x111h Privacy Policy

1 Introduction & Scope

This Privacy Policy ("Policy") is issued by x111h ("we", "us", "our", "the Platform") and applies to all personal data processed in connection with your use of the x111h website at x111h.net, the x111h gaming and betting platform, and all related services including live casino, cricket and sports betting, slot gaming, arcade titles, account management, deposit and withdrawal processing, promotional programmes, and customer support.

This Policy applies to all users of x111h regardless of their location, including players accessing x111h from Karachi, Lahore, Islamabad, Faisalabad, Rawalpindi, Peshawar, and all other locations across Pakistan and internationally. By registering an x111h account or by using any x111h service, you acknowledge that you have read this Policy and consent to the data practices described herein.

This Policy should be read alongside the x111h Terms & Conditions, which govern the overall use of x111h services. Definitions used in the Terms & Conditions carry the same meaning in this Policy unless the context otherwise requires.

2 Data Controller

For the purposes of applicable data protection law, x111h is the data controller in respect of the personal data it collects and processes from players using the x111h platform. As data controller, x111h determines the purposes for which your personal data is processed and the means by which that processing is carried out.

x111h processes personal data in accordance with the data protection requirements imposed by its international gaming license and in alignment with internationally recognised privacy standards. Where x111h engages third-party service providers to process personal data on its behalf — such as KYC verification providers, payment processors, and fraud detection services — those providers act as data processors under written data processing agreements that bind them to the same data protection standards as x111h.

3 Personal Data We Collect

x111h collects personal data through several channels: directly from you when you register and use the platform; automatically through technical systems as you navigate and interact with x111h; and from third-party service providers such as KYC verification bureaus and payment processors.

3.1 Sensitive Data

x111h processes biometric-adjacent data (identity document scans including photographs) exclusively for the purpose of mandatory KYC age and identity verification as required under our gaming license. This data is processed by our certified KYC partner under strict data processing agreements. x111h does not collect or process sensitive personal data categories such as health information, political opinions, or religious beliefs, except where a player voluntarily discloses such information in a support communication — in which case it is used only to address the specific support query and is not stored beyond the resolution of that query.

4 How x111h Uses Your Personal Data

x111h uses the personal data it collects for the following specific purposes:

• Account Creation and Management: To register your x111h account, verify your identity and age (mandatory 21+ verification), manage your login credentials, and maintain your account in an accurate and current state;
• Service Delivery: To provide access to the full suite of x111h gaming and betting services including live casino, cricket betting, PSL markets, slot gaming, and arcade titles;
• Payment Processing: To process deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT (TRC20); to process withdrawal requests; to maintain your PKR wallet balance; and to manage currency conversion for cryptocurrency deposits;
• KYC and Anti-Money Laundering Compliance: To verify your identity, confirm your age, conduct AML screening, and fulfil all identity verification obligations imposed by our international gaming license and applicable regulatory requirements;
• Fraud Prevention and Security: To detect, prevent, and investigate fraudulent account activity, bonus abuse, collusion, and any other prohibited conduct as defined in the x111h Terms & Conditions;
• Responsible Gaming: To monitor player activity for indicators of problem gambling behaviour; to enforce player-set limits and self-exclusion elections; and to prevent re-registration by self-excluded players;
• Customer Support: To handle your support queries, complaints, and feedback via live chat and email, and to maintain records of support interactions for quality assurance;
• Marketing and Promotions: To send you promotional communications about x111h bonuses, new games, and special offers — but only where you have provided your consent to receive such communications. You may withdraw marketing consent at any time from within your account settings;
• Platform Improvement: To analyse aggregated and anonymised usage data to improve the x111h platform, game selection, user interface, and customer experience;
• Legal and Regulatory Obligations: To comply with all applicable legal, regulatory, and licensing obligations including responding to lawful requests from regulatory and law enforcement authorities.

