Privacy Policy
How x111g Protects Your Data

This Privacy Policy ("Policy") is issued by x111g ("we", "us", "our", "x111g"), the operator of the online casino and sports betting platform accessible at x111g.org (the "Platform"). This Policy describes how x111g collects, uses, stores, shares, and protects the personal data of all individuals who access or use the Platform, including registered account holders, visitors browsing without an account, and any person who communicates with x111g's customer support team.

x111g is Pakistan's premier online casino and sports betting platform, serving players across Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, and all other cities and regions of Pakistan. We are committed to handling your personal data with the utmost care, transparency, and respect — in accordance with applicable data protection principles and the requirements of our international gaming licence.

This Policy applies to all data processing activities carried out by x111g in connection with the Platform, including registration, account management, payment processing, identity verification, game play, customer support, marketing communications, and fraud prevention. By accessing the Platform or registering an x111g account, you acknowledge that you have read, understood, and agree to the practices described in this Policy.

x111g collects personal data that is necessary for the provision of our services, compliance with our regulatory obligations, and the protection of our users and platform. The categories of personal data we collect are described below:

x111g does not collect sensitive personal data such as biometric data, health data, religious beliefs, or political opinions, except where strictly required by applicable law or regulation. We do not require or store full payment card numbers; all card-based payment processing is handled by PCI-DSS compliant payment processors, and x111g only retains tokenised references to card instruments.

x111g collects personal data through multiple channels, all of which are designed to be transparent and purposeful. We never collect data without a lawful reason for doing so. The primary collection methods are:

• Direct submission by you: When you register an x111g account, complete identity verification, make a deposit or withdrawal, contact our support team, or update your account settings, you directly provide us with personal data. This is the primary source of identity, contact, and financial data.
• Automated technical collection: When you access the x111g Platform, our systems automatically collect technical data including your IP address, device identifiers, browser details, and session information. This collection is necessary for platform security, fraud prevention, and service delivery.
• Game and betting activity logging: All game interactions, bet placements, and account transactions are logged automatically in x111g's secure server infrastructure. These logs form the authoritative record of account activity and are essential for dispute resolution and regulatory compliance.
• Cookies and tracking technologies: x111g uses cookies and similar technologies to maintain your login session, remember your preferences, and analyse how the Platform is used. Please see Section 7 of this Policy for full details of our cookie practices.
• Third-party verification providers: During the KYC and AML verification process, x111g may receive data from third-party identity verification services that cross-check the information you have provided against authoritative databases. This is a standard industry practice required under our gaming licence.
• Payment processors: When you transact via JazzCash, EasyPaisa, or Pakistani banking partners, those providers may share transaction reference data with x111g to confirm successful payments. x111g does not receive your full financial account credentials from these providers.

x111g uses your personal data exclusively for legitimate, disclosed purposes that are necessary for operating a safe, compliant, and enjoyable gaming platform for Pakistani players. The following table summarises the purposes for which we process your personal data:

x111g does not use your personal data for any purpose other than those listed above. We do not sell your personal data to third parties for their own marketing purposes under any circumstances.

x111g processes your personal data on the following lawful bases, depending on the nature and purpose of the processing activity:

• Contractual necessity: The majority of x111g's data processing is necessary for the performance of the contract between you and x111g — specifically, the x111g Terms & Conditions that you accepted at registration. This includes account creation, payment processing, game provision, and customer support.
• Legal obligation: x111g processes identity verification, AML screening, and transaction records as required by the terms of our international gaming licence and applicable financial crime prevention regulations. This processing is non-negotiable and cannot be opted out of as a condition of platform access.
• Legitimate interests: x111g processes technical and usage data for fraud prevention, platform security, and service improvement on the basis of our legitimate interests as a licensed gaming operator. We have assessed that these legitimate interests do not override users' privacy rights when appropriate safeguards are applied.
• Consent: Where x111g sends marketing communications or uses non-essential cookies, we rely on your freely given, informed consent. You may withdraw consent at any time without affecting the lawfulness of processing prior to withdrawal.

