Privacy Policy — How 111dt Protects Your Personal Data

About This Policy

This Privacy Policy ("Policy") describes how 111dt ("we", "us", "our") collects, uses, stores, shares, and protects the personal data of individuals ("you", "your", "the Player") who register for an account on, or visit, the 111dt platform located at https://111dt.io (the "Platform"). This Policy applies to all users of the Platform regardless of the device used to access it.

This Policy forms part of the overall legal framework governing your use of the Platform and should be read alongside our Terms & Conditions and Responsible Gaming Policy, both of which are accessible from the footer of every page on the Platform. In the event of any conflict between this Policy and the Terms & Conditions on a privacy matter, this Policy takes precedence.

By registering an account or continuing to use the Platform, you acknowledge that you have read and understood this Policy and that you consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must cease using the Platform and may request closure of your account by contacting [email protected].

Data Controller

For the purposes of applicable data protection law, 111dt is the data controller in respect of personal data collected from players and visitors through the Platform. As data controller, 111dt determines the purposes for which and the means by which personal data is processed.

Where 111dt engages third-party service providers to process data on its behalf — for example, identity verification providers, payment processors, or game technology partners — those parties act as data processors and are bound by written data processing agreements that require them to process data only on 111dt's documented instructions and to maintain appropriate security measures.

All enquiries relating to the exercise of data rights or the handling of personal data under this Policy should be directed to: [email protected]

Data We Collect

111dt collects personal data across several categories. The table below summarises the main categories of personal data we collect and the specific data points within each category.

111dt does not knowingly collect sensitive personal data beyond what is necessary for identity verification (e.g., we do not collect biometric data, health data, or political opinions). Identity document photographs collected for KYC purposes are processed by our verification partner and are not retained on 111dt's primary application servers beyond the verification process.

How We Collect Data

111dt collects personal data through the following channels:

• Direct submission: Data you provide when registering an account, completing KYC verification, making a deposit or withdrawal, contacting our support team, or participating in a promotion.
• Automated collection: Technical data collected automatically when you visit or interact with the Platform, including IP address, device identifiers, browser fingerprint, session data, and clickstream data collected via first-party cookies and server-side logging.
• Payment providers: Confirmation data from bKash, Nagad, Rocket, and Upay regarding the status and outcome of payment transactions initiated by you. 111dt does not receive your full payment account credentials — only transaction references and confirmation statuses.
• Identity verification partners: The outcome of identity and age verification checks performed on your submitted documents. 111dt receives a verified/not-verified status along with any flagged discrepancies; raw document images are handled directly by the verification partner under a separate data processing agreement.
• Game providers: Aggregated game round data from Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi in relation to games played through the 111dt platform. This data is used for dispute resolution, responsible gaming monitoring, and platform analytics.

Legal Basis for Processing

111dt processes your personal data under the following legal bases, each of which applies to specific processing activities:

• Contractual necessity: Processing required to perform the contract between you and 111dt — specifically, operating your account, processing BDT deposits and withdrawals, settling bets, and providing customer support.
• Legal obligation: Processing required to comply with applicable law — including Know Your Customer (KYC) obligations, anti-money laundering (AML) record-keeping, and responding to lawful requests from regulatory or law enforcement authorities.
• Legitimate interests: Processing necessary for 111dt's legitimate business interests where those interests are not overridden by your rights — including fraud prevention, platform security, responsible gaming enforcement, internal analytics, and improving the platform experience.
• Consent: Processing based on your freely given, specific, and informed consent — primarily for marketing communications (email and SMS) and for the use of non-essential cookies. You may withdraw consent at any time without affecting the lawfulness of prior processing.

