a111 Privacy Policy

1 Introduction

1.1 a111 takes the privacy of its players seriously. This Policy explains in plain terms what personal information a111 collects, why it is collected, how it is used, with whom it is shared, and how long it is retained. It also explains the rights you have over your personal data and how to exercise those rights.

1.2 This Policy applies to all players accessing a111 services, including players based in Pakistan (Karachi, Lahore, Islamabad, Rawalpindi, Faisalabad, and beyond) and in any other jurisdiction. Where applicable local law provides additional data protection rights, those rights apply in full.

1.3 This Policy should be read alongside the a111 Terms & Conditions and Responsible Gaming Policy, both of which are incorporated by reference.

2 Personal Data We Collect

2.1 Registration Data. When you create an a111 account, we collect your full legal name, date of birth, Pakistani mobile number or email address, and the password you create (stored in hashed form only — never as plain text).

2.2 Identity Verification (KYC) Data. Before processing your first withdrawal, a111 requires KYC verification. This involves collecting a copy of a government-issued identity document (CNIC or passport), and may include a selfie for liveness verification. This data is used solely for identity and age verification and is handled in accordance with applicable legal requirements.

2.3 Financial Data. We collect information about your deposits and withdrawals including payment method type, transaction amounts in PKR, and transaction reference numbers. For JazzCash and Easypaisa transactions, we receive confirmation data from those providers. We do not store full bank account numbers or card numbers on our servers.

2.4 Gameplay Data. We collect records of your betting and gaming activity on a111, including game type, stakes, outcomes, and session duration. This data is required for regulatory compliance, responsible gaming monitoring, and dispute resolution.

2.5 Technical Data. We automatically collect device type, operating system, browser type, IP address, and connection data when you access a111.win. This information is used for security, fraud prevention, and platform optimisation.

2.6 Communications Data. If you contact a111 support, we retain records of that communication including its content, date, and outcome, for the purpose of providing support and maintaining service quality records.

2.7 Responsible Gaming Data. If you set deposit limits, request a cool-off period, or self-exclude, we retain a record of those instructions permanently to ensure they are enforced accurately even if your account is later closed and reopened.

3 How We Use Your Personal Data

a111 uses your personal data for the following purposes:

• Account management: To register, maintain, and administer your a111 account;
• Identity verification: To verify your age (18+) and identity as required by our KYC obligations;
• Payment processing: To process PKR deposits and withdrawals via JazzCash, Easypaisa, HBL, UBL, Meezan Bank, and Bank Alfalah;
• Service delivery: To provide access to casino games, sports betting markets, and all other a111 platform features;
• Security and fraud prevention: To monitor for suspicious activity, protect player accounts, and maintain platform integrity;
• Regulatory compliance: To fulfil our obligations under applicable laws including anti-money laundering (AML) requirements;
• Responsible gaming: To monitor gameplay patterns and intervene where responsible gaming concerns arise, and to enforce player-set limits and exclusions;
• Customer support: To respond to and resolve player queries and complaints;
• Platform improvement: To analyse usage patterns and improve the a111 platform, games, and user experience;
• Communications: To send you transactional notifications (account activity, deposit confirmations, withdrawal updates) and, where you have consented, promotional communications about a111 offers.

4 Legal Basis for Processing

4.1 Contract performance. The majority of data processing by a111 is necessary for the performance of your player account agreement — without it, we cannot provide the services you have registered for.

4.2 Legal obligation. KYC verification, AML monitoring, and the retention of certain transaction records are legal obligations under applicable regulations, independent of your consent.

4.3 Legitimate interests. Security monitoring, fraud detection, and platform analytics are processed on the basis of a111's legitimate interest in maintaining a safe and properly functioning platform for all players.

4.4 Consent. Where we send you promotional communications or use non-essential cookies, we rely on your consent. You may withdraw consent at any time by contacting support at [email protected].

