p111 Privacy
Policy

For the purposes of this Privacy Policy, the following defined terms apply:

• "Personal Data" means any information relating to an identified or identifiable natural person, including but not limited to name, mobile telephone number, CNIC number, date of birth, financial account details, IP address, and gaming and transaction history.
• "Processing" means any operation performed on Personal Data, including collection, storage, organisation, retrieval, use, disclosure, transfer, alteration, and deletion.
• "Data Controller" refers to p111, the entity that determines the purposes and means of processing Personal Data collected through the p111 platform.
• "Data Processor" refers to any third party that processes Personal Data on behalf of p111 under a written data processing agreement, including payment service providers and KYC verification partners.
• "Consent" means freely given, specific, informed, and unambiguous indication of agreement to the processing of Personal Data for a stated purpose.
• "Player" or "You" refers to any natural person who has registered or is seeking to register an account on the p111 platform.

p111 is the Data Controller responsible for the Personal Data collected and processed in connection with your use of the p111 platform at p111.bio. p111 operates under an international gaming licence and is subject to data protection obligations imposed by that licensing authority.

As Data Controller, p111 is accountable for ensuring that Personal Data is collected and processed lawfully, fairly, and transparently; that data is collected for specified, explicit, and legitimate purposes; and that data is kept accurate, secure, and no longer than necessary for its stated purpose.

For all data protection enquiries, requests to exercise your data rights, or concerns regarding this Privacy Policy, please contact the p111 Data Protection contact via the support channels described in Section 16 of this Policy.

p111 collects the following categories of Personal Data about players on the p111 platform:

p111 does not collect or process Special Categories of Personal Data (including racial or ethnic origin, political opinions, religious beliefs, health data, or biometric data) unless specifically required for responsible gaming compliance or mandatory KYC verification under licensing obligations, and only with explicit consent or as permitted by applicable regulation.

p111 collects Personal Data through the following means:

• Direct Provision: When you complete the p111 account registration form, submit KYC documentation, initiate a deposit or withdrawal, contact the p111 support team, or respond to a promotion, you provide Personal Data directly to p111.
• Automated Technical Collection: When you access the p111 platform, our systems automatically collect technical data including your IP address, device identifiers, browser characteristics, and session data. This collection occurs via cookies and server-side logging as described in Section 8 of this Policy.
• Payment Provider Integration: When you make a deposit or withdrawal via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, or card payment, p111 receives transaction confirmation data and payment reference identifiers from the relevant payment service provider. p111 does not receive or store your full JazzCash or EasyPaisa PIN, or full card numbers.
• KYC Verification Partners: Where p111 uses a third-party identity verification service to assist with KYC processing, that partner may return verification outcomes and extracted identity data to p111 as part of the verification workflow.
• Fraud Detection Systems: p111's fraud prevention infrastructure monitors platform activity and generates risk signals based on behavioural patterns. Data generated by these systems is used internally for account security purposes.

p111 processes your Personal Data for the following specific and documented purposes:

• Account Registration and Management: To create and maintain your p111 account, verify your eligibility, manage your PKR wallet, and provide you with access to p111 gaming and betting services.
• Age and Identity Verification: To confirm that you are at least 21 years of age and that your identity matches the information provided at registration, in compliance with p111's licensing obligations.
• Payment Processing: To process deposits via JazzCash, EasyPaisa, HBL, UBL, and Meezan Bank, and to process withdrawal requests to your registered payment method. This necessarily involves sharing transaction data with the relevant payment service provider.
• Responsible Gaming Compliance: To enforce responsible gaming controls activated by you, including deposit limits, session limits, cooling-off periods, and self-exclusion. To monitor for behavioural patterns indicative of problem gambling and to intervene with appropriate support resources in accordance with p111's responsible gaming obligations.
• Anti-Money Laundering and Fraud Prevention: To detect, prevent, and investigate suspicious financial activity, bonus abuse, account fraud, identity fraud, and money laundering as required under p111's licensing conditions and applicable international AML standards.
• Customer Support: To respond to your queries, resolve complaints, process responsible gaming requests, and maintain records of support interactions for quality assurance and dispute resolution purposes.
• Platform Improvement: To analyse aggregated, anonymised usage data for the purpose of improving the p111 platform, game lobby, payment flows, and overall player experience. This analysis does not involve identifying individual players.
• Marketing Communications: To send promotional offers, bonus notifications, and platform updates to players who have given explicit consent to receive such communications. Where consent has been withdrawn, marketing processing ceases immediately.
• Legal and Regulatory Compliance: To comply with obligations imposed by p111's gaming licence, applicable anti-money laundering regulations, and any lawful order from a competent regulatory or law enforcement authority.

p111 processes your Personal Data on the following legal bases:

• Contractual Necessity: Processing required to provide the p111 gaming services you have contracted for, including account management, payment processing, and game access.
• Legal Obligation: Processing required to comply with p111's international gaming licence conditions, anti-money laundering obligations, age verification requirements, and any lawful regulatory or law enforcement directive.
• Legitimate Interests: Processing necessary for the legitimate interests of p111, specifically fraud prevention, platform security, responsible gaming monitoring, and abuse detection — where those interests are not overridden by your fundamental rights and interests.
• Consent: Processing for optional purposes where you have provided explicit consent, including receipt of marketing communications and use of optional analytics cookies. Consent may be withdrawn at any time without affecting the lawfulness of prior processing.

p111 may share your Personal Data with the following categories of third parties:

• Payment Service Providers: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, and card processing networks receive the minimum transaction data required to process your deposits and withdrawals. These providers are independently regulated and maintain their own privacy programmes.
• KYC and Identity Verification Partners: Third-party identity verification providers receive your identity documentation and personal details to conduct verification checks on behalf of p111. These partners are bound by strict data processing agreements and are prohibited from using your data for their own purposes.
• Gaming Content Providers: Where required by studio licensing arrangements, aggregated and anonymised gameplay data may be shared with game providers whose titles you play on the p111 platform for RTP auditing and fairness certification purposes.
• Regulatory and Law Enforcement Authorities: p111 is obligated to disclose Personal Data to its licensing authority, financial intelligence units, and law enforcement agencies where required by lawful order or as part of mandatory suspicious activity reporting obligations.
• Self-Exclusion Scheme Operators: Where a player activates self-exclusion at p111, certain data may be shared with multi-operator self-exclusion scheme administrators if p111 is a participant in such a scheme, for the purpose of enforcing the player's self-exclusion across affiliated platforms.

p111 uses cookies and similar tracking technologies to operate and improve the p111 platform. Cookies are small text files placed on your device when you visit the platform. The following categories of cookies are used:

• Strictly Necessary Cookies: Required for the platform to function. These include session authentication cookies that keep you logged into your p111 account, security cookies for CSRF protection, and cookies that remember your responsible gaming settings. These cookies cannot be disabled without impairing core platform functionality.
• Functional Cookies: Store your platform preferences, including game lobby filter settings, language and display preferences, and notification settings. These improve your experience but are not essential to platform operation.
• Analytics Cookies: Used to collect anonymised information about how players navigate and use the p111 platform, enabling p111 to identify performance issues, popular game categories, and areas for improvement. These cookies are activated only with your consent.
• Marketing Cookies: Where consent has been given, marketing cookies assist p111 in delivering relevant promotional content and tracking the effectiveness of marketing activities. You may withdraw consent for marketing cookies at any time through your account settings.

You may manage cookie preferences through your browser settings or through the p111 cookie preference centre accessible from the platform. Note that disabling strictly necessary cookies will impair your ability to use the p111 platform.

p111 implements a comprehensive and layered approach to Personal Data security, including the following technical and organisational measures:

• 256-bit SSL/TLS encryption on all data transmitted between your device and the p111 platform, including login credentials, financial transactions, and account updates.
• Encryption of sensitive Personal Data at rest within p111's database infrastructure, including identity documents, financial account references, and KYC records.
• Role-based access controls ensuring that p111 personnel can access player Personal Data only to the extent necessary for their specific operational role.
• Two-factor authentication requirements for all p111 internal systems that process player Personal Data.
• Regular independent penetration testing and security auditing of p111's platform infrastructure.
• Incident response procedures providing for rapid detection, containment, and notification in the event of a Personal Data breach.
• Data processing agreements with all third-party processors that include binding security and confidentiality obligations.

p111 retains Personal Data for the following periods, after which data is securely deleted or irreversibly anonymised:

• Account and Identity Data: Retained for the duration of your p111 account plus a minimum of five years following account closure, as required by p111's international gaming licence and applicable anti-money laundering regulations.
• Financial Transaction Records: Retained for a minimum of five years from the date of each transaction, in compliance with AML record-keeping obligations.
• Gaming History: Retained for a minimum of three years, and for the duration of any open dispute or investigation involving the relevant gaming activity.
• Support Interaction Records: Retained for three years from the date of the last interaction in the relevant support thread, for dispute resolution and quality assurance purposes.
• Responsible Gaming Records: Retained for the full duration of any self-exclusion or exclusion period, plus five years thereafter, to prevent re-registration during an active exclusion and to maintain required regulatory records.
• Marketing Consent Records: Retained for the period during which consent is active, plus three years following withdrawal of consent, to evidence the lawful basis for prior marketing processing.

Where retention beyond these periods is required by a specific legal obligation, court order, or regulatory directive, p111 will retain the relevant data for the mandated period and delete it promptly upon expiry of that obligation.

As a player whose Personal Data is processed by p111, you have the following rights regarding your personal information. These rights are exercisable by submitting a written request to the p111 support team via live chat or email:

p111 will respond to all data rights requests within 30 days of receipt. In complex cases, this period may be extended by a further 60 days with notification. p111 may require verification of your identity before processing a rights request to ensure that data is not disclosed to or actioned by an unauthorised party.

p111 implements multiple safeguards to prevent access by underage individuals, including mandatory date of birth declaration at registration, automated age-check screening, and KYC identity verification requiring documentary proof of age for withdrawals above specified thresholds. Any person aware that a person under 21 has registered a p111 account is requested to notify p111 immediately via the support team.

p111 may send you promotional communications — including details of bonuses, new game releases, PSL cricket betting promotions, and platform updates — via SMS to your registered Pakistani mobile number and, where provided, to your email address, but only where you have given explicit consent to receive such communications.

You may withdraw your consent to receive marketing communications from p111 at any time by:

• Updating your notification preferences in your p111 account settings dashboard.
• Replying STOP to any SMS marketing message received from p111.
• Contacting the p111 support team via live chat and requesting removal from all marketing lists.

Withdrawal of marketing consent does not affect the lawfulness of any marketing processing conducted prior to your withdrawal. p111 will process opt-out requests within 48 hours of receipt, after which no further marketing communications will be directed to your contact details. Note that withdrawal of marketing consent does not affect transactional and account communications, which p111 is required to send in connection with your account activity.

p111 operates infrastructure and engages service providers across multiple international jurisdictions. As a result, your Personal Data may be transferred to and processed in countries outside Pakistan. p111 takes the following steps to ensure that such international transfers are conducted with appropriate protections in place:

• p111 enters into data processing agreements with all third-party processors that include standard contractual clauses or equivalent contractual protections requiring the processor to maintain data protection standards consistent with those applied by p111.
• Transfers to jurisdictions with recognised adequacy determinations under applicable data protection frameworks are conducted without additional safeguard requirements.
• p111 maintains records of all international data transfer arrangements and makes these available to its licensing authority upon request.

By using the p111 platform, you acknowledge that your Personal Data may be transferred internationally in the circumstances described above, subject to the protections outlined in this section.

p111 reserves the right to update, revise, or replace this Privacy Policy at any time to reflect changes in law, regulatory requirements, platform features, or data processing practices. When we make material changes to this Policy, we will:

• Update the "Effective Date" and "Version" shown at the top of this document.
• Notify registered p111 players of material changes via SMS to their registered mobile number or via in-platform notification at least 7 days prior to the changes taking effect.
• Where a material change involves a new processing purpose that requires fresh consent, p111 will seek that consent separately before commencing the new processing activity.

Continued use of the p111 platform following the effective date of any updated Privacy Policy constitutes your acknowledgement of the revised terms. If you do not agree with any changes to this Policy, you may request closure of your p111 account and deletion of your Personal Data, subject to the retention obligations described in Section 10.

For all privacy-related enquiries, data rights requests, or concerns regarding this Privacy Policy and how p111 handles your Personal Data, please contact the p111 Data Protection team through the following channels:

• Live Chat: The fastest method for privacy enquiries. Available 24 hours a day, 7 days a week through the p111 platform. Select the "Account & Privacy" category when initiating the chat.
• Support Email: [email protected] — displayed as plain text only; this is not a clickable link. Mark your email "Data Protection Request" in the subject line for prioritised handling. Response within 12 hours for non-urgent enquiries.
• Formal Written Request: For formal data rights requests, submit a written request via live chat or email identifying the specific right you wish to exercise and the data to which the request relates. p111 will acknowledge receipt within 5 business days and provide a substantive response within 30 days.