How We Use Your Data

111dt uses the personal data we collect for the following purposes:

• Account creation and management: Setting up and maintaining your registered player account, verifying your identity and age (21+ requirement), authenticating your login sessions, and managing account security settings including two-factor authentication.
• Payment processing: Facilitating BDT deposits via bKash, Nagad, Rocket, and Upay; processing withdrawal requests to your verified payment method; maintaining your real-money and bonus wallet balances; and generating transaction records.
• Regulatory compliance: Satisfying KYC and AML obligations, reporting suspicious transactions where required by law, maintaining audit trails for regulatory review, and responding to lawful information requests from competent authorities.
• Fraud prevention and security: Detecting and investigating suspicious account activity, identifying and closing duplicate accounts, preventing unauthorised access, and protecting the integrity of the betting and gaming environment.
• Responsible gaming: Monitoring gameplay patterns to identify potential problem gambling behaviour, administering deposit limits and self-exclusion requests, and delivering reality-check notifications and session reminders where these tools have been activated by you.
• Customer support: Responding to your queries, resolving disputes, investigating complaints, and maintaining records of communications to ensure consistent and accountable service delivery.
• Platform improvement: Analysing aggregated, anonymised usage data to improve the Platform's design, performance, game selection, and user experience. Individual player data is not used for this purpose in identifiable form.
• Marketing communications: Sending promotional emails or SMS messages about 111dt offers, new games, seasonal promotions (such as BPL cricket season, Eid specials, and Pohela Boishakh bonuses), and platform updates — but only where you have opted in to receive such communications.

Data Sharing & Disclosure

111dt does not sell, rent, or trade your personal data to any third party for commercial purposes. We share personal data only in the following limited circumstances:

• Payment processors: bKash, Nagad, Rocket, and Upay receive the transaction details necessary to process your deposits and withdrawals. These providers operate under their own privacy policies and are not permitted to use your data for purposes unrelated to transaction processing.
• Identity verification providers: Our KYC verification partner receives identity documents you submit for verification purposes. The partner is bound by a data processing agreement that restricts use of your data to identity verification services provided to 111dt.
• Game technology providers: Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi receive a player session token (not your personal details) to facilitate access to their games. Game round data is shared back to 111dt for settlement and dispute resolution purposes.
• Legal and regulatory authorities: 111dt will disclose personal data to competent governmental, regulatory, or law enforcement authorities where legally required to do so by applicable law, court order, or regulatory instruction. We will, where legally permitted, notify affected players of such disclosures.
• Professional advisers: Lawyers, accountants, auditors, and insurers who are bound by confidentiality obligations may access personal data to the extent necessary to provide professional services to 111dt.
• Business transfers: In the event of a merger, acquisition, or sale of all or a substantial part of 111dt's business, personal data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer via the email address registered on your account prior to your data being transferred and becoming subject to a different privacy policy.

Cookies & Tracking Technologies

111dt uses cookies and similar tracking technologies on the Platform to support platform functionality, security, and — where you have consented — analytics and personalisation. The categories of cookies we use are as follows:

• Strictly necessary cookies: These cookies are essential for the Platform to function and cannot be disabled. They include session authentication tokens, CSRF protection tokens, load balancing cookies, and security cookies that protect your account from session hijacking. No consent is required for strictly necessary cookies.
• Functional cookies: These cookies remember your preferences such as your chosen display settings and notify you of session time reminders where you have activated this responsible gaming tool. Disabling these cookies may reduce the functionality of certain Platform features.
• Analytics cookies: With your consent, 111dt uses first-party analytics cookies to collect aggregated, anonymised data about how players navigate and interact with the Platform. This data is used exclusively for internal Platform improvement and is not shared with third-party analytics providers.
• Marketing cookies: With your consent, marketing cookies allow 111dt to measure the effectiveness of its own promotional communications and to customise offers displayed within the Platform based on your gameplay and navigation history.

You may manage your cookie preferences at any time via your account settings. Withdrawing consent for non-essential cookies will not affect your ability to use the core Platform. Note that blocking strictly necessary cookies will prevent you from logging into your account.

