Privacy Policy — x111cm

x111cm ("we", "us", "our", "the Platform") is committed to protecting the privacy of all individuals who access or use the services available at https://x111cm.cam. This Privacy Policy describes how we collect, process, store, share and protect personal data in connection with our online betting and live casino services.

This Policy applies to all users of the x111cm platform, including registered account holders, visitors who browse without registering and individuals who contact our support team. It covers personal data collected through the website, mobile web interface and any communications channels operated by x111cm.

By accessing the platform, creating an account or submitting any personal data, you acknowledge that you have read and understood this Privacy Policy and consent to the processing of your data as described herein. If you do not consent, you must not use the platform and should contact us to request deletion of any data we may already hold.

This Policy should be read alongside our Terms & Conditions, which govern the overall use of the x111cm platform.

In this Privacy Policy, the following terms carry the meanings set out below:

x111cm acts as the Data Controller for all personal data collected through the platform at https://x111cm.cam. As Data Controller, we are responsible for determining the purposes and means by which your personal data is processed and for ensuring that processing is conducted lawfully, fairly and transparently.

x111cm operates under the licensing framework of its applicable operating jurisdiction. The platform does not hold a locally issued Pakistani gambling licence and does not claim any authorisation from the Government of Pakistan, the Pakistan Telecommunication Authority (PTA), the State Bank of Pakistan, or any Pakistani provincial authority.

For all data-related enquiries, please contact our support team using the details in Section 15 of this Policy.

x111cm collects personal data across several categories depending on your level of interaction with the platform. The table below sets out the main data categories and illustrative examples:

We do not intentionally collect special-category personal data (such as health information, religious beliefs or biometric data used for identification) except where a liveness check is conducted as part of KYC and solely for that verification purpose.

x111cm collects personal data through the following channels:

• Direct submission: Data you provide when registering an account, completing a KYC form, submitting support requests or corresponding with our team;
• Automated collection: Technical and usage data collected automatically during your sessions via cookies, server logs and analytics tools (see Section 11);
• Identity verification providers: Data returned from authorised KYC sub-processors following document verification and liveness checks;
• Payment processing infrastructure: Transaction confirmation data and payment method identifiers returned from payment routing systems;
• Fraud detection systems: Risk scores and device fingerprinting data generated by fraud-prevention sub-processors during account activity monitoring;
• Publicly available sources: Where permitted, we may supplement account information with data available from official public registries for AML screening purposes.

x111cm processes personal data only for defined purposes. The principal purposes and their corresponding legal basis are set out below:

x111cm does not use personal data for automated profiling that produces significant legal effects, nor for behavioural advertising to third-party networks. Where we rely on legitimate interest as a legal basis, we conduct a balancing test to ensure that our interests do not override your fundamental rights and freedoms.

x111cm shares personal data with third parties only in the circumstances described below. We do not sell personal data to any third party. We do not share data with advertisers or data-broker platforms.

• Identity verification sub-processors: Authorised KYC and liveness-check providers engaged to verify documents submitted during account verification. These providers process data only on our instruction and under binding data processing agreements.
• Payment infrastructure providers: Third-party payment routing and processing systems necessary to facilitate deposits and withdrawals. Payment method names referenced on x111cm — including Easypaisa, JazzCash, Raast, HBL, UBL, Meezan Bank, Bank Alfalah, BTC and USDT — are contextual references. Their mention does not imply partnership, endorsement or support for gambling by these institutions.
• Fraud prevention and AML compliance systems: Risk-scoring and transaction monitoring services used to detect and prevent fraud and money laundering.
• Regulatory and law enforcement authorities: Where required by applicable law, court order or regulatory instruction. x111cm will comply with lawful data requests from competent authorities.
• Professional advisers: Legal, compliance, audit and accountancy professionals, subject to professional confidentiality obligations.
• Business succession: In the event of a merger, acquisition or asset sale involving x111cm, user data may be transferred to a successor entity, with advance notice provided to affected users where legally permissible.

x111cm and its sub-processors may process personal data in countries outside Pakistan and potentially outside the jurisdiction in which the platform is licensed. Where data is transferred internationally, x111cm ensures that appropriate safeguards are in place, which may include:

• Standard contractual clauses approved by applicable data protection authorities;
• Transfers to jurisdictions recognised as providing adequate data protection;
• Binding corporate rules where applicable within a group structure.

Users in Pakistan should note that their personal data will be processed in the platform's operating jurisdiction and potentially in other territories where sub-processors are located. By using x111cm, you consent to such international processing subject to the safeguards described in this Policy.

x111cm retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, or as required by applicable law or regulatory obligation. The following general retention principles apply:

• Active account data: Retained for the duration of the account relationship and for a defined period following account closure, as required to meet AML and regulatory record-keeping obligations.
• KYC documentation: Retained for the period required by the applicable AML regulatory framework — typically a minimum of five years from the end of the customer relationship.
• Transaction records: Retained for a minimum of five years to meet financial record-keeping requirements.
• Support communications: Retained for a period sufficient to resolve disputes and meet any applicable limitation periods.
• Technical and usage logs: Typically retained for a shorter rolling period unless required for specific investigations.

Upon expiry of the applicable retention period, data is either securely deleted using appropriate data-destruction methods or anonymised such that it can no longer be linked to an identifiable individual.

x111cm implements a range of technical and organisational measures designed to protect personal data against unauthorised access, disclosure, alteration or destruction. These measures include, but are not limited to:

• TLS encryption for all data in transit between user devices and platform servers;
• Encryption of sensitive data at rest, including identity documents and financial data;
• Role-based access controls limiting staff access to personal data to those with a legitimate operational need;
• Regular security assessments and penetration testing;
• Two-factor authentication (2FA) options for user accounts;
• Logging and monitoring of access to sensitive data stores.

While x111cm takes these security measures seriously, no system is completely impenetrable. In the event of a data breach that is likely to result in a risk to affected individuals, x111cm will notify relevant parties in accordance with applicable legal requirements.

x111cm uses cookies and similar technologies (including local storage and session tokens) to operate the platform, remember user preferences and analyse usage patterns. The following cookie categories are used:

x111cm does not use third-party advertising cookies or cross-site tracking technologies for behavioural advertising. Most web browsers allow you to control cookie settings through their preferences menu. Disabling certain cookies may affect platform functionality.

Subject to applicable law and our legal obligations (including AML record-keeping requirements), you have the following rights in relation to your personal data:

To exercise any of the above rights, please submit a request to x111cm's support team using the contact details in Section 15. We will respond within a reasonable timeframe. Note that certain rights may be limited where we have overriding legal obligations — for example, AML regulations may prohibit deletion of certain transaction records during a mandatory retention period.

x111cm is strictly an adults-only platform. Access and account registration is prohibited for any person under the age of 18, or the higher minimum age required by the applicable operator or license jurisdiction. We do not knowingly collect personal data from individuals under the applicable minimum age.

x111cm employs KYC verification procedures specifically to prevent access by underage individuals, including identity document checks and liveness verification that enable age confirmation. Where we become aware or have reasonable grounds to suspect that data has been collected from a minor, we will immediately suspend the account and delete the associated data (subject to any overriding legal obligation to retain evidence of the incident).

x111cm reserves the right to amend this Privacy Policy at any time to reflect changes in our data practices, platform functionality or applicable legal requirements. Material changes will be communicated to registered users via the email address on file or through a prominent notice on the platform prior to the change taking effect.

The effective date displayed at the top of this page indicates the version currently in force. We encourage users to review this Policy periodically. Your continued use of the platform following any amendment constitutes acceptance of the revised Policy.

For any questions, concerns, access requests or complaints relating to this Privacy Policy or the processing of your personal data, please contact x111cm's support team through the following channels. Please note that the email address below is displayed as plain text and is not a clickable link.