Your Privacy Matters
to 111be

This Policy applies to all personal data collected by 111be through its website, mobile-optimised pages, and any other platform interface through which 111be services are made available to players in Bangladesh and elsewhere. It governs all data processing activities associated with account registration, gameplay, payment processing, customer support interactions, and marketing communications.

111be is committed to handling personal data responsibly and in accordance with applicable data protection principles. The platform operates from Bangladesh Standard Time (BST, UTC+6) and serves an audience based primarily in Bangladesh. All references to "you" or "your" in this Policy refer to any individual who accesses or uses the 111be platform.

If you have any questions about this Policy or about how 111be processes your personal data, you may contact the 111be data support team at the contact address provided in Section 13 of this Policy.

111be collects personal data across several categories depending on how you interact with the platform. The following table summarises the categories of personal data collected, together with specific examples of the data items within each category.

The majority of personal data 111be holds about you is data you have provided directly — either at the point of registration, during the KYC verification process, when making a deposit or withdrawal, or when contacting the support team. Providing accurate data is a condition of account eligibility under the 111be Terms & Conditions.

When you access the 111be platform, certain technical and usage data is collected automatically through server logs and cookies. This includes your IP address, browser type, device type, and the pages you visit within the platform. This data is used for security monitoring, fraud prevention, and platform performance analysis. It is not used to build advertising profiles for third-party commercial purposes.

111be may receive supplementary identity or fraud-screening data from third-party identity verification providers as part of the KYC process. 111be may also receive transaction confirmation data from payment partners such as bKash, Nagad, Rocket, and Upay when you make a deposit or withdrawal. This data is used solely for the purpose for which it was shared and is not combined with data from other sources for profiling.

111be uses your personal data only for the purposes described in this Policy. We do not use your data in ways that are incompatible with the purposes for which it was originally collected. The primary purposes for which 111be processes personal data are as follows:

• Account creation and management: To register your account, verify your identity, maintain your account profile, and enable you to log in and use the platform.
• Payment processing: To process deposits, credit winnings to your account balance, and execute withdrawal requests to your registered Bangladesh payment method (bKash, Nagad, Rocket, Upay, or bank account).
• Fraud prevention and security: To detect, investigate, and prevent unauthorised access, fraudulent transactions, money laundering, and other prohibited activities. This includes automated screening of transaction patterns and login behaviour.
• Legal and regulatory compliance: To fulfil obligations under applicable law, including responding to lawful requests from government authorities or law enforcement agencies, maintaining financial records, and conducting KYC as required.
• Customer support: To respond to your queries, resolve disputes, investigate complaints, and provide assistance through live chat, email, and other support channels.
• Responsible gaming: To monitor for patterns of problem gambling behaviour, apply player-requested deposit limits, cooling-off periods, and self-exclusion requests, and to comply with responsible gaming obligations.
• Platform improvement: To analyse how players use the platform and identify areas for improvement, fix bugs, optimise game loading, and develop new features. Analysis is performed on aggregated or anonymised data wherever possible.
• Marketing communications: To send promotional emails, SMS messages, or push notifications about bonuses, seasonal promotions (BPL, IPL, T20 World Cup, Eid, Pohela Boishakh), and new platform features — subject to your marketing preferences. See Section 11 for opt-out information.

111be processes your personal data on the following legal bases, depending on the specific processing activity:

• Contractual necessity: Processing that is required to fulfil the contract between you and 111be — including registering your account, processing payments, and providing access to betting and casino products.
• Legitimate interests: Processing that is necessary for 111be's legitimate business interests — including fraud prevention, security monitoring, platform improvement, and responsible gaming monitoring — provided those interests are not overridden by your rights and interests.
• Legal obligation: Processing that 111be is required to carry out under applicable law — including KYC identity verification, financial record-keeping, and disclosure to law enforcement authorities where legally required.
• Consent: Processing that is based on your freely given, specific, and informed consent — primarily in the context of marketing communications. Where consent is the legal basis, you have the right to withdraw it at any time without affecting the lawfulness of prior processing.

