x111 Privacy Policy – How We Protect Your Data in Pakistan

01 Introduction

At x111, we understand that handing over personal information — your name, your mobile number, your payment details — requires trust. That trust is not something we take lightly. This Privacy Policy explains in plain, honest language how x111 handles the personal data of everyone who registers and plays on the platform.

x111 operates at https://x111.run and serves players primarily in Pakistan. We are the data controller for all personal information you provide when registering an x111 account, making deposits or withdrawals in PKR, placing bets, or using any other feature on the platform.

This policy applies to all x111 players regardless of how they access the platform — whether via a mobile browser, desktop browser, or any future x111 application. It covers personal data collected online through the x111 platform and through direct communication with our customer support team.

The short version: x111 collects only the data it genuinely needs to operate your account and comply with its legal obligations. We do not sell your data. We do not share it with advertisers. We protect it using industry-standard security measures. And we give you meaningful control over it.

02 What Data x111 Collects

x111 collects two broad categories of data: information you provide directly, and information generated automatically when you use the platform. Here is a detailed breakdown of both.

Information You Provide Directly

• Registration Data: Your full name, date of birth, mobile phone number, and email address (if provided). This information is required to create and verify your x111 account.
• Identity Verification Documents: In line with our licensing obligations, x111 may request a copy of your CNIC (Computerised National Identity Card), utility bill, or bank statement to verify your identity before processing withdrawals above certain thresholds.
• Financial Information: Details of the payment method used for deposits and withdrawals, including mobile wallet identifiers (Easypaisa/JazzCash account numbers), bank account details for IBFT transfers, or masked card numbers for Visa/Mastercard transactions. x111 does not store full card numbers — payment card data is handled exclusively by PCI-DSS compliant payment processors.
• Communication Data: Records of any communications you have with x111 customer support, including live chat transcripts, email correspondence, and any feedback or complaints submitted.
• Responsible Gaming Preferences: Any deposit limits, self-exclusion requests, or cooling-off periods you set through your x111 account settings.

Information Generated Automatically

• Device and Technical Data: IP address, browser type and version, operating system, device type (mobile or desktop), and screen resolution — collected when you access x111.
• Usage Data: Pages visited within x111, features used, time spent on the platform, betting patterns, login times, and session duration.
• Transaction Data: A complete record of all deposits, withdrawals, bets placed, bets settled, bonuses credited, and balance movements within your x111 account.
• Cookie and Tracking Data: Data collected through cookies and similar technologies used on the x111 platform — explained in detail in Section 7 of this policy.

03 How x111 Collects Your Data

x111 collects personal data through several channels, and we want to be transparent about each of them.

• Direct Registration: When you complete the x111 registration form, you provide your name, mobile number, date of birth, and other required fields directly. This is the primary source of your personal data at x111.
• Deposits and Withdrawals: Every time you initiate a PKR deposit or withdrawal through your x111 account, the transaction generates a data record that includes the method used, amount, timestamp, and outcome.
• Betting Activity: Every bet placed on x111 — whether a PSL cricket bet, a live in-play football market, or an Aviator game round — generates a transaction record associated with your account.
• Automated Platform Technologies: x111 uses standard web technologies including cookies, session tokens, and server logs to collect technical data when you access and use the platform. See Section 7 for full cookie details.
• Customer Support Interactions: When you contact x111 via live chat or email, the content of that conversation is recorded for quality assurance and dispute resolution purposes.
• Identity Verification Providers: Where x111 engages third-party identity verification services to assist with KYC checks, those providers may supply x111 with verification results and supporting data. x111 selects only reputable, compliant providers for this purpose.

04 Why x111 Uses Your Data — Purposes of Processing

x111 only processes personal data for specific, legitimate purposes. We do not collect data speculatively or store data beyond what is needed. Here are the specific reasons we use your information.

• Account Creation and Management: To open, maintain, and secure your x111 account. This includes verifying your identity, managing your balance, and processing your login credentials securely.
• Processing Financial Transactions: To handle PKR deposits via Easypaisa, JazzCash, NayaPay, SadaPay, bank transfer (IBFT), and card payments — and to process withdrawals back to your chosen method. Financial records are required for regulatory compliance and are essential to the operation of x111.
• Bet Settlement and Account History: To record, settle, and maintain a full history of all bets placed through your x111 account. This history is available to you in your account panel at any time.
• KYC and Fraud Prevention: To verify your identity in accordance with x111's licensing obligations, detect and prevent fraudulent activity, money laundering, and underage gambling. This is a legal obligation, not a commercial choice.
• Customer Support: To respond to your queries, resolve account issues, investigate complaints, and maintain a record of communications for quality assurance purposes.
• Responsible Gaming: To monitor account activity for signs of problematic gambling behaviour, to apply and enforce deposit limits or self-exclusion instructions set by you, and to fulfil x111's responsible gaming obligations under its licence.
• Platform Improvement: To understand how x111 players use the platform — which features are popular, where technical issues arise, and how the betting experience can be improved. This analysis uses aggregated, anonymised data wherever possible.
• Legal and Regulatory Compliance: To comply with obligations under x111's gaming licence, applicable anti-money laundering regulations, and any lawful requests from regulatory or law enforcement authorities.
• Marketing Communications: To send you promotional offers, new feature announcements, and x111 updates — but only if you have opted into receiving them. See Section 12 for details on how to opt out.

