111vd Privacy Policy

1 Introduction & Scope

111vd ("we", "us", "our") is committed to protecting the personal data of all individuals who interact with our platform, including registered players, prospective players who browse our website without registering, and individuals who contact us via support channels. This Privacy Policy applies to all personal data processed in connection with the 111vd website accessible at 111vd.app and all associated mobile and app-based interfaces.

This policy is intended to be read alongside our Terms & Conditions and our Responsible Gaming Policy. Together, these three documents form the complete framework governing your relationship with 111vd. In the event of any conflict between this Privacy Policy and the Terms & Conditions on a data-related matter, the Privacy Policy prevails.

We process personal data primarily to fulfil our contractual obligations to you as an account holder, to comply with legal and regulatory requirements including anti-money laundering (AML) and Know Your Customer (KYC) obligations, and to operate and improve the 111vd platform. We do not process personal data for any purpose that is incompatible with these stated aims without obtaining your separate, informed consent.

This policy is written in plain English to ensure that it is accessible and understandable to all our players in Bangladesh and internationally. Where legal or technical terminology is used, we have provided explanations in plain language alongside the technical term.

2 Data We Collect

111vd collects personal data through several channels: directly from you when you register or interact with the platform, automatically through your use of the website and platform, and from third-party sources such as payment providers and identity verification services. The categories of personal data we collect are described in the table below.

Registration & Account Data

When you create a 111vd account, you provide us with your full legal name, date of birth, residential address, email address, and mobile phone number. This information is mandatory for account creation. Providing false information at this stage is a breach of our Terms & Conditions and may result in account closure.

Identity Verification (KYC) Data

As part of our Know Your Customer process, we may collect copies of government-issued identity documents such as your National Identity Card (NID), passport, or driving licence. We may also collect proof of address documents, such as utility bills or bank statements, and where required, documentation confirming the source of funds deposited on the platform.

Financial & Transaction Data

We record details of all financial transactions conducted through your 111vd account, including deposit amounts, withdrawal amounts, payment method identifiers (such as the last four digits of a card or the registered mobile number of a bKash or Nagad account), transaction timestamps, and transaction reference numbers. We do not store full card numbers or mobile banking PINs.

Technical & Usage Data

We automatically collect certain technical information when you access the platform, including your IP address, browser type and version, device type and operating system, screen resolution, session timestamps, pages visited, and in-app navigation paths. This data is used primarily for security monitoring, fraud detection, and platform performance optimisation.

Summary of Data Categories

3 How We Use Your Data

111vd processes personal data only for specific, legitimate purposes. We do not use your data in ways that are inconsistent with the purposes described below. The primary purposes for which we process personal data are as follows:

• Account Management: Creating, maintaining, and administering your 111vd account, including processing deposits and withdrawals, managing bonus entitlements, and providing account statements.
• Identity & Age Verification: Verifying that you meet the minimum age requirement of 18 years and confirming your identity in compliance with our KYC obligations before processing withdrawal requests.
• Fraud Prevention & Security: Monitoring transactions and account activity for indicators of fraudulent behaviour, money laundering, collusion, or bonus abuse. This includes automated pattern analysis and, where necessary, manual review by our compliance team.
• Responsible Gaming: Analysing betting patterns and session data to identify indicators of problem gambling and to apply responsible gaming interventions, including deposit limits, session time restrictions, and self-exclusion where appropriate.
• Legal & Regulatory Compliance: Meeting our obligations under applicable anti-money laundering regulations, financial crime prevention requirements, and any applicable data protection legislation.
• Customer Support: Responding to your queries, complaints, and requests via live chat and email. Support communications may be recorded for quality assurance and training purposes.
• Platform Improvement: Using aggregated and anonymised technical and behavioural data to understand how players use the platform, identify technical issues, and develop new features and improvements.
• Marketing Communications: Where you have provided explicit consent, sending promotional emails or SMS messages about new games, bonuses, seasonal promotions (such as BPL season offers, Eid promotions, and Pohela Boishakh specials), and platform updates. You may withdraw this consent at any time by updating your communication preferences in your account settings.

4 Data Sharing & Third Parties

111vd does not sell, rent, or trade your personal data to third parties for their own marketing purposes under any circumstances. We share personal data with third parties only where it is strictly necessary to operate the platform, comply with legal obligations, or protect the security and integrity of the service. The categories of third parties with whom we share data are set out below.