Data Security

111dt implements industry-standard technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security infrastructure includes:

• Transport encryption: All data in transit between your device and the 111dt Platform is protected using TLS 1.3 (Transport Layer Security). The Platform operates exclusively over HTTPS and does not serve any content over unencrypted HTTP connections.
• Data-at-rest encryption: Sensitive personal data stored on 111dt's servers — including identity documents, payment method details, and account credentials — is encrypted at rest using AES-256 encryption.
• Access controls: Access to personal data within 111dt's internal systems is governed by role-based access control (RBAC). Only personnel whose job function requires access to specific categories of personal data are granted that access. All internal data access events are logged and subject to periodic audit.
• Password security: Player account passwords are stored as salted cryptographic hashes using bcrypt. 111dt does not store or have access to your plaintext password at any time.
• Penetration testing: The Platform undergoes periodic security assessments by independent security professionals. Critical vulnerabilities identified through these assessments are remediated on a priority basis.
• Incident response: 111dt maintains a documented data breach response procedure. In the event of a personal data breach that poses a risk to your rights and freedoms, affected players will be notified without undue delay at the email address registered on their account.

While 111dt takes all reasonable steps to protect your personal data, no security system is impenetrable. You are responsible for maintaining the security of your account credentials and for notifying us immediately at [email protected] if you suspect any unauthorised access to your account.

Data Retention

111dt retains personal data for as long as necessary to fulfil the purposes for which it was collected, including satisfying any legal, regulatory, accounting, or reporting obligations. The following retention periods apply:

• Active account data: Retained for the full lifetime of your active 111dt account.
• Post-closure account data: Following account closure (whether voluntary or initiated by 111dt), all account data — including identity, financial, and gaming records — is retained for a minimum of five (5) years from the date of closure in order to comply with anti-money laundering record-keeping requirements and to enable resolution of any post-closure disputes.
• Transaction records: BDT deposit and withdrawal records are retained for a minimum of five (5) years from the date of each transaction.
• Support communications: Customer support correspondence is retained for three (3) years from the date of the final communication in a thread, after which it is securely deleted.
• Marketing consent records: Records of your marketing opt-in or opt-out history are retained for the lifetime of your account plus three (3) years to demonstrate compliance with applicable consent requirements.
• Analytics data: Anonymised, aggregated analytics data with no connection to individual players may be retained indefinitely for platform improvement purposes.

When personal data is no longer required for any lawful purpose and its retention period has expired, 111dt securely deletes or irreversibly anonymises that data in accordance with its internal data retention and disposal procedures.

Your Privacy Rights

As a data subject, you hold the following rights in relation to the personal data 111dt holds about you. These rights may be exercised by submitting a written request to [email protected]. 111dt will respond to all valid rights requests within 30 days of receipt and will not charge a fee for standard requests.

• Right of access: You may request a copy of the personal data 111dt holds about you, together with information about how that data is processed, the categories of data held, the purposes of processing, and any third parties with whom it has been shared.
• Right to rectification: You may request correction of any personal data about you that is inaccurate or incomplete. Certain data (such as your verified legal name and date of birth) cannot be self-amended through account settings and must be corrected via a formal request supported by updated documentation.
• Right to erasure: You may request deletion of your personal data where 111dt no longer has a lawful basis to retain it. This right is subject to override by 111dt's legal obligations — in particular, AML record-keeping requirements mean that core financial and identity records must be retained for five years post-closure and cannot be deleted upon request during that period.
• Right to restriction: You may request that 111dt restricts the processing of your personal data in certain circumstances — for example, while a dispute about the accuracy of your data is being resolved, or where you have objected to processing and a determination on that objection is pending.
• Right to object: You may object to processing based on legitimate interests at any time. You also have the absolute right to object to processing of your data for direct marketing purposes, which will be honoured without requiring justification.
• Right to data portability: You may request a copy of the personal data you provided to 111dt in a structured, machine-readable format (CSV or JSON), to the extent that the data was processed on the basis of your consent or contractual necessity and is technically feasible to provide in portable format.
• Right to withdraw consent: Where processing is based on your consent (primarily for marketing communications and non-essential cookies), you may withdraw that consent at any time via your account settings or by contacting [email protected]. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

Children & Minors

The 111dt Platform is strictly intended for adults aged 21 years and above. 111dt does not knowingly collect personal data from individuals under the age of 21 and does not permit persons under 21 to register accounts or access real-money gaming services.