5 Sharing Your Personal Data

5.1 a111 does not sell, rent, or trade your personal data to third parties for marketing or advertising purposes. We share your data only in the following circumstances:

• Payment processors: JazzCash, Easypaisa, HBL, UBL, Meezan Bank, and Bank Alfalah receive transaction data necessary to process your deposits and withdrawals;
• Identity verification providers: KYC documentation is processed by licensed identity verification service providers under strict data processing agreements;
• Game content providers: Game providers receive your player identifier and game session data to deliver and resolve game rounds. They do not receive your identity documents or payment details;
• Regulatory and law enforcement authorities: Where required by applicable law, we disclose data to regulators, law enforcement, or anti-money laundering authorities;
• Professional advisers: Lawyers, auditors, and compliance consultants, subject to confidentiality obligations.

5.2 All third parties with whom a111 shares personal data are required to process that data only for the specified purpose and in accordance with applicable data protection standards.

6 International Data Transfers

6.1 a111's platform infrastructure and some service providers may be located outside Pakistan. Where personal data is transferred internationally, a111 ensures that appropriate safeguards are in place — including contractual protections — to ensure your data receives a standard of protection consistent with this Policy.

7 Data Retention

7.1 a111 retains your personal data for as long as your account is active and for a period after account closure as required by applicable law and regulatory obligations. Transaction records, KYC documentation, and gameplay logs are typically retained for a minimum of five years following account closure to comply with AML and financial record-keeping requirements.

7.2 Responsible gaming records — including self-exclusion requests and deposit limit settings — are retained permanently to ensure that these instructions remain enforceable regardless of account status.

7.3 Where data is no longer required for any lawful purpose, a111 will securely delete or anonymise it.

8 Security Measures

8.1 a111 implements industry-standard security measures to protect your personal data, including:

• SSL/TLS encryption for all data transmitted between your browser and a111.win;
• AES-256 encryption for sensitive data stored on a111 servers;
• Password hashing using bcrypt or equivalent — your password is never stored in readable form;
• Role-based access controls limiting internal access to personal data on a need-to-know basis;
• Regular security audits and penetration testing of the a111 platform;
• Two-factor authentication available to all registered players.

8.2 While a111 takes all reasonable steps to protect your data, no online platform can guarantee absolute security. Players are responsible for maintaining the security of their own account credentials.

9 Cookies and Tracking Technologies

9.1 a111 uses cookies and similar technologies on a111.win. These include:

• Essential cookies: Required for session management, authentication, and basic platform functionality. These cannot be disabled without impacting your ability to use a111;
• Analytics cookies: First-party analytics cookies help a111 understand how players use the platform so we can improve it. These do not identify you personally;
• Preference cookies: Store your settings such as language preferences and responsible gaming tool configurations.

9.2 a111 does not use third-party advertising cookies or share data with ad networks. You can manage cookie preferences through your browser settings, though disabling essential cookies will affect platform functionality.

10 Your Data Rights

10.1 Subject to applicable law, you have the following rights regarding your personal data held by a111:

• Right of access: Request a copy of the personal data a111 holds about you;
• Right to rectification: Request correction of inaccurate or incomplete personal data;
• Right to erasure: Request deletion of your personal data, subject to legal retention obligations;
• Right to restriction: Request that processing of your data be restricted in certain circumstances;
• Right to object: Object to processing based on legitimate interests;
• Right to withdraw consent: Where processing is based on consent, withdraw that consent at any time.

10.2 To exercise any of these rights, contact a111 at [email protected]. We will respond to all valid requests within 30 days. Note that some rights are subject to limitations — for example, we cannot delete KYC records that we are legally required to retain.

11 Minors

11.1 a111 services are strictly for persons aged 18 and above. a111 does not knowingly collect personal data from persons under 18. If we become aware that personal data has been collected from a minor, that account will be closed immediately, any deposited funds returned, and the data deleted from our systems. If you are a parent or guardian and believe a minor has registered with a111, please contact us immediately at [email protected].

12 Changes to This Privacy Policy

12.1 a111 may update this Privacy Policy from time to time. The current version is always published at a111.win/privacy-policy with the "Last Updated" date shown at the top. For material changes, registered players will be notified by email or account notification. Continued use of a111 services after any update constitutes acceptance of the revised Policy.

13 Contact Us

For any questions, requests, or concerns relating to this Privacy Policy or how a111 handles your personal data, please contact:

• Support: [email protected]
• Business & Compliance: [email protected]

Support is provided in English and is available to players across Pakistan including Karachi, Lahore, Islamabad, Rawalpindi, and Faisalabad.