Payment Processing Partners

To process deposits and withdrawals, we share the minimum necessary transaction data with our payment processing partners, including bKash, Nagad, Rocket, Upay, Visa, Mastercard, and our banking partners such as Dutch-Bangla Bank and BRAC Bank. These partners process data only as required to complete the relevant financial transaction and are bound by their own regulatory obligations and data protection commitments.

Identity Verification Services

For KYC document verification, we may use third-party identity verification service providers. These providers process your identity documents solely for the purpose of confirming your identity and age on behalf of 111vd. They do not retain your documents or use them for any other purpose.

Game Technology Providers

Casino game providers such as Evolution Gaming, Pragmatic Play, Ezugi, NetEnt, and Microgaming may receive session and game-outcome data necessary to facilitate the delivery of their games on our platform. These providers operate under strict contractual data processing agreements with 111vd and are not permitted to use this data for purposes beyond game delivery and technical support.

Legal & Regulatory Authorities

We may be required by law or by a competent regulatory authority to disclose personal data relating to your account. In such cases, 111vd will comply fully with any lawfully issued request and, where permitted by law, will notify you that such a disclosure has been made.

Data Sub-Processors

111vd uses certain technical sub-processors to operate the platform, including cloud hosting providers, database infrastructure providers, and customer support software vendors. All sub-processors are subject to written data processing agreements that require them to protect your data to a standard equivalent to or greater than the standard applied by 111vd itself.

5 Cookies & Tracking Technologies

111vd uses cookies and similar tracking technologies (including web beacons, pixel tags, and local storage objects) on our website and platform. Cookies are small data files placed on your device that allow us to recognise your browser and remember certain information about your session and preferences.

Types of Cookies We Use

Managing Cookies

You may configure your browser to refuse some or all cookies, or to alert you when cookies are being set. Please note that disabling strictly necessary cookies will prevent you from logging into your 111vd account or using the platform's core functionality. Instructions for managing cookies in common browsers are available through the Help function of your browser software.

111vd does not use third-party advertising or behavioural retargeting cookies. We do not share cookie data with advertising networks.

6 Data Security & Storage

111vd implements a comprehensive set of technical and organisational security measures designed to protect your personal data against unauthorised access, alteration, disclosure, or destruction. These measures include, but are not limited to, the following:

• Transport Encryption: All data transmitted between your device and the 111vd platform is encrypted using TLS 1.3 or higher. Our HTTPS implementation is configured to prevent protocol downgrade attacks.
• Data at Rest Encryption: Sensitive personal data stored in our databases is encrypted at rest using AES-256 encryption. This applies to identity documents, KYC records, and financial transaction data.
• Password Security: Account passwords are stored as salted cryptographic hashes. 111vd staff cannot retrieve your plain-text password under any circumstances. If you forget your password, it must be reset rather than recovered.
• Access Controls: Access to systems containing personal data is restricted to authorised staff members on a strict need-to-know basis. All internal access events are logged and subject to regular audit review.
• Two-Factor Authentication: Two-factor authentication is available and strongly recommended for all 111vd accounts. Players are encouraged to enable 2FA in their account security settings.
• Penetration Testing: 111vd commissions independent security assessments of our platform and data infrastructure on a periodic basis. Critical findings from these assessments are remediated as a matter of priority.
• Data Breach Response: In the event of a data breach that poses a risk to your rights and freedoms, 111vd will notify affected players within 72 hours of becoming aware of the breach, in accordance with internationally recognised incident response standards.

7 Data Retention Periods

111vd retains personal data only for as long as is necessary to fulfil the purposes for which it was collected, or as required by applicable legal and regulatory obligations. The table below summarises the standard retention periods applied to the main categories of personal data we hold.

When personal data is no longer required for any of the above purposes, it is securely deleted or anonymised in a way that prevents re-identification. Anonymised, aggregated data (such as platform-wide statistical reports) may be retained indefinitely as it no longer constitutes personal data.

8 Your Privacy Rights

As a data subject, you hold a number of rights in relation to the personal data that 111vd holds about you. These rights are summarised below. To exercise any of these rights, please contact our support team via 24/7 live chat on the platform or write to us at [email protected]. We will respond to all valid requests within 30 calendar days.

