Privacy Policy — 111tk Data Protection Commitment

01 Personal Data We Collect

111tk collects personal data across several categories. The specific data collected depends on the nature of your interaction with the platform — registration, payment, gameplay, and support interactions each involve different data points. The following table provides a comprehensive overview:

We do not collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information unless specifically required by an applicable legal obligation and only with your explicit consent.

02 How We Collect Your Data

111tk collects personal data through three primary channels:

• Direct collection: Data you voluntarily provide when you register an account, complete identity verification, make a deposit or withdrawal, contact our support team, or interact with any form or input field on the platform.
• Automated collection: Technical and gameplay data collected automatically through cookies, session tracking, server logs, and analytics tools as you use the platform. See Section 6 for full details on our cookie practices.
• Third-party sources: Identity and fraud-verification data received from payment providers (bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, Visa, Mastercard) when you initiate a transaction, and from identity verification service providers when you complete KYC checks.

03 Why We Use Your Personal Data

111tk processes your personal data for the following specific and lawful purposes:

• Account management: To create, maintain, and secure your 111tk player account, including password recovery and OTP-based login verification.
• Identity verification (KYC): To confirm that you meet the minimum age requirement of 21 years and that your identity matches the payment method registered on your account, in fulfilment of our anti-fraud obligations.
• Payment processing: To execute deposits, process withdrawal requests, and maintain an accurate transaction ledger for your account.
• Fraud prevention and security: To detect, investigate, and prevent fraudulent transactions, multi-accounting, money laundering, collusion, and other prohibited activities that could harm our players or the integrity of the platform.
• Responsible gaming compliance: To monitor gameplay patterns that may indicate problem gambling behaviour, to apply deposit limits and self-exclusion restrictions, and to fulfil our duty of care to players under our Responsible Gaming framework.
• Customer support: To respond to your queries, resolve disputes, investigate complaints, and maintain a record of support interactions for quality assurance.
• Platform improvement: To analyse aggregated, anonymised usage data in order to improve platform performance, game selection, user experience, and promotional offerings.
• Legal and regulatory obligations: To comply with applicable laws, respond to lawful requests from competent authorities, and maintain records as required by anti-money laundering (AML) and counter-terrorism financing (CTF) frameworks.

04 Data Sharing and Disclosure

111tk does not sell, rent, or transfer your personal data to third parties for their own commercial use. We may share your data in strictly limited circumstances, as described below:

• Payment service providers: Transaction data is shared with bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, Visa, and Mastercard solely to execute the payment instructions you initiate. These providers are bound by their own privacy policies and applicable financial regulations.
• Identity verification partners: Identity data may be shared with third-party KYC verification providers for the purposes of age and identity confirmation. These providers are contractually prohibited from using your data for any purpose other than the verification service they supply to 111tk.
• Game studio providers: Gameplay data (bets placed, game rounds, wager amounts) is transmitted to game studios including Evolution Gaming, Pragmatic Play, Microgaming, NetEnt, Spribe, and Ezugi as a technical requirement of delivering live and RNG-based games. These studios process gameplay data in accordance with their own certified data protection frameworks.
• Legal authorities: We may disclose personal data to law enforcement agencies, regulatory bodies, or courts when required to do so by a lawful order, warrant, or legal obligation. We will notify you of such disclosure where we are legally permitted to do so.
• Business transfers: In the event of a merger, acquisition, or sale of substantially all of 111tk's assets, your personal data may be transferred to the acquiring entity, subject to the acquiring entity's commitment to honour this Policy or a substantially equivalent privacy standard.

05 Data Retention

111tk retains your personal data for the minimum period necessary to fulfil the purpose for which it was collected, subject to any longer retention requirements imposed by applicable law. The following retention periods apply:

When a retention period expires, data is either permanently deleted from our systems or irreversibly anonymised so that it can no longer be associated with any identifiable individual. Anonymised, aggregated data may be retained indefinitely for statistical and platform improvement purposes.