During the registration process, all players are required to provide their date of birth, which is verified against submitted identity documents as part of the mandatory KYC process. Accounts where the account holder is found to be under the age of 21 will be immediately closed, any funds will be returned to the originating payment method where possible, and all associated personal data will be deleted without undue delay.

If you have reason to believe that a minor has registered an account on the Platform or that their personal data has been collected by 111dt, please contact us immediately at [email protected] with details and we will investigate and take appropriate action within 48 hours.

International Data Transfers

111dt operates its Platform and stores the majority of player data on servers located in secure data centre facilities. In certain circumstances, personal data may be transferred to or accessed from locations outside Bangladesh — for example, where a game technology partner or identity verification provider maintains infrastructure in another country.

Where such international transfers of personal data occur, 111dt ensures that appropriate safeguards are in place to protect your data to an equivalent standard as would apply within Bangladesh. These safeguards include contractual data protection clauses incorporated into all data processing agreements with international partners, requiring those partners to implement security measures consistent with the standards described in this Policy.

111dt does not transfer personal data to any country that it considers to present an unacceptable risk to the rights and freedoms of data subjects, based on its ongoing assessment of the data protection standards applicable in those countries.

Marketing Communications

111dt sends promotional and marketing communications by email and SMS only to players who have explicitly opted in to receive such communications. Marketing messages may include information about deposit bonuses, free bets, new game launches, seasonal promotions tied to BPL cricket, IPL, Eid, Durga Puja, and Pohela Boishakh events, and platform feature announcements.

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

• Clicking the "Unsubscribe" link in any marketing email from 111dt;
• Replying "STOP" to any marketing SMS from 111dt;
• Updating your communication preferences in your account settings; or
• Contacting [email protected] with a request to remove you from all marketing lists.

Opting out of marketing communications does not affect your ability to receive transactional and account-related communications from 111dt, which are sent regardless of marketing preferences. These include deposit and withdrawal confirmations, KYC status notifications, account security alerts, responsible gaming reminders, and any other communication that is required for the operation of your account.

Changes to This Policy

111dt reserves the right to update or revise this Privacy Policy at any time to reflect changes in applicable law, our data processing practices, or the features and services offered through the Platform. The version number and effective date at the top of this page will be updated whenever material changes are made.

For material changes — those that significantly affect your rights or the way we process your personal data — 111dt will notify all registered players via the email address on their account at least 14 days before the changes take effect. Minor clarifications or non-material amendments may be published without advance notice.

Your continued use of the Platform after the effective date of any updated Policy constitutes acceptance of the revised terms. If you do not accept a material change to this Policy, you may close your account and request withdrawal of your Real Money Balance in accordance with the withdrawal procedures set out in our Terms & Conditions before the change takes effect.

Contact & Complaints

For any questions, concerns, or requests relating to this Privacy Policy or the handling of your personal data by 111dt, please contact us at:

Email: [email protected]

111dt will acknowledge all privacy-related enquiries within 24 hours and will provide a substantive response within 30 days of receiving a valid request. Where a request is complex or involves a large volume of data, we may extend this period by a further 30 days and will inform you of the extension and the reason for it within the initial 30-day period.

If you are not satisfied with 111dt's response to a privacy complaint, or if you believe we are processing your personal data in a manner inconsistent with applicable law, you have the right to escalate your complaint to a competent supervisory authority or to seek an independent determination through applicable dispute resolution mechanisms available in your jurisdiction.