05 Legal Basis for Processing

x111 processes your personal data only where there is a valid legal basis for doing so. The applicable legal bases for different types of processing are as follows.

• Contractual Necessity: Processing your registration data, managing your account, handling deposits and withdrawals, and settling bets are all necessary to fulfil x111's contract with you as a registered player.
• Legal Obligation: Identity verification (KYC), anti-money laundering checks, age verification, and record-keeping for regulatory compliance are required by the terms of x111's gaming licence and applicable law.
• Legitimate Interests: Fraud prevention, platform security monitoring, and service improvement analytics are carried out on the basis of x111's legitimate interest in operating a safe, fair, and functional betting platform. In each case, x111 has assessed that this interest is not outweighed by your privacy rights.
• Consent: Sending you marketing communications by email or SMS is done only on the basis of your explicit consent. You may withdraw this consent at any time — see Section 12 for details.

06 Who x111 Shares Your Data With

x111 does not sell your personal data. We do not share it with advertisers. We share data with third parties only in the specific circumstances listed below, and only to the minimum extent necessary.

• Payment Processors: When you deposit or withdraw PKR, your transaction data is shared with the relevant payment processor — Easypaisa, JazzCash, NayaPay, SadaPay, your bank (for IBFT), or your card issuer. These providers process your financial data under their own privacy policies and under strict contractual obligations with x111.
• Identity Verification Providers: When KYC checks require third-party verification, x111 shares the minimum necessary identity data with certified identity verification providers. These providers are contractually obligated to use your data only for verification purposes.
• Game Content Providers: Some games available on x111, including the Aviator game, are provided by third-party game studios. These providers may receive anonymised session data necessary to operate the game. They do not receive your personal identity or financial information.
• Regulatory and Law Enforcement Authorities: x111 will share personal data with regulatory bodies or law enforcement agencies when legally required to do so — for example, in response to a lawful request relating to money laundering, fraud, or other criminal investigation. x111 is not required to notify you of such disclosures in all circumstances.
• Internal Group Companies: Where x111 operates as part of a group of companies, personal data may be shared within the group for the purposes of account management, compliance, and platform operations. All group companies are bound by equivalent data protection standards.

07 Cookies and Tracking Technologies

x111 uses cookies and similar technologies on the x111 platform. A cookie is a small text file stored on your device when you visit a website. Here is how x111 uses them.

• Essential Cookies: Required for basic platform functionality — including keeping you logged in during a session, maintaining your bet slip, and ensuring that security features work correctly. These cannot be disabled without breaking the platform.
• Performance Cookies: Used to collect anonymous data about how pages on x111 are used — which pages load slowly, where errors occur, and how navigation flows are working. This data is used exclusively to improve x111's technical performance.
• Functional Cookies: Used to remember your preferences on x111, such as your preferred language and display settings, so you do not have to re-enter them every session.
• Analytics Cookies: x111 uses analytics tools to understand aggregate traffic patterns and user behaviour on the platform. This data is anonymised and used only for platform development decisions.

You can control cookie preferences through your browser settings. Note that disabling essential cookies will prevent x111 from functioning correctly. Non-essential cookies can be disabled without affecting your ability to use core x111 features.

08 How x111 Keeps Your Data Secure

Security is not an optional extra for a platform that handles PKR transactions and personal identity documents. x111 implements the following technical and organisational security measures.

• SSL/TLS Encryption: All communications between your browser or device and x111 are encrypted using industry-standard SSL/TLS protocols. Every page on x111 — not just login and payment pages — is served over HTTPS.
• Payment Data Handling: x111 does not store full payment card numbers on its own servers. Card transactions are processed entirely through PCI-DSS certified payment processors. Easypaisa and JazzCash transactions are handled through their own secure API integrations.
• Access Controls: Access to personal data within x111's systems is restricted to staff members who need it to perform their specific role. Access rights are reviewed regularly and revoked immediately when no longer required.
• Incident Response: x111 maintains a documented data breach response plan. In the event of a security incident that puts your personal data at risk, x111 will notify affected players and relevant regulatory authorities within the timeframes required by applicable law.
• Infrastructure Security: x111's platform is hosted on secure, redundant infrastructure with regular security patching, vulnerability scanning, and penetration testing performed by independent security professionals.

While x111 takes all reasonable precautions, no online system is completely immune to all possible security risks. We strongly encourage players to use strong, unique passwords for their x111 account and to never share login credentials with anyone.

09 How Long x111 Keeps Your Data

x111 does not keep personal data for longer than is necessary for the purposes for which it was collected. The specific retention periods for different data categories are as follows.

