptly and fairly. If you are not satisfied with x111e's response to your complaint, you may have the right to lodge a complaint with the relevant data protection supervisory authority in the jurisdiction applicable to your situation.