1. Introduction — Who We Are & What This Policy Covers
Scope of this Privacy Policy and the controller responsible for your data
This Privacy Policy applies to all products and services operated by 111 Games at 111games.ws — including the online casino, PSL and cricket betting, Aviator crash game, crash games suite, poker room, Refer a Friend programme and all promotional features. When you create an account, use the platform in any way or contact our support team, this policy governs how your personal information is handled.
111 Games acts as the data controller for personal data collected through the platform. That means we determine the purpose and means by which your personal information is processed. We take that responsibility seriously and have designed our data practices to be both lawful and genuinely respectful of your privacy.
This policy should be read alongside the 111 Games Terms and Conditions and Responsible Gaming guidelines. Together these three documents cover the complete framework governing your relationship with the platform. If anything here is unclear, contact us at support@111games.ws and we will explain it directly.
By registering an account at 111 Games, you acknowledge that you have read and understood this Privacy Policy. If you do not agree with how your data is processed under this policy, you should not create an account. If you already have an account and wish to withdraw consent for data processing, please contact our support team to discuss your options — though note that some processing is necessary to maintain an active account.
2. Personal Data We Collect at 111 Games
A complete breakdown of every category of data collected and why
111 Games only collects data that is genuinely necessary to deliver the service, comply with legal obligations or protect the platform's integrity. We do not collect data just because we can — every field in our forms has a specific purpose. Here is a breakdown of the main categories:
| Data Category | Examples | When Collected | Required? |
|---|---|---|---|
| Identity Data | Full name, date of birth, CNIC/Passport number | Registration & KYC verification | Required |
| Contact Data | Mobile number, email address | Registration | Required |
| Financial Data | Easypaisa/JazzCash account reference, bank account IBAN, Visa/MC last four digits | Deposits & withdrawals | Required |
| Transaction Data | Deposit amounts, withdrawal history, bet records, game results | During platform use | Required |
| Technical Data | IP address, device type, browser, operating system, session duration | Automatically on login | Required |
| Profile Data | Username, game preferences, bonus history, responsible gaming settings | During platform use | Required |
| Marketing Data | Promotional communication preferences, referral source | Registration (opt-in) | Optional |
| Support Data | Chat logs, ticket history, call recordings (if applicable) | When you contact support | Situational |
Data We Do Not Collect
111 Games does not collect your full payment card numbers (card payments are handled by PCI-DSS compliant processors who do not pass full card data to us), does not store biometric data, and does not collect sensitive special category data such as ethnicity, religion or health information except where legally required for responsible gaming compliance purposes.
3. How 111 Games Uses Your Personal Data
Every purpose for which your data is processed — stated plainly
111 Games processes your personal data for the following purposes. For each purpose, we have identified the legal basis that justifies the processing — this is covered in more detail in Section 4.
- Account creation and management — creating your player account, verifying your identity, maintaining your profile and preferences, and managing account-level settings including responsible gaming tools
- Processing deposits and withdrawals in PKR — receiving and sending funds via Easypaisa, JazzCash, NayaPay, SadaPay, bank IBFT and card payments; this requires sharing necessary data with our payment processing partners
- Delivering the gaming and betting service — operating casino games, PSL betting markets, Aviator, crash games and the poker room; recording game outcomes and settling bets correctly
- KYC and age verification — verifying that you are aged 18 or over and that your identity matches the payment methods used; this is a legal obligation we cannot waive
- Fraud prevention and platform security — detecting duplicate accounts, bonus abuse, collusion in poker, unusual betting patterns and potential money laundering; this protects all honest players on the platform
- Customer support — responding to queries, resolving disputes, processing responsible gaming requests and managing account complaints
- Responsible gaming compliance — monitoring play patterns for signs of problem gambling, applying player-set deposit limits and exclusions, and facilitating self-exclusion requests
- Legal and regulatory compliance — maintaining records required by applicable law, responding to lawful requests from authorities and fulfilling anti-money laundering obligations
- Platform improvement — analysing anonymised and aggregated usage data to improve site performance, add new features and optimise the user experience for Pakistani players
- Marketing communications — where you have opted in, sending information about promotions, bonuses, PSL betting offers and new features at 111 Games via SMS or email
We do not use your personal data for automated decision-making that produces legal or similarly significant effects on you — such as creditworthiness assessment or insurance pricing. Fraud detection flags are reviewed by a human team member before any account action is taken.
4. Legal Basis for Processing Your Data
Why we are legally entitled to process each category of data
Every processing activity at 111 Games rests on one of the following legal bases. Understanding which basis applies to which type of processing helps you know which rights you can exercise:
4.1 Contractual Necessity
Most core processing at 111 Games is necessary to deliver the service you signed up for. Processing your registration data to create your account, processing your financial data to handle PKR deposits and withdrawals, recording your game and bet results, and managing your account profile are all necessary to perform the contract between you and 111 Games. Without this processing, the service cannot function.
4.2 Legal Obligation
KYC identity verification, age verification, anti-money laundering record-keeping and reporting, and responsible gaming monitoring are all required by law or by the terms of our operating licence. We have no discretion about whether to perform this processing — it is mandated by applicable regulations. You cannot opt out of processing that falls under this basis while maintaining an active account.
4.3 Legitimate Interests
Fraud detection, platform security monitoring, system performance analysis and aggregated usage analytics are processed on the basis of 111 Games' legitimate interest in maintaining a secure, fair and well-functioning platform. These interests do not override your fundamental privacy rights — we have assessed and documented this balance.
4.4 Consent
Marketing communications — promotional SMS, email newsletters, bonus announcements and PSL betting offers — are only sent where you have given clear opt-in consent at registration or subsequently through your account settings. You can withdraw this consent at any time and it will not affect the rest of your account.
6. Payment Data, KYC & PKR Transactions
Specific rules for financial data — the most sensitive category we handle
Financial data is the most sensitive category of personal information handled by 111 Games and we treat it accordingly. Here is exactly how payment-related data is handled on the platform:
When you deposit via Easypaisa or JazzCash, your mobile wallet number is recorded against your 111 Games account as your registered payment method. This number is used to verify withdrawal requests — ensuring that withdrawals only go to the payment method used for deposits — and is stored in encrypted form in our database.
When you make a bank IBFT deposit or withdrawal, the bank account name and IBAN reference are recorded for the same purpose. For Visa and Mastercard card deposits, only the last four digits of your card number, the card type and expiry month/year are stored by 111 Games — full card numbers are handled exclusively by our PCI-DSS certified payment gateway provider and are never stored on 111 Games servers.
All financial data stored by 111 Games is encrypted at rest using AES-256 encryption and encrypted in transit using TLS 1.3. Access to financial data within our organisation is restricted to authorised staff on a need-to-know basis and is logged for audit purposes.
KYC documents — CNIC scans, passport copies and proof of address — are stored securely and accessed only by our compliance team for verification purposes. Document images are retained for the period required by applicable law (typically five years from account closure) and then securely destroyed.
7. Cookies, Tracking Technologies & Analytics
What cookies 111 Games uses and what you can do about them
7.1 Essential Cookies
111 Games uses essential session cookies to keep you logged in during your session, maintain your bet slip across pages and preserve your responsible gaming settings. These cookies are strictly necessary to provide the service and cannot be disabled while using the platform.
7.2 Functional Cookies
Functional cookies remember your language preference, the odds format you have selected (Decimal, Fractional or American) and whether you have dismissed certain on-screen notifications. These make your experience more convenient but are not critical to the platform functioning.
7.3 Analytics Cookies
We use analytics tools to understand how players navigate the platform — which pages load slowly, where players drop out of the registration flow, and which features are used most. This data is anonymised and aggregated before analysis. Individual-level browsing data is not retained beyond the analytics processing window. You can opt out of analytics cookies via your browser settings or by contacting support to set an opt-out preference on your account.
7.4 No Third-Party Advertising Cookies
111 Games does not allow advertising networks, retargeting platforms or social media trackers to place cookies on our pages. You will not be followed around the internet by 111 Games adverts based on cookies placed during your session on our site.
Your browser gives you full control over cookies. You can view, manage and delete cookies set by 111 Games at any time through your browser's privacy settings. Deleting essential session cookies will log you out. For a full list of cookies we use, contact support@111games.ws.
8. Data Retention — How Long We Keep Your Information
Specific retention periods by data category
111 Games retains personal data only for as long as necessary to fulfil the purpose for which it was collected or to comply with legal obligations. Here are our retention periods by data category:
Where an account is under investigation for fraud, money laundering or breach of Terms, relevant data may be retained beyond standard periods pending resolution of the investigation and any associated legal proceedings.
9. Security Measures — How We Protect Your Data
Technical and organisational security controls at 111 Games
111 Games implements a layered approach to data security that covers both technical controls and organisational practices. The following measures are in place to protect your personal data:
- SSL/TLS 1.3 encryption for all data in transit between your device and our platform — the padlock icon in your browser confirms an active encrypted connection
- AES-256 encryption for sensitive data stored in our databases, including financial identifiers and identity document data
- Role-based access controls ensuring that staff can only access the data they need for their specific job function — customer support agents do not have access to raw financial data or KYC documents beyond what is needed to resolve your query
- Two-factor authentication for all internal staff accounts with access to player data
- Regular security audits conducted by independent third-party security professionals covering our application, infrastructure and data handling procedures
- Intrusion detection systems monitoring for unauthorised access attempts, unusual query patterns and potential data exfiltration
- Secure data deletion procedures using industry-standard methods when data reaches its retention end date
Data Breach Notification: In the event of a data breach that poses a risk to your rights and freedoms, 111 Games will notify affected players within 72 hours of becoming aware of the breach. Notification will include the nature of the breach, the data affected, the steps we have taken to contain it and recommended actions for affected players.
Despite these measures, no internet-based system can guarantee absolute security. If you become aware of any security concern relating to your 111 Games account — unauthorised login attempts, unexpected password reset requests or suspicious activity — please contact support immediately via WhatsApp or live chat.
10. Your Privacy Rights as a 111 Games Player
The controls and rights you have over your personal data
You have specific rights over the personal data that 111 Games holds about you. Here is what each right means and how to exercise it:
Right to Access
Request a copy of all personal data 111 Games holds about you. We will provide this within 30 days of your request at no charge.
Right to Rectification
Request correction of any inaccurate personal data. Contact support with the correct information and we will update it promptly.
Right to Erasure
Request deletion of your personal data where we no longer have a lawful basis to retain it. Note: legal retention obligations (AML records) cannot be overridden by this right.
Right to Data Portability
Request your account data in a structured, machine-readable format (JSON/CSV) so you can transfer it elsewhere. Covers data you provided to us directly.
Right to Restriction
Request that we limit processing of your data while a dispute is under review or while you are exercising another right. Processing can be paused without full deletion.
Right to Object
Object to processing based on legitimate interests — including fraud analytics and aggregated usage analysis. We will cease that processing unless we can demonstrate compelling grounds.
How to Exercise Your Rights
To exercise any of the above rights, contact the 111 Games privacy team at support@111games.ws with the subject line "Privacy Request — [Your Right]". Include your registered mobile number and a description of your request. We will acknowledge your request within 48 hours and respond within 30 calendar days. If your request is complex or involves a large volume of data, we may extend this by an additional 30 days with notification.
We will need to verify your identity before processing any data request. This typically involves confirming your registered mobile number and answering security questions — the same process as account recovery. This step protects you from someone else requesting access to or deletion of your data.
11. Children, Minors & Age Protection
111 Games' strict approach to preventing underage access
111 Games is strictly an 18+ platform. We do not knowingly collect personal data from individuals under the age of 18. The registration process requires you to confirm your date of birth, and KYC verification is conducted to confirm age before withdrawals are permitted.
If we discover that an account has been created by a person under 18 — whether through KYC check, age verification inconsistency or any other means — the account will be closed immediately, all funds will be frozen and, in line with responsible gaming best practice, any deposited funds will be returned to the payment method used after verification that the payment method belongs to a guardian or responsible adult.
If you are a parent or guardian and believe that your child has created an account at 111 Games, please contact us immediately at support@111games.ws. We will investigate and close the account as a matter of priority. We take this more seriously than almost anything else on the platform.
12. Changes to This Privacy Policy
How updates work and how we notify you
111 Games reviews and updates this Privacy Policy periodically to reflect changes in our data processing activities, applicable law or platform features. The "Last Updated" date and version number at the top of this page change whenever the policy is revised.
Where we make significant changes — for example, adding a new category of data collection, sharing data with a new category of third party, or materially changing how we use existing data — we will notify registered players by SMS or in-platform notification at least 14 days before the changes take effect.
Minor clarifications, formatting corrections and non-material updates may be applied immediately and are reflected only in the version number change. Continued use of 111 Games after the effective date of any Privacy Policy update constitutes acceptance of the revised policy.
We recommend bookmarking this page. For any questions about this policy — including requests to exercise your rights or concerns about how your data is handled — email support@111games.ws with "Privacy" in the subject line. We aim to respond within 48 hours on business days.
This Privacy Policy (Version 2.4, January 2025) governs all data processing by 111 Games at 111games.ws. It is read alongside our Terms and Conditions and Responsible Gaming guidelines. Contact: support@111games.ws. For account closure, self-exclusion or responsible gaming assistance, our support team is available 24/7.