111kap Privacy Policy

1 Introduction

This Privacy Policy ("Policy") describes how 111kap ("111kap", "we", "us", or "our"), operator of the online gaming platform at 111kap.net, collects, uses, stores, shares, and protects personal data belonging to registered players and visitors ("you", "your", or "Player").

111kap is committed to handling your personal data responsibly. We process personal data only where we have a valid legal basis for doing so, and we take appropriate technical and organisational measures to protect the data we hold against unauthorised access, loss, or misuse.

This Policy forms part of the broader contractual relationship between 111kap and its players, alongside the Terms & Conditions and Responsible Gaming Policy. Together, these documents define the framework under which 111kap operates and your rights and obligations as a player.

If you have any questions about this Policy or about how 111kap handles your personal data, please contact our support team using the details provided in Section 14 of this document.

2 Personal Data We Collect

111kap collects several categories of personal data in connection with the operation of our gaming platform. The specific data collected depends on how you interact with 111kap:

2.1 Identity and Registration Data

• Full legal name as it appears on your government-issued identification;
• Date of birth (used to verify the 21+ age requirement);
• CNIC number, passport number, or other national identification number;
• Residential address, city (e.g. Karachi, Lahore, Faisalabad, Islamabad), and postal code;
• Profile photograph or scanned identification documents submitted during KYC.

2.2 Contact Data

• Pakistani mobile number (including JazzCash or EasyPaisa registered number);
• Email address;
• Preferred language for communications (English or Urdu).

2.3 Financial and Payment Data

• JazzCash and EasyPaisa account details used for deposits and withdrawals;
• Bank account details for HBL, UBL, or Meezan Bank transfers where applicable;
• Visa/Mastercard card details (last four digits and expiry only — full card numbers are processed by PCI-DSS compliant payment processors and are not stored by 111kap);
• USDT wallet addresses for cryptocurrency transactions;
• Transaction history including deposits, withdrawals, and PKR wallet balances.

2.4 Gaming Activity Data

• Betting and wagering history across all 111kap products (slots, live casino, cricket sportsbook, Keno Bonus Number, Treasure Boat Fishing);
• Game session duration, frequency, and patterns of play;
• Bonus activations, wagering progress, and promotion participation;
• Responsible gaming tool usage including deposit limits and self-exclusion events.

2.5 Technical and Device Data

• IP address and approximate geolocation derived from IP;
• Device type, operating system, and browser type;
• Cookies and session identifiers (see Section 7 for full cookie details);
• Platform interaction logs including 111kap login timestamps and session durations.

2.6 Communications Data

• Records of support interactions via live chat, email, or other channels;
• Feedback, complaints, or dispute records;
• Records of consent to or opt-out from marketing communications.

3 How We Collect Your Data

111kap collects personal data through several channels:

• Direct submission: Information you provide when registering your 111kap account, completing KYC verification, making deposits or withdrawal requests, contacting support, or submitting feedback;
• Automated collection: Technical and device data collected automatically when you access or use the 111kap platform, including via cookies and server logs;
• Payment processors: Confirmation data received from JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa/Mastercard, and USDT payment processors upon completion of transactions;
• Identity verification providers: Results of identity and document verification checks conducted through third-party KYC service providers as part of our licensing obligations;
• Fraud prevention services: Risk signals and flagging information received from fraud detection partners to protect the integrity of the 111kap platform;
• Regulatory sources: Self-exclusion registration data received from recognised responsible gambling registries in connection with our licensing authority obligations.

4 Why We Use Your Personal Data

111kap uses your personal data for the following purposes:

5 Legal Basis for Processing

111kap processes personal data on the following legal bases:

• Contractual necessity: Processing required to create and manage your 111kap account, process transactions, and deliver the gaming services you have requested;
• Legal obligation: Processing required to comply with our licensing authority's KYC, Anti-Money Laundering (AML), and responsible gambling obligations — including age verification, identity verification, and transaction monitoring;
• Legitimate interests: Processing for fraud prevention, platform security, abuse detection, and service improvement where these interests are not overridden by your data protection rights;
• Consent: Marketing communications and certain non-essential cookies are processed only where you have given explicit consent. You may withdraw consent at any time by contacting 111kap support or updating your communication preferences in your account settings.

6 Sharing Your Personal Data

111kap does not sell your personal data. We share personal data only with the following categories of recipients, and only to the extent necessary for the stated purpose:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Visa/Mastercard processors, and USDT wallet service providers — for the sole purpose of processing deposits and withdrawals on your behalf;
• KYC and identity verification providers: Third-party identity verification services engaged by 111kap to fulfil licensing authority requirements for player identity checks;
• Fraud prevention services: Risk and fraud detection service providers who assist 111kap in identifying and preventing fraudulent activity on the platform;
• Game providers: Where technically required, limited session data may be shared with third-party game providers whose games are hosted on the 111kap platform, solely to facilitate game play and resolve game-related disputes;
• Licensing and regulatory authorities: 111kap's licensing authority and any other regulatory body with a legal right to access player data for compliance, audit, or enforcement purposes;
• Law enforcement: Government agencies, courts, or law enforcement bodies where 111kap is legally required to disclose data in connection with investigations or legal proceedings;
• IT and infrastructure providers: Cloud hosting, security, and technical service providers who process data on behalf of 111kap under data processing agreements with equivalent data protection obligations.