Right of Access

You have the right to request a copy of the personal data that 111vd holds about you. This is sometimes called a Subject Access Request (SAR). Upon receipt of a valid SAR, we will provide you with a structured summary of the data we hold, the purposes for which it is processed, the retention periods applied, and any third parties to whom it has been disclosed.

Right to Rectification

If any personal data we hold about you is inaccurate or incomplete, you have the right to request that it be corrected without undue delay. You may also update certain account details — such as your email address or residential address — directly through your account settings panel.

Right to Erasure

In certain circumstances, you have the right to request that 111vd delete the personal data we hold about you. This right applies where the data is no longer necessary for the purpose for which it was collected, where you have withdrawn consent (and no other lawful basis exists for processing), or where the data has been unlawfully processed. Please note that this right is subject to important limitations — we are legally required to retain certain data categories for defined periods as set out in Section 7, and erasure requests cannot override these obligations.

Right to Restriction of Processing

You may request that 111vd restrict the processing of your personal data in specific circumstances — for example, while the accuracy of data is contested, or while an objection to processing is being considered. During a restriction period, we will continue to store your data but will not actively process it except for specific permitted purposes.

Right to Data Portability

Where we process your personal data on the basis of your consent or on the basis of a contract, and the processing is carried out by automated means, you have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format. This right applies to data you have actively provided to us, such as registration information and transaction history.

Right to Object to Processing

You have the right to object to processing that is based on 111vd's legitimate interests. If you lodge such an objection, we will cease the relevant processing unless we can demonstrate compelling legitimate grounds that override your interests, rights, and freedoms, or unless the processing is necessary for the establishment, exercise, or defence of legal claims.

Right to Withdraw Marketing Consent

Where you have provided consent to receive marketing communications from 111vd, you may withdraw that consent at any time by updating your communication preferences in your account settings, or by contacting our support team. Withdrawal of marketing consent does not affect the lawfulness of any communications sent prior to withdrawal, and does not affect the processing of your data for non-marketing purposes.

9 Children's Privacy

111vd employs active age verification measures at account registration to prevent underage individuals from accessing the platform. These measures include mandatory date-of-birth submission at registration and KYC document verification prior to first withdrawal or upon reasonable suspicion of underage access.

If 111vd becomes aware that personal data has been collected from an individual under the age of 18, that data will be securely deleted as soon as practicable, the account will be permanently closed, and any funds deposited will be returned to the payment source in accordance with our underage account closure procedure, as described in our Terms & Conditions.

If you are a parent or guardian and have reason to believe that a minor in your care has registered an account on the 111vd platform, please contact our support team immediately via live chat. We treat reports of underage account access as a matter of the highest priority and will investigate and respond within 24 hours.

For guidance on preventing underage access to gambling platforms, including free parental control software options and support resources available in Bangladesh, please visit our Responsible Gaming page.

10 Changes to This Policy

111vd reserves the right to update or amend this Privacy Policy at any time. When material changes are made — for example, changes to the categories of data we collect, the purposes for which we process data, or the third parties with whom we share data — we will notify registered account holders via email to the address on file at least 14 days before the changes take effect.

Non-material changes, such as corrections to typographical errors, clarifications of existing practices, or updates to contact details, may be made without individual notification. The current version of this policy is always available on this page, along with the effective date and version number shown in the header of this document.

Your continued use of the 111vd platform after the effective date of any revised Privacy Policy constitutes your acknowledgement of the updated policy. If you do not agree with any changes to this policy, you may request account closure as described in our Terms & Conditions.

11 Contact & Data Protection Officer

If you have any questions, concerns, or requests relating to this Privacy Policy or to the way 111vd processes your personal data, please contact us through any of the following channels:

• Live Chat: Available 24/7 directly on the 111vd platform. This is the fastest channel — average response time under 90 seconds.
• Email: [email protected] — for written privacy requests, Subject Access Requests, and formal data protection complaints. Please include "Privacy" in the subject line of your message.

For formal privacy requests including Subject Access Requests, erasure requests, and data portability requests, please send a written request to our support email above. To protect the security of your account, we will verify your identity before processing any request relating to your personal data. Responses to formal privacy requests are provided within 30 calendar days of receipt of a verified request.