x111g shares your personal data only where it is strictly necessary for the provision of our services, fulfilment of our legal obligations, or protection of our platform and users. We never sell your data to third parties. The categories of recipients with whom x111g may share your data are:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, 1LINK, and card network processors (Visa/Mastercard acquiring banks). We share the minimum data required to process your transaction. All payment processors are contractually bound to use your data solely for payment processing purposes.
• Identity verification providers: Third-party KYC and AML service providers who assist x111g in verifying the identity and age of account holders as required under our gaming licence. These providers operate under strict data processing agreements and are not permitted to use your data for any other purpose.
• Regulatory and law enforcement authorities: x111g is legally obliged to share information with our gaming licence regulator, Pakistani financial intelligence authorities, and law enforcement agencies where required by law, court order, or regulatory directive. We cannot refuse such requests where a valid legal basis exists.
• Technology and infrastructure providers: Cloud hosting, database, cybersecurity, and platform infrastructure providers who process data on x111g's behalf under data processing agreements. These providers access only the minimum data required to provide their technical services.
• Responsible gaming support services: In cases where x111g identifies a player at risk under our Responsible Gaming Policy, we may share limited data with accredited problem gambling support organisations, strictly for the purpose of facilitating assistance to the player.
• Professional advisers: Legal counsel, auditors, and compliance advisers may access personal data as strictly necessary for the provision of professional services to x111g, subject to confidentiality obligations.

In all cases where x111g shares personal data with third parties, we ensure appropriate contractual safeguards are in place to protect your data and restrict third-party use to the disclosed purpose only.

x111g uses cookies and similar tracking technologies to operate the Platform, maintain your session, remember your preferences, and analyse how users interact with our site. A cookie is a small text file stored on your device by your browser at the instruction of the x111g Platform.

x111g does not use third-party advertising cookies or cross-site tracking cookies. We do not allow third-party advertising networks to place cookies on the x111g Platform. You can manage your cookie preferences through your browser settings or the x111g cookie consent manager, accessible from the footer of the Platform. Disabling essential cookies will affect your ability to use the Platform.

x111g retains personal data for as long as it is necessary for the purposes described in this Policy, including compliance with our gaming licence obligations and applicable legal retention requirements. The following retention periods apply:

• Active account data: Retained for the lifetime of your x111g account and for a minimum of five (5) years following account closure, as required under our gaming licence and applicable AML regulations.
• Financial transaction records: Retained for a minimum of seven (7) years following the date of each transaction, in compliance with financial record-keeping requirements under our international gaming licence.
• KYC and identity verification documents: Retained for the duration of your account and for five (5) years following account closure. Extended retention may apply where we are required to maintain records for ongoing regulatory investigations.
• Customer support communications: Retained for three (3) years from the date of each communication, for dispute resolution and quality assurance purposes.
• Marketing consent records: Retained for the duration of your account. Where you have withdrawn marketing consent, a record of that withdrawal is retained indefinitely as evidence of your opt-out.
• Technical and usage data: Aggregated and anonymised after twelve (12) months. Raw session and event logs are retained for up to six (6) months for security and fraud investigation purposes.

Following the expiry of the applicable retention period, x111g securely deletes or irreversibly anonymises your personal data. Where deletion is not immediately practicable (for example, where data is stored in backup systems), we will ensure the data is isolated from active processing until it can be securely deleted.

x111g employs a comprehensive suite of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. Our security infrastructure includes, but is not limited to:

• 256-bit SSL/TLS encryption for all data transmitted between your device and the x111g Platform;
• AES-256 encryption at rest for all personal data stored in x111g's database infrastructure;
• Multi-factor authentication (MFA) for all x111g internal staff who have access to personal data;
• Role-based access control (RBAC) ensuring that staff can only access the personal data they require to perform their specific duties;
• Real-time intrusion detection and automated threat response systems monitoring all Platform infrastructure 24/7;
• Regular independent penetration testing and security audits conducted by certified third-party security firms;
• Segregated storage for payment data, identity documents, and operational data with separate access controls for each data category;
• Comprehensive audit logging of all access to personal data by x111g staff, with logs retained for security investigation purposes.

While x111g takes all reasonable and industry-standard precautions to protect your data, no online platform can guarantee absolute security against all possible threats. In the event of a personal data breach that poses a risk to your rights and freedoms, x111g will notify the relevant regulatory authority and, where required, the affected users, in accordance with our breach notification obligations.