7 Cookies and Tracking Technologies

The 111kap platform uses cookies and similar tracking technologies to support platform functionality, maintain your session after 111kap login, and analyse platform usage. The following cookie categories are used:

You may manage your cookie preferences at any time through your browser settings. Please note that disabling strictly necessary cookies may impair your ability to use core 111kap platform features including the login system and wallet functionality.

8 Data Retention

111kap retains personal data for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable laws and our licensing authority. In practice, this means:

• Active account data is retained for the duration of your 111kap account relationship and for a defined period following account closure, as required by our licensing authority for AML compliance purposes (typically five to seven years);
• Transaction records including PKR deposits, withdrawals, and betting history are retained for a minimum of five years from the date of the transaction in compliance with standard financial record-keeping requirements;
• KYC and identity documents are retained for the period required by our licensing authority, typically five years from the date the account relationship ends;
• Support interaction records are retained for a minimum of two years from the date of the interaction;
• Marketing consent records are retained for as long as the consent remains active and for a period thereafter sufficient to demonstrate historical compliance;
• Technical and device logs are typically retained for 90 days for security monitoring purposes, after which they are deleted or anonymised.

Upon expiry of applicable retention periods, personal data is securely deleted or irreversibly anonymised so that it can no longer be linked to an identifiable individual.

9 Data Security

111kap implements a layered approach to data security, applying appropriate technical and organisational measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. These measures include:

• TLS/SSL encryption for all data in transit between your device and the 111kap platform;
• Encryption of sensitive data at rest, including identity documents and financial credentials;
• Password hashing using industry-standard cryptographic algorithms — 111kap does not store plaintext passwords;
• Role-based access controls ensuring that only authorised 111kap personnel can access player data, and only to the extent required for their role;
• Regular security assessments and penetration testing of the 111kap platform infrastructure;
• Secure data centres with physical access controls and environmental protections;
• Incident response procedures to detect, contain, and notify affected players of data security breaches within required timeframes.

While 111kap takes all reasonable steps to protect your personal data, no online platform can guarantee absolute security. Players are encouraged to maintain strong, unique passwords for their 111kap account and to use the optional two-factor authentication feature available in account settings.

10 Your Data Protection Rights

As a 111kap player, you have the following rights with respect to your personal data. To exercise any of these rights, please contact 111kap support using the details in Section 14:

11 Children and Minors

The 111kap platform is strictly for individuals aged 21 years and above. 111kap does not knowingly collect personal data from any individual under the age of 21. If you are a parent or guardian and believe that a minor has registered on 111kap or submitted personal data to the platform, please contact 111kap support immediately using the details in Section 14. Any account belonging to an individual under 21 will be closed and any personal data collected will be deleted as soon as it is practicable to do so, subject to overriding legal obligations.

12 International Data Transfers

111kap operates internationally and your personal data may be processed in countries outside Pakistan, including the country in which 111kap's licensing authority is based and the locations of our cloud infrastructure and technology partners. Where data is transferred outside Pakistan, 111kap ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that required under 111kap's licensing authority rules.

Safeguards for international transfers may include:

• Contractual data protection clauses in agreements with third-party processors located in other jurisdictions;
• Transfer only to jurisdictions that provide an adequate level of data protection as recognised by applicable law or our licensing authority;
• Binding corporate rules or equivalent frameworks where applicable to group-wide data flows.

If you would like further information about the safeguards applied to international transfers of your personal data, please contact 111kap support.

13 Changes to This Privacy Policy

111kap may update this Privacy Policy from time to time to reflect changes in our data processing practices, legal or regulatory requirements, or the evolution of our platform and services. Where changes are material, 111kap will notify registered players via email or in-platform notification before the updated Policy takes effect.

The "Last Updated" date at the top of this Policy indicates when the most recent revision was made. 111kap encourages players to review the Privacy Policy periodically to stay informed of how their personal data is handled. Continued use of the 111kap platform after notification of changes to this Policy constitutes acceptance of the updated version.

14 Contact Us

For any questions, concerns, or requests relating to this Privacy Policy or to the personal data that 111kap holds about you, please contact our support team. Our team is available 24 hours a day, 7 days a week and provides support in both English and Urdu for the convenience of players across Pakistan.

This Privacy Policy was last reviewed and updated on 1 January 2026. For historical versions of this Policy or for specific compliance enquiries related to our licensing authority's data protection requirements, please contact our support team directly.