• Account Data: Retained for the lifetime of your active x111 account, plus an additional period of at least five years after account closure to comply with regulatory and legal obligations.
• Transaction Records: All PKR deposit, withdrawal, and betting records are retained for a minimum of five years from the date of each transaction. This is required by x111's licensing obligations and anti-money laundering regulations.
• Identity Verification Documents: Retained for a minimum of five years from the date of verification, or five years after account closure, whichever is later. This is a regulatory requirement.
• Customer Support Communications: Retained for two years from the date of the last communication relating to a given query or dispute.
• Marketing Preferences: Records of your marketing consent or opt-out are retained for the duration of your account relationship with x111, to ensure we respect your preferences accurately.
• Technical and Usage Data: Server logs and anonymised usage analytics are typically retained for 12 months before deletion or further anonymisation.

When data is no longer required and no legal retention obligation applies, x111 deletes or permanently anonymises it in a secure manner.

10 Your Privacy Rights as an x111 Player

As an x111 player, you have the following rights regarding your personal data. To exercise any of these rights, contact x111 at support@x111.run with your registered mobile number and a clear description of your request.

• Right to Access: You can request a copy of the personal data x111 holds about you at any time. x111 will respond within 30 days of receiving a verified request.
• 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 or updated.
• Right to Erasure: You may request that x111 delete your personal data. Note that x111 may be unable to fulfil this request in full where legal retention obligations apply — for example, transaction records required for regulatory compliance. x111 will explain any limitations on erasure clearly when responding to such requests.
• Right to Object to Marketing: You have an absolute right to opt out of direct marketing communications from x111 at any time, without giving a reason. See Section 12 for details on how to unsubscribe.
• Right to Data Portability: You may request that x111 provides your personal data in a commonly used, machine-readable format for transfer to another service provider, where technically feasible.
• Right to Restrict Processing: In certain circumstances, you may request that x111 restricts how it uses your data — for example, while you dispute the accuracy of data x111 holds about you.

11 Children's Privacy

x111 is strictly an adults-only platform. Players must be 18 years of age or older to register an account, make a deposit, or place a bet. This is not simply a policy preference — it is a requirement of x111's gaming licence.

x111 employs age verification measures at registration and may request identity documentation to confirm age before processing withdrawals. x111 does not knowingly collect personal data from anyone under the age of 18.

If x111 becomes aware that a user under the age of 18 has created an account, that account will be immediately suspended, all associated bets will be voided, and all deposited funds will be returned to the depositing payment method following verification. x111 will not retain the personal data of underage users beyond what is needed for the return of funds and compliance reporting.

x111 supports the use of parental control software for households where minors have access to internet-connected devices. If you are a parent or guardian and believe a minor has accessed x111, please contact us at support@x111.run immediately.

12 Marketing Communications from x111

x111 may send promotional communications about new features, special offers, seasonal promotions, and platform updates. These communications are only sent to players who have opted into receiving them.

• Channels Used: x111 may communicate with opted-in players via SMS to their registered mobile number, and/or via email to their registered email address.
• Opt-Out Options: You can opt out of x111 marketing communications at any time by replying STOP to any SMS received, by following the unsubscribe link in any marketing email, or by contacting customer support directly and requesting removal from marketing lists.
• Effect of Opt-Out: Once you opt out, x111 will stop sending promotional communications within a reasonable processing period (typically within five business days). You will continue to receive transactional communications — such as deposit confirmations, withdrawal notifications, and account security alerts — regardless of your marketing preferences, as these are necessary for your account.
• No Third-Party Marketing: x111 does not share your contact details with third-party advertisers. All marketing communications you receive from x111 come from x111 directly.

13 Changes to This Privacy Policy

x111 may update this Privacy Policy from time to time as the platform evolves, as our legal obligations change, or as best practices in data protection develop. When we make material changes, we will:

• Notify registered x111 players via SMS or email to their registered contact details.
• Display a prominent notice on the x111 platform before the updated policy takes effect.
• Update the "Last Updated" date shown at the top of this page.

The most current version of the x111 Privacy Policy will always be available at x111.run/privacy-policy. We recommend checking this page periodically. Continued use of x111 after the effective date of an updated policy constitutes acceptance of the revised terms.

If you disagree with any change to this Privacy Policy, please contact us before the change takes effect so that we can address your concerns. If you cannot accept the updated terms, you may close your x111 account and any real-money balance will be processed for withdrawal in the usual way.

14 Contact Us and Privacy Complaints

If you have any questions about this Privacy Policy, about the personal data x111 holds about you, or about how to exercise your privacy rights, please get in touch.

• Email: support@x111.run — for privacy requests, data access requests, and formal privacy complaints. Please include your registered mobile number in your email so we can verify your identity efficiently.
• Live Chat: Available directly within the x111 platform 24/7 — for faster responses to straightforward questions about data or account settings.
• Response Time: x111 acknowledges privacy queries within 72 hours and aims to provide a full response within 30 days. Complex data requests may take up to 60 days — we will always communicate timelines clearly.