As an x111g user, you have a number of rights in relation to the personal data we hold about you. x111g is committed to facilitating the exercise of these rights promptly and without unnecessary barriers. Your rights are summarised below:

To exercise any of the above rights, please contact x111g's Data Protection Officer by emailing [email protected] with the subject line "Privacy Rights Request". Please include your registered account username and a description of the right you wish to exercise. We will respond within 30 days of receiving a verified request. Identity verification may be required before we process certain data rights requests.

x111g sends marketing communications — including promotional offers, bonus announcements, PSL season promotions, Ramadan specials, and Eid campaign notifications — only to users who have expressly opted in to receive such communications at the time of registration or subsequently via their account settings.

x111g's marketing communications are delivered via the following channels, depending on your preferences:

• Email to your registered email address;
• SMS to your registered Pakistani mobile number;
• In-platform notifications within the x111g Platform interface.

x111g will never send unsolicited marketing communications. You may unsubscribe from email and SMS marketing at any time by clicking the unsubscribe link in any x111g marketing email, by replying STOP to any x111g marketing SMS, or by updating your communication preferences in your account settings. In-platform notifications may be managed directly within the Platform's notification settings.

Please note that even if you opt out of marketing communications, x111g will continue to send transactional and service communications that are necessary for the operation of your account — such as deposit confirmations, withdrawal notifications, security alerts, and mandatory responsible gaming messages. These are not marketing communications and cannot be opted out of while your account remains active.

x111g operates a strict 21+ age policy across all products and services on the Platform. The x111g Platform is not directed at, and is not intended to be used by, any person under the age of 21. x111g does not knowingly collect personal data from anyone under the age of 21.

As part of the x111g registration process, all applicants are required to confirm that they are 21 years of age or older. x111g reserves the right to request age verification documentation (such as a Pakistani CNIC) at any time. Where x111g discovers or has reason to believe that an account has been registered by or on behalf of a person under 21 years of age, the following actions will be taken immediately:

• The account will be permanently closed and access suspended;
• All funds deposited will be returned to the original payment method after appropriate investigation;
• All winnings generated while the account was active will be forfeited;
• The matter may be reported to relevant authorities where required by law.

If you are a parent or guardian and believe that a minor under your care has registered or attempted to register an x111g account, please contact us immediately at [email protected]. x111g will act promptly on all such reports.

x111g is an internationally licensed gaming operator. The processing and storage of personal data collected from Pakistani users may involve transfer to and processing in countries outside Pakistan, including the jurisdiction in which x111g's gaming licence is issued and where our technology infrastructure providers are headquartered.

Where personal data is transferred internationally, x111g ensures that appropriate safeguards are in place to protect your data to a standard equivalent to that described in this Policy. These safeguards may include:

• Contractual data processing agreements incorporating standard data protection clauses with all international processors;
• Transfer only to jurisdictions that maintain adequate data protection standards as assessed by x111g's compliance team;
• Encryption of all data in transit across international network connections;
• Regular compliance audits of international data processing partners.

By registering an x111g account and using the Platform, you acknowledge and consent to the transfer of your personal data to x111g's processing locations as described in this section, subject always to the safeguards outlined above.

x111g reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, changes in applicable law, or changes in our services. When we make material changes to this Policy, we will notify registered users by publishing an updated version on the Platform with a revised effective date, and where appropriate, by sending a notification to your registered email address.

Your continued use of the x111g Platform following the effective date of any updated Privacy Policy constitutes your acceptance of the revised Policy. If you do not agree with the updated Policy, you should stop using the Platform and may close your account by contacting our support team.

We encourage you to review this Privacy Policy periodically to stay informed about how x111g protects your personal data. The version number and effective date at the top of this document will always reflect the most current version in force.

If you have any questions, concerns, or requests regarding this Privacy Policy or the way x111g processes your personal data, please contact our Data Protection Officer (DPO) using the details below. We are committed to responding to all privacy-related enquiries within 30 days.

For urgent account security matters — such as suspected unauthorised access, suspected identity theft, or a report of underage account use — please contact x111g's 24/7 live chat support directly via the Platform for the fastest possible response. Email enquiries are monitored during business hours and responded to within the 30-day window, but live chat is the recommended channel for time-sensitive matters.