5 Legal Bases for Data Processing

x111h processes your personal data on one or more of the following legal bases, depending on the purpose of processing:

• Contractual Necessity: Processing your identity data, contact data, financial data, and gaming activity data is necessary to perform the contract between you and x111h — i.e., to operate your account and deliver the x111h gaming and betting services you have registered to use;
• Legal Obligation: Processing your identity documents, conducting KYC verification, performing AML screening, and maintaining transaction records are required by x111h's international gaming license and applicable financial crime prevention obligations;
• Legitimate Interests: x111h processes technical data and communications data on the basis of its legitimate interests in preventing fraud, maintaining platform security, improving service quality, and managing risk — where these interests are not overridden by your data protection rights;
• Consent: x111h processes your data for direct marketing communications only where you have given your explicit consent at registration or subsequently through your account settings. You may withdraw this consent at any time without affecting the lawfulness of processing carried out prior to withdrawal.

6 Sharing Your Personal Data

x111h does not sell, rent, or commercially transfer your personal data to any third party. Your data is shared only in the following strictly defined circumstances:

• Payment Processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, and USDT payment processing partners receive the financial data necessary to process your deposit and withdrawal transactions. All payment processors are bound by financial industry data security standards;
• KYC and Identity Verification Providers: x111h shares identity document data with certified KYC and age-verification service providers solely for the purpose of conducting mandatory identity and age verification as required under our gaming license;
• Fraud Detection and Risk Services: Aggregated behavioural and technical data may be shared with fraud detection partners to identify and prevent fraudulent account activity, bonus abuse, and money laundering patterns;
• Game Providers: Where required by specific game providers to deliver their games on the x111h platform, limited technical session data may be shared. Game providers do not receive your identity or financial data;
• Regulatory and Law Enforcement Authorities: x111h may disclose personal data to gaming regulators, anti-money laundering authorities, and law enforcement agencies where required to do so by law, court order, or lawful regulatory demand;
• Professional Advisers: x111h may share personal data with its lawyers, auditors, and compliance advisers on a confidential, strictly need-to-know basis where required for the purposes of obtaining professional advice or managing legal proceedings.

7 International Data Transfers

Given that x111h operates under an international gaming license and uses globally distributed technology infrastructure, your personal data may be transferred to and processed in countries outside Pakistan. x111h ensures that all such international transfers of personal data are protected by appropriate safeguards, including:

• Contractual data protection clauses (equivalent to standard contractual clauses) binding all receiving entities to x111h's data protection standards;
• Transfer to recipients in jurisdictions that maintain data protection standards recognised as adequate by international privacy frameworks;
• Technical security measures including end-to-end encryption that apply regardless of the jurisdiction in which data is processed.

By using x111h services, you acknowledge that your personal data may be processed in jurisdictions outside Pakistan and that x111h will apply the protections described above to all such processing.

8 Data Retention

x111h retains your personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law and regulatory obligation. The following general retention periods apply:

• Account and Identity Data: Retained for the duration of your active x111h account, and for a minimum of five (5) years following account closure, as required by anti-money laundering regulations applicable under our gaming license;
• Financial Transaction Records: Retained for a minimum of seven (7) years from the date of each transaction, as required by financial record-keeping obligations;
• Gaming and Betting History: Retained for a minimum of three (3) years from the date of each gaming session or bet settlement;
• KYC Documentation: Retained in accordance with the retention periods specified in our gaming license terms, typically five (5) years from the date of the most recent KYC verification;
• Responsible Gaming Records: Self-exclusion records are retained permanently to prevent re-registration during any active or lapsed exclusion period. Other responsible gaming settings records are retained for the duration of your account plus three (3) years;
• Marketing Consent Records: Retained for as long as your account remains active. Upon withdrawal of consent, x111h will cease marketing communications within 10 business days and will retain a record of the consent withdrawal for compliance purposes.

Upon expiry of the applicable retention period, x111h will securely delete or anonymise your personal data so that it can no longer be linked to you as an individual.

9 Security Measures

x111h implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, loss, disclosure, alteration, or destruction. These measures include:

• Encryption: All data transmitted between your device and x111h is protected by 256-bit SSL/TLS encryption. Personal data stored in x111h databases is encrypted at rest using AES-256;
• Access Controls: Access to personal data within x111h's systems is restricted to personnel who require it for their specific operational role. Access is granted on a least-privilege basis and is subject to regular access review;
• Two-Factor Authentication: x111h offers and strongly recommends two-factor authentication (2FA) for all player accounts. When enabled, 2FA adds an additional verification layer to your x111h Login and withdrawal requests;
• Vulnerability Management: x111h conducts regular security assessments and penetration testing of its platform infrastructure. Critical vulnerabilities are patched on priority timelines;
• Incident Response: x111h maintains a data breach response plan. In the event of a personal data breach that is likely to result in a risk to your rights and freedoms, x111h will notify affected players without undue delay in accordance with applicable notification obligations.