06 Cookies and Tracking Technologies

111tk uses cookies and similar tracking technologies (including local storage and session tokens) to operate the platform, remember your preferences, maintain your logged-in session, detect fraud, and analyse platform usage. The following categories of cookies are used:

• Strictly necessary cookies: These cookies are essential for the platform to function. They maintain your login session, store your language and currency preferences, and enable core security features such as CSRF protection. These cookies cannot be disabled without impairing platform functionality.
• Performance and analytics cookies: These cookies collect anonymised information about how users navigate and interact with the platform — such as which pages are visited most frequently and how long sessions last — to help us improve user experience. No personally identifiable information is included in this data.
• Fraud detection cookies: These cookies analyse device fingerprinting signals, IP addresses, and behavioural patterns to identify accounts that may be engaging in multi-accounting, bonus abuse, or automated betting. They are a core component of our platform security.
• Functional / preference cookies: These cookies remember choices you have made on the platform — such as your preferred game lobby layout or deposit method — to personalise your experience on return visits.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary or fraud detection cookies may affect your ability to log in and use core platform features. 111tk does not use third-party advertising or retargeting cookies.

07 Data Security

111tk applies a layered security architecture to protect your personal data against unauthorised access, accidental loss, alteration, and destruction. Our key security measures include:

• 256-bit SSL/TLS encryption for all data in transit between your device and our servers.
• AES-256 encryption at rest for all stored personal and financial data.
• Bcrypt password hashing with per-user salts — no plain-text password storage.
• OTP (one-time password) verification for account login and withdrawal authorisation.
• Role-based access controls limiting internal access to personal data on a strict need-to-know basis.
• Regular third-party penetration testing and security audits of platform infrastructure.
• Automated anomaly detection systems that flag unusual login patterns, IP changes, and suspicious transaction sequences in real time.

Despite our best efforts, no data transmission over the internet or electronic storage system can be guaranteed to be 100% secure. If you have reason to believe that your 111tk account has been compromised, please notify our support team immediately at [email protected] so that we can take protective action.

08 Your Privacy Rights

As a 111tk account holder, you hold the following rights with respect to your personal data. To exercise any of these rights, contact our privacy team at [email protected] with your full name, registered mobile number, and a description of your request. We will respond within 30 days of receipt.

09 Minors and Age Restrictions

The 111tk platform is strictly intended for adults aged 21 years and above. We do not knowingly collect personal data from individuals under the age of 21. Age verification is conducted as part of the account registration and KYC process for all new users.

If we discover or have reasonable grounds to suspect that an account has been registered by or on behalf of an individual under 21 years of age, that account will be immediately suspended, all gameplay during the period of suspected underage use will be investigated, and any funds held in the account will be handled in accordance with applicable law. We may report confirmed underage gambling incidents to the appropriate authorities.

Parents and guardians who believe their child has registered an account on the 111tk platform are encouraged to contact us immediately at [email protected] so that we can investigate and take appropriate action without delay. The safety of minors is a non-negotiable priority for 111tk.

10 Changes to This Privacy Policy

111tk reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, applicable law, or the services we offer. When we make a material change to this Policy — meaning a change that substantively affects your rights or the way we process your personal data — we will notify you by sending an alert to your registered mobile number or email address at least 7 days before the new version takes effect.

Minor changes, such as typographical corrections, clarifications that do not alter the substance of the Policy, or updates to contact information, may be made without advance notice. The effective date displayed at the top of this document will always reflect the date on which the current version came into force.

Your continued use of the 111tk platform after the effective date of a revised Privacy Policy constitutes your acceptance of the updated terms. If you do not agree with a proposed change, you may request account closure before the new version takes effect.

11 Contact Our Privacy Team

If you have any questions, concerns, or requests relating to this Privacy Policy or the way 111tk handles your personal data, please contact our dedicated privacy and data protection team using the details below. All privacy-related enquiries are treated with strict confidentiality and handled by trained staff.

We aim to acknowledge all privacy-related requests within 48 hours and to provide a substantive response within 30 calendar days. In complex cases, this period may be extended by a further 30 days, in which case we will inform you of the extension and the reason for it before the initial 30-day period expires.