111d Privacy Policy — Your Data, Your Rights

Last updated: January 2026

Introduction

This Privacy Policy ("Policy") describes how 111d ("we", "us", "our", "the Platform") collects, processes, stores, and protects the personal data of users ("you", "the Player") who access or use the 111d platform at 111d.club. This Policy forms part of the overall agreement between you and 111d and should be read alongside the Terms and Conditions and the Responsible Gaming Policy.

By registering an account on 111d, you acknowledge that you have read this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree to the terms of this Policy, you must not use the 111d platform. 111d may update this Policy periodically; the date of the most recent revision is shown at the top of this page.

What Personal Data We Collect

111d collects only the personal data that is necessary to provide you with a secure, functional, and locally relevant gaming and betting experience. The categories of data we collect are set out below:

How We Use Your Personal Data

111d uses your personal data for the following specific purposes. We do not use your data for any purpose not listed below without first obtaining your explicit consent:

• Account creation and management — to create, verify, and maintain your 111d account, including processing your KYC documentation and updating your account details when you notify us of a change.
• Payment processing — to process deposits and withdrawals via bKash, Nagad, Rocket, and Upay, and to maintain an accurate financial record of all transactions on your account.
• Security and fraud prevention — to detect, investigate, and prevent fraudulent activity, account abuse, money laundering, and any other conduct that violates our Terms and Conditions or applicable law.
• Responsible gaming — to monitor gaming patterns that may indicate problem gambling behaviour, and to apply deposit limits, time-out periods, or self-exclusion where requested or where required by our responsible gaming obligations.
• Customer support — to respond to your support queries, investigate complaints, and resolve disputes relating to your account, transactions, or gaming activity.
• Legal and regulatory compliance — to comply with applicable anti-money laundering (AML) obligations, age verification requirements, and any other legal obligations that apply to the operation of the 111d platform.

Legal Basis for Processing

111d processes your personal data on one of the following legal bases depending on the purpose of the processing:

Payments, Mobile Money, and KYC

When you make a deposit or withdrawal via bKash, Nagad, Rocket, or Upay, 111d processes the mobile number and transaction reference associated with that payment. This data is required to reconcile your account balance, confirm receipt of funds, and process outgoing payments to your verified mobile money account. Payment data is transmitted over SSL-encrypted connections and is stored in encrypted form on 111d's servers.

As part of our KYC obligations, 111d may request documentary evidence of your identity — such as a copy of your National ID card (NID) — if your account activity triggers a verification threshold or if you request a withdrawal above a specified amount. KYC documents are stored securely, accessed only by authorised personnel, and are not shared with any third party except where required by law.

Sharing Your Personal Data

111d does not sell, rent, or trade your personal data. We share personal data with third parties only in the following strictly limited circumstances:

• Payment service providers — we share transaction data with mobile money operators (bKash, Nagad, Rocket, Upay) solely for the purpose of processing your deposits and withdrawals. These providers process data under their own privacy policies and are bound by their own regulatory obligations.
• Game technology providers — game studios such as Evolution Gaming, Pragmatic Play, Ezugi, Microgaming, and Spribe receive session data necessary to deliver their games to your device. This data is limited to what is technically required and does not include your financial or identity details.
• Legal and regulatory authorities — if required by applicable law, a court order, or a request from a competent regulatory or law enforcement authority, 111d will disclose the minimum amount of personal data necessary to comply with that legal obligation.
• Fraud prevention services — anonymised or pseudonymised risk signals may be shared with fraud detection partners to identify and block known fraudulent patterns. These partners do not receive your name, mobile number, or financial details in identifiable form.

In all cases where 111d shares data with a third party, we require that third party to maintain appropriate technical and organisational security measures for the data and to use the data only for the specific purpose for which it was shared.

Cookies and Tracking Technologies

111d uses cookies and similar tracking technologies (including local storage and session storage) on its platform. Cookies are small text files stored on your device that help the platform function correctly, remember your session, and detect unusual activity that may indicate a security threat.

111d uses only the cookies necessary to operate the platform securely. We do not use advertising cookies, retargeting pixels, or third-party analytics trackers that share your browsing behaviour with external advertising networks. You may disable cookies in your mobile browser settings, but doing so may prevent some features of the 111d platform from working correctly — in particular, your session may not be maintained between pages.

Data Security

111d implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These measures include SSL/TLS encryption for all data transmitted between your device and the 111d platform, encryption at rest for all financial data and identity documents, access controls limiting data access to authorised personnel on a need-to-know basis, and regular security assessments of the platform's infrastructure.

Data Retention

111d retains your personal data only for as long as it is necessary for the purpose for which it was collected. The specific retention periods we apply are as follows: account data (name, mobile number, KYC documents) is retained for the lifetime of your account and for a minimum of five years after account closure to comply with anti-money laundering record-keeping obligations; financial transaction records are retained for a minimum of five years from the date of the transaction; support communications are retained for two years from the date of the communication.

When the applicable retention period expires and there is no ongoing legal obligation or legitimate business reason to retain your data further, 111d will securely delete or anonymise your personal data. Anonymised aggregate data (from which you cannot be individually identified) may be retained indefinitely for statistical and platform improvement purposes.

Your Rights Over Your Personal Data

You have the following rights in relation to the personal data that 111d holds about you. To exercise any of these rights, contact 111d support via the email address shown in the footer:

• Right of access — you may request a copy of the personal data that 111d holds about you. We will provide this within a reasonable timeframe and at no charge for a first request in any 12-month period.
• Right of rectification — if you believe that any personal data we hold about you is inaccurate or incomplete, you may request that we correct or complete it. We will action any valid rectification request promptly.
• Right to erasure — you may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, where you withdraw consent (where consent was the legal basis), or where we have no legitimate overriding reason to retain it. Note that this right is subject to our legal retention obligations — we cannot delete data that we are required by law to keep.
• Right to restrict processing — you may request that we restrict the processing of your personal data in certain circumstances, for example while a rectification request is being assessed, or where you contest the legal basis for our processing.
• Right to data portability — where processing is based on your consent or on contractual necessity and is carried out by automated means, you may request that we provide your personal data in a structured, commonly used, machine-readable format so that you can transfer it to another service provider.

111d will respond to all valid data rights requests within 30 days of receipt. Where a request is complex or where we receive a high volume of requests, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it. We will not charge a fee for handling data rights requests unless a request is manifestly unfounded or repetitive.

Protection of Minors

111d is strictly a platform for adults aged 21 and above. We do not knowingly collect personal data from persons under the age of 21. If you are a parent or guardian and you believe that a minor has registered an account on 111d using false age information, please contact 111d support immediately via the email address in the footer. Upon receiving credible notification that an account belongs to a minor, 111d will immediately close the account, void any balance, and permanently delete the personal data associated with that account to the extent permitted by our legal retention obligations.

Changes to This Privacy Policy

111d reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or improvements to the 111d platform. When we make a material change to this Policy, we will update the "Last updated" date at the top of this page and, where practical, notify registered users via their registered mobile number. Your continued use of the 111d platform after a revised Policy has been published constitutes your acceptance of the updated terms. If you do not agree with any change to this Policy, you must stop using the platform and may request account closure by contacting 111d support.

Contact Us About Your Privacy

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, or want to raise a concern about how 111d has handled your personal data, please contact the 111d support team via the email address shown in the footer of every page on this site. The support team is available 24 hours a day, 7 days a week, in Bangladesh Standard Time (BST, UTC+6). When contacting us about a privacy matter, please include your account username and a clear description of your query so that we can identify your account and respond accurately and efficiently.