x111 Privacy Policy

x111 is an internationally licensed online gaming platform accessible at x111.vu, offering cricket betting, live casino, slot games, kabaddi, and a range of other interactive gaming products to eligible players. x111 operates under a valid international gaming licence and adheres to the data protection standards required under that licensing regime.

For the purposes of this Privacy Policy, x111 acts as the data controller — meaning we determine the purposes and means by which your personal data is processed. Where we engage third-party service providers to process data on our behalf, those providers act as data processors and are bound by contractual obligations that require them to handle your data only in accordance with our instructions and this policy.

This Privacy Policy applies to all personal data collected through the x111 website, any mobile-optimised versions of the platform, and all services offered under the x111 brand. By registering an account or using any x111 services, you acknowledge that you have read and understood this policy.

x111 collects the following categories of personal data from players. We only collect data that is necessary and proportionate for the purposes described in this policy:

x111 does not collect sensitive special-category data such as racial or ethnic origin, religious beliefs, health data, or biometric identification data beyond what is strictly required for identity verification under applicable KYC regulations.

x111 collects your personal data through the following channels:

• Direct interactions: Data you actively provide when registering an account, completing KYC verification, making deposits or withdrawals, contacting customer support, or filling out any form on the x111 platform.
• Automated technologies: When you access and navigate the x111 platform, we automatically collect Technical Data and Usage Data through cookies, server logs, and similar tracking technologies. See Section 7 for full details on our cookie practices.
• Third-party KYC providers: When we perform identity and age verification, our regulated KYC partner may supply us with verification status and data matching results based on documents you have submitted to them.
• Payment processors: Payment service providers such as JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank share limited transaction confirmation data with x111 to facilitate deposits and withdrawals and to comply with AML obligations.
• Fraud prevention services: Regulated third-party fraud detection systems may share risk-scoring data with x111 to protect both the platform and our players from fraudulent activity.

x111 processes your personal data for the following specific purposes. Each purpose is tied to a lawful basis described in Section 5:

• Account registration and management: Creating and maintaining your x111 account, verifying your identity and age (21+ requirement), and ensuring only one account exists per player.
• Service delivery: Processing deposits and withdrawals, settling bets and game outcomes, crediting bonuses, and providing all gaming and betting services you use on the platform.
• Legal and regulatory compliance: Fulfilling our obligations under anti-money laundering (AML) regulations, Know Your Customer (KYC) requirements, and the conditions of our international gaming licence — including mandatory transaction monitoring and reporting of suspicious activity.
• Fraud prevention and security: Detecting, investigating, and preventing fraudulent transactions, account takeovers, multi-accounting, and other forms of abuse or prohibited conduct on the x111 platform.
• Responsible gaming: Monitoring player behaviour patterns to identify potential signs of problem gambling and to enforce self-exclusion, deposit limits, and cooling-off periods where requested or required.
• Customer support: Responding to your queries, resolving disputes, and maintaining records of communications to improve our support quality.
• Platform improvement: Analysing aggregated usage data to improve the functionality, performance, and content of x111 services. This analysis uses anonymised or pseudonymised data wherever possible.
• Direct marketing: Sending you promotional communications about x111 bonuses, new games, PSL-related offers, and platform updates — but only where you have opted in to receive such communications or where we have a legitimate interest in doing so, subject always to your right to opt out at any time.

x111 relies on the following lawful bases for processing your personal data under applicable data protection law:

• Contractual necessity: Processing required to perform our contract with you — i.e., to operate your account, process transactions, and deliver gaming services. Without this processing, x111 cannot provide its services to you.
• Legal obligation: Processing required to comply with applicable laws and regulations, including AML legislation, KYC obligations under our gaming licence conditions, and tax reporting requirements.
• Legitimate interests: Processing that is necessary for x111's legitimate business interests, where those interests are not overridden by your rights and interests. This includes fraud prevention, security monitoring, platform analytics, and certain direct marketing activities where you are an existing customer.
• Consent: Where x111 relies on your consent as the legal basis for processing — such as for opt-in marketing communications — you have the right to withdraw that consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out before the withdrawal.

x111 does not sell, rent, or trade your personal data. We share data only with the following categories of third parties, and only to the extent necessary for the purposes described in this policy:

• KYC and identity verification providers: Regulated third-party services that assist x111 in verifying player identity, age, and document authenticity as required by our gaming licence conditions.
• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and selected cryptocurrency payment networks — solely for the processing of deposits and withdrawals to and from your x111 account.
• Fraud detection and AML services: Specialist providers that analyse transaction patterns and account behaviour to detect fraud, money laundering, and other financial crime. These providers are contractually prohibited from using your data for any purpose other than the fraud and AML services they provide to x111.
• Regulatory and licensing authorities: x111's gaming licence regulator and, where required by law, financial intelligence units, tax authorities, or law enforcement agencies. Such disclosures are made only where x111 is legally compelled to do so.
• IT and infrastructure providers: Cloud hosting, data centre, cybersecurity, and platform technology providers who process data on our behalf under strict data processing agreements and who have no independent right to access or use your data.
• Customer support platforms: Third-party live chat and ticketing software used to manage and respond to support requests. Providers are bound by data processing agreements and process only the data necessary to deliver support services.

All third-party data processors engaged by x111 are required to implement appropriate technical and organisational security measures and to process data only in accordance with x111's written instructions.

x111 uses cookies and similar tracking technologies on its platform. Cookies are small text files stored on your device that help us recognise you, remember your preferences, maintain your session, and analyse how players use our platform.

x111 uses the following categories of cookies:

• Strictly necessary cookies: Essential for the platform to function. These include session cookies that keep you logged in and security cookies that protect against cross-site request forgery. These cannot be disabled without breaking core platform functionality.
• Functional cookies: Remember your preferences such as language settings, preferred deposit method, and display options to provide a more personalised experience on return visits.
• Analytics cookies: Collect aggregated, anonymised data about how players navigate and use the x111 platform. This data helps us identify technical issues and improve the user experience. x111 uses only privacy-respecting analytics that do not build cross-site profiles.
• Marketing and retargeting cookies: Used only where you have provided explicit consent. These help x111 show relevant promotional content within the x111 platform. x111 does not use third-party advertising networks or programmatic ad exchanges.

You can manage your cookie preferences at any time through your browser settings or the x111 cookie preference centre accessible from the platform footer. Note that disabling certain cookies may affect the functionality and performance of the x111 platform.

x111 takes the security of your personal data seriously and has implemented a comprehensive set of technical and organisational measures to protect your data against unauthorised access, accidental loss, destruction, or disclosure. Key security measures include:

• 256-bit SSL/TLS encryption on all data transmitted between your device and x111 servers.
• At-rest encryption for all sensitive personal and financial data stored in x111 databases.
• Role-based access controls ensuring that only authorised x111 personnel with a legitimate business need can access personal data, and only to the extent necessary for their role.
• Multi-factor authentication for all internal x111 systems that store or process personal data.
• Regular penetration testing and vulnerability assessments conducted by independent third-party security specialists.
• 24/7 security monitoring with automated alerting systems to detect and respond to anomalous activity in real time.
• Incident response procedures that ensure data breaches are identified, contained, and — where required by law — reported to the relevant regulatory authority within the required timeframe.

While x111 takes all reasonable steps to protect your personal data, no method of electronic storage or transmission over the internet is entirely secure. You also have an important role to play in keeping your account secure: choose a strong, unique password for your x111 account, enable two-factor authentication, and never share your login credentials with anyone.

x111 retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable law and our gaming licence conditions. The following retention periods apply as a general guide:

Upon expiry of the applicable retention period, x111 will securely delete or irreversibly anonymise your personal data. Anonymised data — from which you can no longer be identified — may be retained for statistical and analytical purposes indefinitely.

Subject to applicable data protection law and certain legal exceptions, you have the following rights in relation to your personal data held by x111:

• Right of access: You may request a copy of the personal data x111 holds about you. x111 will provide this within 30 days of a verified request, free of charge for the first request in any 12-month period.
• Right to rectification: If any personal data x111 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. Many details can be updated directly through your x111 account settings.
• Right to erasure ("right to be forgotten"): You may request that x111 delete your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn consent, or where you object to processing based on legitimate interests. This right is subject to exceptions where x111 is legally required to retain data.
• Right to restriction of processing: You may request that x111 restrict the processing of your data in certain circumstances — for example, while the accuracy of data is contested, or where you have objected to processing and the outcome of that objection is pending.
• Right to data portability: Where processing is based on consent or contractual necessity and is carried out by automated means, you may request that x111 provide your data in a structured, commonly used, machine-readable format.
• Right to object: You may object at any time to processing of your data based on x111's legitimate interests, including for direct marketing purposes. x111 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests.
• Right to withdraw consent: Where processing is based on consent, you may withdraw that consent at any time without affecting the lawfulness of prior processing.

