Privacy Policy
— 111 bat Platform

111 bat collects personal data through several channels during your interaction with the platform. The categories of data we collect, and the circumstances in which they are gathered, are described below.

1.1 Registration Data

When you create an account on 111 bat, we collect the information you provide directly, including:

• Full legal name
• Date of birth (required for age verification — Members must be 18 or older)
• Residential address, including city (e.g., Dhaka, Chittagong, Sylhet, Khulna, Rajshahi)
• Email address
• Mobile phone number
• Username and encrypted password
• Preferred currency (BDT only on this platform)

1.2 Identity Verification (KYC) Data

To comply with our Know Your Customer (KYC) obligations and to process withdrawals, we collect copies of:

• Government-issued photo identification (National ID card, passport, or driving licence)
• Proof of address documentation (utility bill, bank statement dated within three months)
• Where required: source-of-funds documentation or a selfie with valid ID

KYC documents are used exclusively for identity and age verification purposes and are handled with the highest level of data security on the 111 bat platform.

1.3 Financial Transaction Data

When you make deposits or request withdrawals, 111 bat records transaction-level data including:

• Payment method type (bKash, Nagad, Rocket, Upay, Visa, Mastercard, bank transfer)
• Mobile financial service number or masked card number associated with the transaction
• Transaction amounts in BDT (৳)
• Transaction timestamps and reference numbers

111 bat does not store full card numbers. Card payment processing is handled by PCI-DSS compliant payment processors, and raw card data does not pass through or reside on 111 bat's servers.

1.4 Behavioural and Usage Data

As you navigate the 111 bat platform, we automatically collect technical and behavioural data, including:

• IP address and approximate geographic location (country and city level)
• Device type, operating system, and browser version
• Pages visited, features accessed, and time spent on each section
• Game sessions played, bet amounts, wagering history, and outcomes
• Login timestamps and session durations
• Referring URL (the page or link that directed you to 111 bat)

This data is used to improve platform performance, detect suspicious activity, and personalise your experience where you have opted in to such features.

1.5 Communications Data

When you contact 111 bat through live chat, email, or any other support channel, we retain records of those communications, including the content of messages, timestamps, and any attachments. This data is used to resolve your enquiry, improve our support quality, and maintain an accurate record of interactions for compliance purposes.

111 bat uses the personal data it collects for specific, documented purposes. We do not use your data for any purpose beyond those listed below without first obtaining your consent or where we are permitted to do so under applicable law.

Marketing Communications: 111 bat will only send you promotional emails or SMS messages if you have explicitly opted in during registration or via your account settings. You may withdraw your consent to marketing communications at any time by updating your notification preferences within your account settings panel or by contacting our support team via live chat. Withdrawal of marketing consent does not affect the lawfulness of processing carried out before withdrawal.

111 bat does not sell, rent, or trade your personal data to third parties for their own marketing or commercial purposes. We share your data only in the limited circumstances described below, and only to the extent strictly necessary for the stated purpose.

3.1 Service Providers and Technology Partners

We engage trusted third-party service providers who process data on our behalf under strict contractual data protection obligations. These include:

• Payment processors: bKash, Nagad, Rocket, Upay, and card payment networks (Visa, Mastercard) — to process deposits and withdrawals in BDT.
• Game providers: Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, Ezugi, and other licensed studios — these providers receive session-level game data to operate game software. They do not receive your full identity documents.
• KYC and identity verification services: Third-party identity verification partners who assist in validating government-issued documents submitted during the KYC process.
• Platform infrastructure and hosting providers: Cloud and server infrastructure providers used to operate the 111 bat platform. All hosting arrangements include contractual data security obligations.
• Analytics providers: Aggregated, anonymised usage data may be processed by analytics tools to help us understand platform performance. No personally identifiable information is shared in this context.

3.2 Legal and Regulatory Disclosure

111 bat may disclose your personal data to law enforcement agencies, regulatory bodies, or other authorities where we are required to do so by applicable law, court order, or official request. We may also disclose data where we reasonably believe disclosure is necessary to prevent financial crime, fraud, or harm to Members or third parties.

3.3 Business Transfers

In the event that 111 bat undergoes a merger, acquisition, or sale of all or part of its assets, Member data may be transferred to the acquiring entity as part of that transaction. You will be notified of any such transfer and any material change to how your data is processed via a prominent notice on the platform or by email to your registered address.

3.4 What We Do Not Do

• We do not sell your personal data to advertisers or data brokers.
• We do not share your full identity documents with game providers.
• We do not share your financial account details (bKash number, bank account) with any party other than the payment processor facilitating your specific transaction.
• We do not use your data to build advertising profiles for use on third-party networks.

The 111 bat platform uses cookies and similar tracking technologies to operate core platform features, remember your preferences, and gather anonymised analytics. Below is a summary of the cookie categories used on the platform.

