111ba Privacy Policy — How We Handle Your Personal Data

111ba ("we", "us", "the Platform") is committed to protecting the privacy and security of all personal data belonging to our players and users. This Privacy Policy explains what personal information we collect when you use 111ba.club, why we collect it, how we use it, who we may share it with, and how long we keep it. This policy applies to all users of the 111ba platform, including registered players, prospective players browsing the site, and individuals contacting our support team.

By registering an account on 111ba or by continuing to use the 111ba platform after this policy has been published, you acknowledge that you have read and understood this Privacy Policy and consent to the collection and use of your personal data as described herein. If you do not agree with this policy, you should not use the 111ba platform.

111ba collects personal information that you provide directly to us and information generated automatically through your use of the platform. The categories of personal data we collect include:

• Registration data: your mobile phone number (used as your account identifier), chosen password (stored in hashed form only), and date of birth for age verification purposes.
• Identity verification data (KYC): where required, a copy of a government-issued identity document and proof of payment method ownership, collected to comply with anti-money laundering obligations.
• Financial transaction data: deposit amounts, withdrawal requests, payment method identifiers (e.g. last four digits of a bKash or Nagad number), and transaction timestamps.
• Usage and gaming data: pages visited, games played, bet amounts, session duration, device type, browser type, operating system, and IP address.
• Communications data: the content of messages you send to the 111ba support team via live chat or email, used to resolve your enquiry and improve our support quality.

111ba does not request or store sensitive personal information such as national identity card numbers beyond what is minimally necessary for KYC, and we do not process biometric data. We do not collect data from children — 111ba is strictly for users aged 21 and above.

111ba uses personal data collected from players for the following purposes, all of which are necessary for the operation of the platform or required by applicable law:

• Account creation and management: to create and maintain your player account, authenticate your identity at login, and manage account preferences.
• Payment processing: to process your deposits and withdrawals via bKash, Nagad, Rocket, Upay and Bangladeshi bank transfer, and to verify that payment methods belong to the registered account holder.
• Legal compliance: to carry out know-your-customer (KYC) checks, comply with anti-money laundering (AML) requirements, and respond to lawful requests from regulatory or law enforcement authorities.
• Responsible gaming: to monitor gaming patterns that may indicate problem gambling behaviour and to apply any self-exclusion or account restriction tools activated by the player.
• Platform improvement: to analyse aggregate, anonymised usage patterns to improve platform performance, fix technical issues, and develop new features. Individual player data is never used for this purpose without anonymisation.
• Customer support: to respond to your queries, process complaints, and provide help through the 111ba live chat and email support channels.

111ba processes personal data under one or more of the following legal bases, depending on the specific processing activity:

• Contractual necessity: processing is required to perform the contract we have with you as a registered player, including account management, payment processing, and delivering gaming services.
• Legal obligation: processing is required to comply with applicable laws, including financial regulations, anti-money laundering requirements, and identity verification obligations.
• Legitimate interests: processing for platform security, fraud prevention, responsible gaming monitoring, and the improvement of our services where these interests do not override your fundamental privacy rights.
• Consent: where we send you optional marketing communications about promotions, new games, or seasonal offers, we do so only where you have given your explicit consent. You may withdraw consent at any time by contacting support.

Payment transactions on the 111ba platform are processed through established Bangladeshi payment gateways including bKash, Nagad, Rocket and Upay. When you make a deposit or withdrawal, the transaction is routed through the relevant payment processor's own secure systems. 111ba does not store your full bKash or Nagad account credentials on our servers — only a truncated reference identifier is retained to confirm which payment method is associated with your account.

For bank transfer deposits and withdrawals, 111ba retains only the information necessary to reconcile the transaction against your account — the sending bank name, a partial account reference, and the transaction amount and date. Full bank account numbers are not stored by 111ba. All financial data is subject to the retention periods required by applicable Bangladeshi financial regulations.

111ba uses cookies and similar browser-based storage technologies to operate certain essential platform functions and to gather anonymised analytics data. The types of cookies we use include:

• Strictly necessary cookies: session cookies required to keep you logged in during an active session, maintain your preferences, and prevent cross-site request forgery. These cannot be disabled without breaking core platform functionality.
• Analytics cookies: anonymised, aggregated data about which pages are visited and how users navigate the platform. This data contains no personally identifiable information and is used solely to improve user experience.
• Functional cookies: cookies that remember your language preference or other optional display settings to personalise your experience across sessions.

111ba does not use third-party advertising cookies or behavioural tracking cookies that follow you across other websites. You may manage cookie preferences through your browser settings. Please note that disabling strictly necessary cookies will affect core platform functionality including your ability to stay logged in.

111ba does not sell or rent personal data to any third party. We share personal data only in the following limited circumstances, and only to the extent necessary for each purpose:

• Payment processors: we share the minimum necessary transactional data with bKash, Nagad, Rocket, Upay and banking partners to process your deposits and withdrawals. These processors have their own privacy policies and security standards.
• KYC and identity verification providers: where a third-party identity verification service is used to process KYC documents, that provider receives only the specific documents submitted and processes them under strict data processing agreements with 111ba.
• Legal and regulatory authorities: where required by law, court order, or a lawful request from a competent authority, 111ba may disclose personal data to regulatory bodies, law enforcement agencies, or courts. We disclose only the minimum data required and, where legally permissible, will notify you of such a request.
• Platform technology providers: our hosting, infrastructure, and platform technology partners may process personal data on our behalf as data processors under contractual obligations that require them to apply the same level of data protection as 111ba.

111ba requires all third parties with whom personal data is shared to maintain appropriate technical and organisational security measures and to use your data solely for the specific purpose for which it was shared. We do not permit our service providers to use your personal data for their own marketing or commercial purposes.

111ba retains personal data only for as long as is necessary for the purpose for which it was collected, or as required by applicable law. In practice, this means: account data and transaction records are retained for a minimum of five years following account closure, as required by applicable financial and anti-money laundering regulations in Bangladesh. Active account data is retained for the duration of the account relationship.

Support communication records are retained for two years from the date of the interaction. Analytics data is retained in anonymised, aggregated form only and has no retention limit. When data is no longer required to be retained, it is securely deleted or irreversibly anonymised in accordance with our internal data deletion procedures.

111ba implements a comprehensive range of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction or disclosure. These measures include 256-bit SSL/TLS encryption for all data in transit, cryptographic hashing of passwords, role-based access controls that restrict internal access to personal data on a need-to-know basis, regular security audits of platform infrastructure, and server-side input validation to protect against common web application vulnerabilities.

While 111ba takes all reasonable steps to protect your data, no internet-based platform can guarantee absolute security. You play an important role in keeping your account secure — use a strong, unique password and do not share your login credentials with anyone. If you believe your account has been compromised, contact 111ba support immediately via live chat.

The 111ba platform is strictly intended for adults aged 21 and above. 111ba does not knowingly collect, solicit, or store personal data from any person under the age of 21. If we become aware that personal data has been collected from a person under 21 without verifiable parental or guardian consent, we will delete that data promptly. If you are a parent or guardian and believe that a minor has registered on the 111ba platform, please contact us immediately at [email protected].

111ba reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, legal obligations, or platform features. When material changes are made, we will post the updated policy on this page with a revised "Last Updated" date and, where appropriate, notify registered players via the account messaging system. Your continued use of the 111ba platform following the posting of any changes constitutes your acceptance of the updated Privacy Policy. We recommend reviewing this page periodically to stay informed.

If you have any questions, concerns or requests regarding this Privacy Policy or the way 111ba handles your personal data, please contact our support team via live chat on the platform or by email at [email protected]