To exercise any of the rights listed above, please contact x111's Data Protection Officer using the details in Section 15. x111 may need to verify your identity before processing a data rights request to protect against fraudulent claims.

As part of our registration and KYC process, x111 requires every player to provide proof of age and verify their identity. Players who cannot satisfy the 21+ age verification requirement will not be permitted to open or maintain an account, and any account found to have been opened by an underage individual will be immediately suspended and any funds returned to the verified payment source.

If you are a parent or guardian and believe that a minor in your care has created an x111 account or provided personal data to x111, please contact our support team immediately. x111 will investigate and take prompt action, including deleting any data collected from the minor and closing the account in question.

x111 supports Pakistan's broader framework for the protection of minors from exposure to gambling-related content and actively cooperates with parental control software providers and internet safety organisations where possible.

x111 operates as an internationally licensed gaming platform and, in the course of delivering its services, may transfer your personal data to countries outside of Pakistan for processing by authorised third-party service providers. Such transfers may occur in connection with cloud hosting infrastructure, KYC verification services, payment processing networks, or fraud detection systems.

x111 takes all reasonable steps to ensure that international transfers of personal data are conducted with appropriate safeguards in place. These safeguards include:

• Transferring data only to countries or organisations that provide an adequate level of data protection as recognised under applicable standards.
• Implementing standard contractual clauses or binding corporate rules with international data processors that require them to process data to the same standards required within x111's licensing jurisdiction.
• Conducting transfer impact assessments where there is any doubt about the adequacy of data protection in the recipient country.

If you would like further information about the specific safeguards applied to any particular international transfer of your data, please contact our Data Protection Officer using the details in Section 15.

x111 may send you promotional communications about bonuses, new game launches, PSL cricket betting specials, seasonal promotions, and platform updates. We will only send you direct marketing communications where:

• You have explicitly opted in to receive marketing communications from x111 during registration or at any point through your account settings, or
• You are an existing x111 player and we are communicating about our own similar products and services, and you have not opted out of such communications.

You can opt out of marketing communications at any time by:

• Clicking the unsubscribe link in any x111 marketing email.
• Updating your communication preferences in your x111 account settings under the Privacy & Notifications section.
• Contacting x111's customer support team and requesting removal from marketing lists.

Opting out of marketing communications will not affect your receipt of service-related communications such as transaction confirmations, account security alerts, KYC verification requests, or responses to your support queries. These communications are necessary for the operation of your account and cannot be opted out of while your account remains active.

x111 reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or our gaming licence requirements. The current version of this policy, including its effective date and version number, is always available on this page.

Where changes to this policy are material — meaning they substantially affect your rights or how x111 processes your data — x111 will notify registered players via the email address on file or through a prominent in-platform notification prior to the changes taking effect. We recommend reviewing this page periodically.

Your continued use of x111 Services following the effective date of any updated Privacy Policy constitutes your acknowledgement of the updated terms. If you do not agree with any changes, you should stop using x111 Services and may request account closure by contacting our support team.

If you have any questions about this Privacy Policy, wish to exercise your data rights, or need to report a data protection concern, please contact x111's Data Protection Officer:

All data rights requests and privacy-related enquiries will be acknowledged within 5 business days and fully resolved within 30 calendar days of receipt. If a request is particularly complex or numerous, x111 may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.

When submitting a data rights request, please include your registered x111 username and the email address associated with your account so that we can verify your identity and locate your data efficiently. x111 will not process data rights requests from unverified sources to protect against fraudulent access attempts.

x111 is committed to resolving all privacy complaints fairly and promptly. If you are not satisfied with the outcome of your complaint, you retain the right to escalate the matter to the relevant regulatory or supervisory authority in your jurisdiction.