Managing Cookies: Most web browsers allow you to control cookie settings through the browser's preferences or settings menu. Disabling strictly necessary cookies will impair your ability to log in and use core platform features. Disabling analytics or functional cookies will not prevent you from accessing the platform but may reduce the quality of certain personalised features.

Local Storage: In addition to cookies, the 111 bat platform may use browser local storage to retain session-related preferences on your device. This data is stored locally and is not transmitted to our servers unless explicitly referenced as part of a platform feature.

111 bat retains personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required by applicable legal, regulatory, or compliance obligations. The following general retention periods apply:

• Active account data: Retained for the full duration of your account's active period and for a minimum of five (5) years following account closure, to satisfy anti-money laundering record-keeping requirements.
• KYC and identity documents: Retained for a minimum of five (5) years following the date of submission or account closure, whichever is later, in line with standard financial compliance obligations.
• Transaction records: Retained for a minimum of five (5) years following each transaction, in line with standard financial record-keeping practice.
• Support communications: Retained for a minimum of two (2) years following the resolution of the relevant support ticket or enquiry.
• Anonymised analytics data: May be retained indefinitely in aggregate, anonymised form for platform improvement purposes. Anonymised data cannot be used to identify any individual Member.

When personal data is no longer required for any of the above purposes, 111 bat will securely delete or anonymise it in accordance with our internal data disposal procedures. You may request early deletion of your data in certain circumstances — see Section 7 (Your Privacy Rights) for details.

111 bat implements a layered set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, alteration, or disclosure. Key security measures include:

• Transport encryption: All data transmitted between your device and the 111 bat platform is encrypted using 256-bit TLS/SSL, the same encryption standard used by major international financial institutions and banks.
• Data-at-rest encryption: Sensitive data stored on our servers, including KYC documents and financial records, is encrypted at rest.
• Password hashing: Member passwords are never stored in plain text. All passwords are hashed using industry-standard one-way cryptographic algorithms before storage.
• Access controls: Access to personal data within the 111 bat organisation is restricted on a strict need-to-know basis. Staff with access to Member data are subject to confidentiality obligations.
• Two-factor authentication: Members are strongly encouraged to enable two-factor authentication (2FA) on their accounts. 111 bat supports 2FA as an additional security layer on top of standard password login.
• Fraud and anomaly detection: Automated systems monitor platform activity for unusual patterns, including atypical login locations, unusual transaction volumes, and suspicious betting behaviour.
• Regular security reviews: 111 bat conducts periodic internal security reviews and works with qualified security professionals to identify and address vulnerabilities.

Despite these measures, no internet-based platform can guarantee absolute security. In the event of a data breach that affects your personal data in a material way, 111 bat will notify affected Members without undue delay and take all reasonable steps to contain and remediate the breach.

As a Member of the 111 bat platform, you hold a set of rights in relation to your personal data. 111 bat is committed to honouring these rights in a timely and transparent manner. To exercise any of the rights listed below, please contact our support team via live chat or by emailing [email protected].

Response Timeframes: 111 bat will acknowledge all privacy rights requests within 72 hours of receipt and will aim to fulfil the request within 30 calendar days. Where a request is complex or involves a large volume of data, we may extend this period by a further 30 days, in which case we will notify you of the extension and the reason for it.

Identity Verification for Rights Requests: To protect your data from unauthorised disclosure, 111 bat will verify your identity before processing any data subject rights request. This typically involves confirming details associated with your registered account via our live chat support channel.

Limitations: Certain rights are subject to limitations under applicable law. For example, the right to erasure does not apply where 111 bat is required to retain data to comply with a legal obligation, such as anti-money laundering record-keeping requirements. Where a limitation applies, we will explain the reason clearly in our response to your request.

8.1 Amendments to This Privacy Policy

111 bat reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data practices, applicable law, or platform features. When material changes are made, we will notify Members by posting a prominent notice on the platform and, where appropriate, by sending a notification to your registered email address.

The "Last updated" date at the top of this page reflects when the most recent revision came into effect. We encourage you to review this Privacy Policy periodically. Continued use of the 111 bat platform after the effective date of any revision constitutes your acceptance of the updated policy. If you do not agree with a revised policy, please contact our support team to close your account before the revision takes effect.

8.2 Contacting 111 bat on Privacy Matters

For any questions, concerns, or requests relating to this Privacy Policy or your personal data, please contact the 111 bat support team via:

• Live chat: Available 24/7 directly within the platform, on Bangladesh Standard Time (UTC+6).
• Email: [email protected] (plain text — not a clickable link)

We aim to respond to all privacy-related enquiries within 72 hours. For formal data subject rights requests, please clearly state the nature of your request and provide your registered account username so we can locate your records and verify your identity efficiently.

8.3 Relationship to Other Policies

This Privacy Policy should be read alongside the Terms & Conditions and the Responsible Gaming Policy, all of which together govern your relationship with the 111 bat platform. In the event of any inconsistency between this Privacy Policy and the Terms & Conditions on a matter of data protection, this Privacy Policy prevails.