111be shares personal data with third parties only where necessary and only for the purposes described in this Policy. The categories of third parties with whom data may be shared are as follows:

When you make a deposit or request a withdrawal, 111be shares the necessary financial data with your chosen Bangladesh payment provider — bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank, City Bank, Islami Bank, or Sonali Bank — to complete the transaction. These providers process your data under their own privacy terms and are responsible for the security of the transaction on their end.

During the KYC process, 111be may share identity documents and personal details with third-party verification providers who specialise in document authentication and fraud screening. These providers are contracted to process data solely for identity verification purposes and are not permitted to use it for any other purpose.

Certain game providers — including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi — may receive your player session identifier and relevant game data when you launch a game hosted on their platform through 111be. This data is limited to what is operationally necessary and does not include your full identity profile.

111be will disclose personal data to government authorities, law enforcement agencies, or regulatory bodies where required to do so by applicable law, a court order, or a binding legal process. 111be will notify affected players of any such disclosure where legally permitted to do so.

111be uses third-party cloud hosting and IT infrastructure providers to operate the platform. These providers may have access to platform data as part of their hosting services but are contractually bound not to use that data for any purpose other than providing the contracted infrastructure services.

111be uses cookies and similar tracking technologies to operate the platform, improve user experience, and support security and fraud prevention functions. Cookies are small text files stored on your device when you visit the 111be website.

You can manage cookie preferences in your browser settings. Note that disabling non-essential cookies may affect certain platform features. 111be does not use third-party advertising cookies or share cookie data with advertising networks.

111be retains personal data only for as long as necessary for the purpose for which it was collected, or as required by applicable legal, regulatory, or financial record-keeping obligations. The following general retention periods apply:

• Account and identity data: Retained for the duration of your account plus a minimum of 5 years following account closure, in compliance with anti-money laundering and financial record-keeping requirements.
• Transaction and payment records: Retained for a minimum of 7 years from the date of each transaction, in line with financial compliance requirements.
• KYC verification documents: Retained for the duration of your account plus 5 years following closure. Physical or scanned copies of ID documents are deleted or securely destroyed once the retention period expires.
• Customer support records: Retained for 3 years from the date of the last support interaction, unless a dispute or legal matter requires longer retention.
• Marketing preferences and consent records: Retained for the duration of your account plus 2 years, to enable 111be to demonstrate compliance with consent requirements.
• Device and technical data (logs): Retained for up to 12 months from the date of collection, after which they are automatically purged unless required for an ongoing fraud or security investigation.

When the applicable retention period expires, data is securely deleted, anonymised, or pseudonymised in accordance with 111be's internal data lifecycle procedures. Anonymised data that no longer identifies any individual may be retained indefinitely for statistical and performance analysis purposes.

111be implements a multi-layered security framework to protect your personal data against unauthorised access, loss, alteration, or disclosure. The measures in place include:

• Transport Layer Security (TLS/SSL): All data transmitted between your device and the 111be platform is encrypted using industry-standard TLS encryption. Look for the padlock symbol in your browser address bar when using the platform.
• Encrypted storage: Sensitive data fields — including identity document references, payment account identifiers, and passwords — are stored in encrypted form. Passwords are hashed using a strong one-way algorithm and are never stored in plain text. 111be staff cannot read your password.
• Access controls: Internal access to personal data is restricted on a strict need-to-know basis. Staff with access to personal data are subject to confidentiality obligations and receive data protection training.
• Two-factor authentication (2FA): 111be supports 2FA for player accounts via registered Bangladesh mobile numbers. 111be strongly recommends activating 2FA to add an additional layer of protection to your account.
• Intrusion detection and monitoring: The platform is monitored continuously for unusual access patterns, login anomalies, and potential security threats. Automated alerts are triggered for suspicious activity.
• Routine audits: 111be conducts regular internal security reviews of its data handling practices, infrastructure configurations, and access logs.

As a player whose personal data is held by 111be, you have the following rights in relation to that data. All rights requests should be submitted to the contact address in Section 13 of this Policy.

• Right of access: You have the right to request a copy of the personal data 111be holds about you, together with information about how it is used. 111be will respond to access requests within a reasonable timeframe.
• Right to rectification: If any personal data 111be holds about you is inaccurate or incomplete, you have the right to request that it be corrected. Basic profile data can be updated directly in your account settings; corrections to KYC data require written request to support.
• Right to erasure ("right to be forgotten"): You may request that 111be delete your personal data. This right is subject to limitations — 111be may be required to retain certain data to comply with legal obligations (see Section 7). Where deletion is possible, it will be completed within a reasonable period of the request being verified.
• Right to restrict processing: In certain circumstances, you may request that 111be restrict the processing of your data — for example, while a data accuracy dispute is being resolved.
• Right to data portability: You have the right to receive a copy of the personal data you provided to 111be in a structured, machine-readable format, where technically feasible.
• Right to object: You have the right to object to processing based on legitimate interests, including profiling for marketing purposes. You may also opt out of marketing communications at any time (see Section 11).
• Right to withdraw consent: Where processing is based on your consent (primarily marketing), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before withdrawal.

111be will not discriminate against any player who exercises their privacy rights. Exercising your rights will not affect your ability to use the platform, subject to the minimum data requirements necessary to maintain a verified account.

Where 111be discovers that personal data has been collected from an individual who was under 21 at the time of registration, that data will be deleted promptly and the account will be permanently closed. Any balances held in such accounts may be withheld subject to investigation.

111be strongly recommends that parents and guardians of minors install parental control software on devices that may be used to access online platforms, to prevent minors from accessing age-restricted services. If you share a device with a minor, ensure that your 111be account is protected by a strong, unique password and that 2FA is activated.

With your consent, 111be may send you marketing communications by email, SMS, or push notification. These communications may include information about welcome bonuses, reload offers, seasonal promotions (BPL, IPL, T20 World Cup, Eid, Pohela Boishakh, Victory Day), new games, and platform features.

You may opt out of marketing communications at any time by:

• Using the "Unsubscribe" link included at the bottom of every marketing email.
• Replying "STOP" to any marketing SMS message received from 111be.
• Updating your notification preferences in your 111be account profile settings.
• Contacting 111be support directly at the address in Section 13 with a written opt-out request.

Opting out of marketing communications will not affect transactional communications — 111be will continue to send you messages that are necessary for operating your account, such as deposit confirmations, withdrawal notifications, security alerts, and important policy updates. These communications are sent on the basis of contractual necessity and cannot be opted out of while your account remains active.

111be will never send marketing communications to players who are self-excluded. If you receive a marketing message following a self-exclusion request, please contact support immediately so the issue can be investigated and resolved.

111be reserves the right to update or amend this Privacy Policy at any time. Changes may be made to reflect updates in applicable law, changes to our data processing practices, new platform features, or feedback from players or advisors.

When material changes are made to this Policy, 111be will notify registered players by email at their registered email address, or by displaying a prominent notice on the 111be platform, at least 14 days before the changes take effect. The "Last updated" date at the top of this page will always reflect the date on which the most recent version of the Policy was published.

Your continued use of the 111be platform following notification of any changes constitutes your acceptance of the updated Policy. If you do not agree with the updated Policy, you should stop using the platform and contact support to request account closure.

We encourage all players to review this Privacy Policy periodically to stay informed about how 111be protects their personal data. Archived versions of previous Policy editions are available on request by contacting support.

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, want to submit a data correction or deletion request, or need to report a privacy concern, please contact the 111be data support team using the details below.

For urgent security matters — such as suspected unauthorised access to your account — please mark your email subject line as "URGENT — Security" so it is prioritised by the support team. All privacy and data requests are handled confidentially by designated 111be staff and are never shared with general customer service representatives without necessity.