While x111h implements robust security measures, no internet-based platform can guarantee absolute security. You are responsible for maintaining the security of your own x111h login credentials and for notifying x111h immediately via live chat if you suspect any unauthorised access to your account.

10 Cookies & Tracking Technologies

x111h uses cookies and similar tracking technologies on its website and platform. Cookies are small data files placed on your device that help x111h recognise you across sessions, maintain your login state, remember your preferences, and gather aggregate usage analytics.

10.1 Types of Cookies Used

• Strictly Necessary Cookies: Essential for the x111h platform to function. These cookies maintain your session state, enable x111h Login authentication, and support the security of your account. These cannot be disabled without affecting core platform functionality;
• Functional Cookies: Remember your platform preferences such as language settings, currency display, and game category filters, to provide a more personalised experience;
• Analytics Cookies: Collect anonymised and aggregated data about how players navigate and interact with x111h, used to improve platform design and performance. x111h uses analytics data in aggregate form only — it cannot be used to identify you as an individual;
• Responsible Gaming Cookies: Maintain session timing data used by x111h's responsible gaming time-tracking tools to support session reminders where you have enabled this feature.

You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will impair your ability to use x111h services, including x111h Login and the cashier.

11 Your Data Rights

As an x111h player, you hold the following rights in respect of your personal data. x111h will respond to all valid data rights requests within thirty (30) calendar days of receipt:

To exercise any of the above rights, please contact x111h via live chat from within your account after x111h Login, or send a written request to [email protected]. x111h may require you to verify your identity before processing a data rights request to ensure that personal data is not disclosed to or altered by an unauthorised party. x111h will not charge a fee for handling valid data rights requests unless a request is manifestly unfounded or excessive, in which case a reasonable administrative fee may apply.

12 Responsible Gaming Data

x111h treats responsible gaming data — including your self-set deposit limits, loss limits, session time reminders, cool-off elections, and self-exclusion records — with heightened care given its sensitive nature and its critical role in player protection.

Self-exclusion records are flagged permanently in x111h's systems and are cross-referenced at every subsequent registration attempt associated with the excluded player's identity data. This matching process uses your name, date of birth, and identity document number to prevent circumvention of self-exclusion through re-registration with different credentials.

x111h shares self-exclusion data with its affiliated platforms where this is required to give full effect to your self-exclusion election. This sharing is carried out under strict data processing agreements and is limited to the data necessary to enforce the exclusion. Responsible gaming data is never shared with third parties for any commercial purpose.

For more information about x111h's responsible gaming tools and how they work, please visit our Responsible Gaming page.

13 Children's Privacy

x111h services are strictly intended for individuals who are 21 years of age and older. x111h does not knowingly collect personal data from persons under the age of 21. Age verification is mandatory at the point of account registration, and x111h uses certified KYC verification processes to confirm that each registering user meets the minimum age requirement.

If x111h becomes aware that personal data has been collected from a person under the age of 21, the relevant account will be immediately suspended, the personal data will be deleted or anonymised as promptly as practicable, and any funds in the account will be returned to the source payment instrument less applicable processing fees, in accordance with x111h's underage account closure policy and the Terms & Conditions.

If you have reason to believe that a minor is using an x111h account, please contact x111h support immediately via live chat.

14 Changes to This Privacy Policy

x111h reserves the right to update or revise this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or platform services. Where changes are material, x111h will notify active account holders via the email address registered on their x111h account, or by displaying a prominent notice on the platform upon login, prior to the changes taking effect.

The effective date of the current version of this Policy is stated at the top of this document. We encourage you to review this Policy periodically to stay informed about how x111h protects your personal data. Your continued use of x111h following the effective date of any revised Policy constitutes your acceptance of the updated terms.

15 Contact & Data Enquiries

If you have any questions, concerns, or requests relating to this Privacy Policy or to x111h's data processing practices, please contact the x111h support and data team through the following channels: