111rr Privacy Policy

1 Introduction

111rr is committed to protecting the privacy and security of all members who use our platform. We recognise that your personal data is valuable and that you have a right to know exactly how it is handled. This Policy is written in clear, plain English so that every member — whether based in Dhaka, Chittagong, Sylhet, Khulna, or anywhere else in Bangladesh — can understand their rights and our obligations without legal expertise.

This Policy should be read alongside the 111rr Terms & Conditions, which govern the overall contractual relationship between you and 111rr. In the event of a conflict between this Policy and the Terms & Conditions on a data-specific matter, this Policy shall prevail. Both documents together constitute the full agreement between you and 111rr regarding the collection and use of your personal information.

111rr operates as an internationally licensed offshore gaming platform. While the Platform primarily serves players in Bangladesh, data may be processed by servers and service providers located outside Bangladesh. By using the Platform, you acknowledge and consent to such cross-border data transfers as described in Section 14 of this Policy.

2 Data Controller

For the purposes of applicable data protection law, 111rr acts as the Data Controller in respect of all personal data collected through the Platform. As Data Controller, 111rr determines the purposes for which personal data is processed and the means by which that processing is carried out.

Where 111rr engages third-party service providers (such as Game Providers including Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, and Ezugi, or payment processors such as bKash, Nagad, and Rocket) to process data on its behalf, those parties act as Data Processors under instruction from 111rr. 111rr remains responsible for ensuring that all Data Processors handle your information in compliance with this Policy.

For all data-related queries, correction requests, access requests, or erasure requests, you may contact the 111rr data privacy team directly at: [email protected] (please mark the subject line "Privacy Request" to ensure direct routing to the privacy team).

3 Information We Collect

111rr collects the following categories of personal information from members and platform visitors:

3.1 Identity & Contact Data

• Full legal name as it appears on a government-issued identity document.
• Date of birth (used to verify compliance with the 21+ age requirement).
• Residential address (street, city, district, postal code).
• Email address (used as primary account identifier and for correspondence).
• Mobile phone number (used for account security, SMS notifications, and payment verification).
• Nationality (collected at KYC stage for compliance screening).

3.2 Identity Verification (KYC) Documents

• National Identity (NID) card number and scanned copy or photograph.
• Passport (where NID is not available), including biographical data page.
• Driving licence (where accepted as a supplementary ID).
• Proof of address: recent utility bill, bank statement, or government letter not older than 3 months.
• Payment method verification: screenshot or confirmation of bKash, Nagad, or Rocket account registration matching your registered mobile number.

3.3 Financial & Transaction Data

• Deposit and withdrawal amounts, dates, and transaction reference numbers.
• Payment method identifiers (e.g., the last four digits of a mobile financial service account or bank account reference — never full account credentials).
• Bonus credit and wagering history.
• Account balance snapshots for regulatory compliance purposes.

3.4 Betting & Gaming Activity Data

• Sports bets placed: event, market, selection, odds, stake, and settlement outcome.
• Casino game sessions: game title, Game Provider, session duration, wager amounts, and outcome.
• VIP Programme tier progression and loyalty points history.
• Responsible gaming tool usage (e.g., deposit limits set, cooling-off periods activated).

3.5 Technical & Usage Data

• IP address and approximate geolocation derived from IP (country and city level only; not precise GPS coordinates).
• Device type, operating system, and browser type and version.
• Pages visited, session duration, click paths, and feature interactions on the Platform.
• Login timestamps and session identifiers.
• Error logs and crash reports (where applicable).

3.6 Communications Data

• Content of live chat transcripts initiated through the Platform support widget.
• Email correspondence sent to [email protected] and replies thereto.
• Survey responses and voluntary feedback submitted through the Platform.

4 How We Collect Data

111rr collects personal data through the following means:

• Direct Submission: Information you actively provide during account registration, KYC verification, deposit or withdrawal requests, contact form submissions, live chat sessions, and email correspondence.
• Automated Technical Collection: Data collected automatically when you access the Platform, including IP address, device information, session cookies, and usage analytics (see Section 9 for cookie details).
• Payment Processors: Transaction confirmation data (reference numbers, amounts, timestamps) passed to 111rr by payment partners such as bKash, Nagad, and Rocket when you initiate a deposit or withdrawal.
• Identity Verification Partners: Where 111rr uses a third-party KYC verification service, that service may return a verification result (confirmed / unconfirmed) and a risk score to 111rr. The underlying identity document is processed by the KYC partner under their own data protection terms, a copy of which is available on request.
• Fraud Prevention Services: Device fingerprint data and behavioural analytics returned by third-party fraud prevention tools integrated into the Platform login and payment flows.

5 How We Use Your Data

111rr processes your personal data for the following specific purposes:

111rr will not use your personal data for any purpose not listed in this Policy without first obtaining your explicit consent, except where required to do so by applicable law or a competent regulatory authority.

6 Legal Basis for Processing

111rr relies on the following legal bases to process personal data, consistent with international data protection principles:

• Contract Performance: Processing necessary to fulfil our contractual obligations to you under the Terms & Conditions — including account creation, game play, and payment services.
• Legal Obligation: Processing required to comply with applicable laws and regulations, including anti-money laundering (AML) obligations, Know Your Customer (KYC) requirements, and responsible gaming mandates.
• Legitimate Interest: Processing where 111rr has a genuine business need that does not override your privacy rights — such as fraud prevention, platform security, technical performance analytics, and improving our service quality.
• Consent: Processing based on your freely given, specific, and informed agreement — primarily for marketing communications and personalised promotional content. You may withdraw consent at any time through your account communication preferences without affecting the lawfulness of processing prior to withdrawal.

7 Data Sharing & Disclosure

111rr does not sell your personal data to any third party. We share personal data only in the following limited and controlled circumstances:

7.1 Service Providers (Data Processors)

We share data with carefully selected third-party service providers who process data on our behalf under contractual data protection terms. These include:

• KYC Verification Partners: Receive identity document data solely for the purpose of verifying member identity in compliance with age and fraud prevention requirements.
• Payment Processors: bKash, Nagad, Rocket, Upay, SureCash, and Bank Transfer partners receive transaction data necessary to process deposits and withdrawals.
• Game Providers: Evolution Gaming, Pragmatic Play, NetEnt, Microgaming, Spribe, Ezugi, and other licensed providers receive anonymised or pseudonymised session data to operate game engines and calculate outcomes.
• Cloud Infrastructure Providers: Server and storage providers that host the 111rr platform under strict data processing agreements.
• Fraud Prevention Tools: Third-party risk and compliance services that analyse behavioural signals to detect account takeover attempts and bonus abuse.

7.2 Legal & Regulatory Disclosure

111rr may disclose personal data to law enforcement agencies, regulatory bodies, or courts when required to do so by applicable law, court order, or where disclosure is necessary to protect the rights, property, or safety of 111rr, its members, or the public. 111rr will notify affected members of such disclosure where legally permitted to do so.

7.3 Business Transfers

In the event of a merger, acquisition, or sale of all or part of 111rr's business, member personal data may be transferred to the acquiring entity as part of the business assets. Members will be notified by email at least 30 days before any such transfer takes effect, with the option to close their account and request data deletion at that time.

8 Payment Data

111rr takes the security of financial data with the utmost seriousness. The following specific protections apply to payment-related personal data:

• Full mobile financial service account numbers (bKash PIN, Nagad account password, Rocket credentials) are never stored by 111rr. Payment authentication is handled entirely within the payment provider's own secure environment.
• Partial payment identifiers (e.g., the last four digits of a registered mobile number linked to bKash or Nagad) may be stored in encrypted form for transaction matching and withdrawal verification purposes.
• All payment data at rest is encrypted using AES-256 encryption. Data in transit uses TLS 1.2 or higher.
• Payment data is accessible only to authorised 111rr finance and compliance staff on a strict need-to-know basis. Access is logged and audited.
• 111rr will never request your full mobile banking PIN, password, or OTP through any communication channel including live chat, email, or phone. Any communication claiming to be from 111rr requesting such credentials should be treated as fraudulent and reported immediately to [email protected].

9 Cookies & Tracking Technologies

111rr uses cookies and similar tracking technologies to operate the Platform, enhance user experience, and gather anonymised analytics data. The following categories of cookies are in use:

You may manage your cookie preferences through your browser settings at any time. Please note that disabling strictly necessary or functional cookies may impair Platform functionality, including the ability to log in or access account settings. Disabling analytics and marketing cookies does not affect your ability to use any core Platform features.

111rr does not use cross-site tracking cookies that follow you across unaffiliated third-party websites. All cookie data collected on the 111rr Platform is used exclusively in connection with your 111rr account and the improvement of 111rr services.

10 Data Retention

111rr retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, subject to any legal or regulatory obligation to retain it for a longer period. The following retention schedule applies:

At the end of the applicable retention period, personal data is securely deleted or anonymised in a manner that prevents re-identification. Anonymised, aggregated data (e.g., platform-wide betting volume statistics) that cannot be linked back to any individual may be retained indefinitely for business analytics purposes.

11 Security Measures

111rr employs a multi-layered security architecture to protect personal data from unauthorised access, accidental loss, destruction, or disclosure. Key technical and organisational measures include:

• Transport Layer Security (TLS 1.2+): All data in transit between your browser and the 111rr platform is encrypted using a minimum of TLS 1.2 with strong cipher suites.
• AES-256 Encryption at Rest: Sensitive data fields (including identity document references and payment identifiers) are encrypted at the database level.
• Access Controls: Role-based access control (RBAC) restricts employee access to personal data on a strict need-to-know basis. All privileged access events are logged.
• Multi-Factor Authentication (MFA): All internal staff with access to member data systems are required to authenticate using MFA. Member accounts also support MFA for enhanced personal account security.
• Penetration Testing: 111rr conducts scheduled and ad-hoc penetration tests of its web application and infrastructure, with identified vulnerabilities remediated according to a risk-prioritised schedule.
• Intrusion Detection: Automated monitoring systems are in place to detect and alert on anomalous access patterns, failed login attempts, and data exfiltration indicators in real time.
• Data Breach Response: In the event of a confirmed data breach affecting member personal data, 111rr will notify affected members within 72 hours of becoming aware of the breach, with full details of the nature of the breach, data affected, and remediation steps taken.

12 Your Rights

As a data subject whose personal data is processed by 111rr, you hold the following rights. To exercise any of these rights, contact the 111rr privacy team at [email protected] with the subject line "Privacy Request — [Right Type]".

• Right of Access: You may request a copy of all personal data 111rr holds about you in a portable, machine-readable format. We will respond within 30 calendar days of a valid request.
• Right to Rectification: If any personal data held by 111rr is inaccurate or incomplete, you have the right to request correction. Minor account details (email address, phone number) can be updated directly from the account settings panel.
• Right to Erasure ("Right to be Forgotten"): You may request deletion of your personal data where no legal retention obligation applies. Note that data required for regulatory compliance, open disputes, or ongoing investigations may not be immediately erasable.
• Right to Restrict Processing: In certain circumstances (e.g., where the accuracy of data is contested, or where processing is unlawful but you prefer restriction over erasure), you may request that processing of your data be limited.
• Right to Data Portability: You may request that personal data you have provided to 111rr be transferred to you or to another service provider in a structured, commonly used, and machine-readable format (e.g., JSON or CSV).
• Right to Object: You may object at any time to processing of your personal data based on legitimate interest grounds, including profiling for marketing purposes. 111rr will cease such processing unless we can demonstrate compelling legitimate grounds that override your interests, or where processing is necessary for the establishment, exercise, or defence of legal claims.
• Right to Withdraw Consent: Where processing is based on your consent (primarily for marketing communications), you may withdraw that consent at any time through your account communication preferences panel. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal.
• Right Not to Be Subject to Automated Decision-Making: Where 111rr makes significant decisions about you solely through automated means (for example, an automated account suspension triggered by fraud detection), you have the right to request human review of that decision. To exercise this right, contact our support team immediately.

111rr will respond to all rights requests within 30 calendar days of receipt of a valid, verified request. In complex cases, this period may be extended by a further 30 days, in which case we will notify you of the extension and the reasons for it within the initial 30-day window.

13 Minors & Age Restriction

111rr strictly prohibits the registration and participation of individuals under the age of 21. Our platform is intended solely for adults aged 21 and above. We do not knowingly collect, store, or process personal data belonging to individuals under the age of 21.

During the registration and KYC verification process, 111rr takes active steps to verify the age of all applicants. Any account found to belong to an individual under 21 years of age will be immediately suspended, all winnings will be voided, and any deposited funds will be returned to the original payment source after deduction of any bonuses received. The relevant identity information may be retained for the legally required period to record the verification failure.

If you are a parent or guardian and believe that a minor in your care has created an account on the 111rr platform without your knowledge, please contact us immediately at [email protected]. We will prioritise the investigation and closure of any such account and the return of any deposited funds. For additional resources on protecting minors from online gambling, please visit our Responsible Gaming page.

14 International Data Transfers

111rr is an internationally operated platform. As a result, personal data collected from members in Bangladesh may be transferred to, stored in, or processed by servers and service providers located outside Bangladesh. This includes but is not limited to data processed by cloud infrastructure providers, KYC verification services, game engine providers, and fraud prevention tools operating in various international jurisdictions.

Where personal data is transferred outside Bangladesh, 111rr takes all reasonable steps to ensure that such transfers are carried out in compliance with applicable data protection standards. Specific safeguards employed include:

• Data Processing Agreements (DPAs) with all third-party service providers that receive member personal data, incorporating binding data protection obligations consistent with internationally recognised standards.
• Transfer Impact Assessments (TIAs) conducted for transfers to jurisdictions where data protection law is assessed as materially weaker than the standards set out in this Policy.
• Standard Contractual Clauses (SCCs) or equivalent mechanisms where required by the laws of the receiving jurisdiction.

By registering for and using the 111rr platform, you acknowledge and consent to the transfer of your personal data to international jurisdictions for processing as described in this Policy. If you wish to understand which specific countries or service providers your data may be transferred to, please submit a data access request to [email protected] and we will provide details relevant to your account.

15 Changes to This Policy

111rr reserves the right to update, amend, or replace this Privacy Policy at any time to reflect changes in applicable law, regulatory requirements, our business practices, or the services we offer. All changes to this Policy will be published on this page with the "Last Updated" date revised accordingly at the top of the document.

For material changes — defined as any change that significantly affects how we collect, use, or share your personal data — 111rr will provide at least 14 days' advance notice by sending an email to the address registered to your account and displaying a prominent notice on the Platform upon login. Continued use of the Platform after the effective date of a material change constitutes acceptance of the updated Policy.

For minor or non-material changes (such as formatting corrections, clarifications that do not alter the substance of data practices, or updates to contact information), notice will be provided solely through the updated publication on this page and no separate email notification will be sent.

We encourage all members to review this Privacy Policy periodically to remain informed about how 111rr protects their personal information. The current version of the Policy is always accessible at https://111rr.io/privacy-policy.

16 Contact & Complaints

111rr takes all privacy concerns seriously. If you have a question, concern, or complaint regarding the way in which your personal data is handled, please use the following contact channels:

16.1 Privacy Team Contact

For data access requests, rectification requests, erasure requests, or general privacy enquiries, contact the 111rr privacy team at:

Email: [email protected] — Subject line: "Privacy Request"

We aim to acknowledge all privacy communications within 2 business days (Bangladesh Standard Time, UTC+6) and to resolve all requests within the 30-day statutory period.

16.2 General Support

For account-related issues that are not specifically privacy requests (e.g., payment problems, game disputes, responsible gaming tool activation), please contact the general 111rr support team at [email protected] and your enquiry will be routed to the appropriate team.

16.3 Complaints Process

If you are dissatisfied with 111rr's response to a privacy concern, you have the right to escalate your complaint through the following process:

1. Step 1 — Internal Review: Submit a formal written complaint to [email protected] with the subject line "Formal Privacy Complaint". A senior member of the privacy team will review your complaint and provide a written response within 15 business days.
2. Step 2 — Escalation: If you remain unsatisfied after the internal review, you may request escalation to 111rr senior management for further consideration. Senior management will provide a final written position within 20 business days of the escalation request.
3. Step 3 — External Recourse: If internal resolution is not achieved, you retain the right to seek external recourse through the applicable data protection authority or through courts of competent jurisdiction. 111rr will cooperate fully with any lawful investigation or regulatory inquiry.