x111me Privacy Policy

1 Who We Are

x111me is Pakistan's premier online casino and sports betting platform, accessible at x111me.com. The platform is operated by its licensed entity under an internationally recognised gaming regulatory authority. In the context of this Privacy Policy, references to "x111me", "we", "us", and "our" refer to the platform operator in its capacity as the data controller responsible for your personal information.

As data controller, x111me determines the purposes and means by which your personal data is processed. We are accountable for ensuring that all personal data we hold is handled lawfully, fairly, and transparently in accordance with applicable data protection principles and the requirements of our gaming licence.

2 Data We Collect

x111me collects personal data across several categories, each serving a specific and necessary operational or regulatory purpose. We do not collect categories of data beyond those listed below without first obtaining your explicit consent.

3 How We Use Your Data

x111me processes your personal data for the following specific purposes. Each purpose is tied to a lawful basis for processing, which is set out in Section 4.

• Account Creation and Management: We use your Identity Data and Contact Data to create and maintain your x111me Account, authenticate your identity at login, and communicate essential account-related information to you.
• KYC and Age Verification: We process your CNIC details and supporting documents to verify that you are at least 21 years of age and to comply with our licensing authority's Know Your Customer requirements before activating withdrawal functionality on your Account.
• Payment Processing: We use your Financial Data to process PKR deposits via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, SadaPay, Raast, 1LINK, USDT TRC20, or Cash OTC, and to process withdrawal requests to your verified payment method.
• Anti-Money Laundering (AML) Compliance: We are required by our gaming licence to monitor transactions for indicators of money laundering and financial crime. We process Usage Data and Financial Data for this purpose and may report suspicious activity to the relevant regulatory authorities.
• Platform Security: We process Technical Data to detect and prevent fraud, unauthorised account access, bot activity, and other security threats to the platform and to other users.
• Game Fairness and Dispute Resolution: Usage Data — including bet histories, game logs, and session records — is retained to ensure game fairness, resolve player disputes, and respond to regulator inquiries.
• Responsible Gaming: x111me uses Usage Data to monitor for signs of problem gambling behaviour and to proactively reach out to users who may benefit from our responsible gaming tools, including deposit limits, session reminders, and self-exclusion.
• Customer Support: We process Communications Data to respond to your queries, resolve complaints, and improve the quality of our support service.
• Promotional Communications: Where you have opted in, we use your Contact Data and Marketing Preferences to send you details of x111me bonuses, promotions, and platform updates. You can opt out at any time via Account settings.
• Platform Improvement: Aggregated and anonymised Usage Data is analysed to improve platform performance, game selection, user experience design, and support processes.

4 Legal Basis for Processing

x111me processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

• Contractual Necessity: Processing is necessary to perform the contract between you and x111me — specifically, to operate your Account, process your transactions, and deliver the platform services you have registered to use.
• Legal Obligation: Processing is required for x111me to comply with its legal and regulatory obligations, including KYC verification, AML transaction monitoring, age verification (21+), and reporting obligations under our international gaming licence.
• Legitimate Interests: Processing is necessary for x111me's legitimate interests in operating a secure, fair, and commercially viable platform — including fraud prevention, platform security, dispute resolution, and internal analytics — where those interests are not overridden by your own rights and interests.
• Consent: For optional activities such as receiving promotional SMS or email communications, x111me relies on your explicit, freely given consent. You may withdraw this consent at any time via your Account settings without affecting the lawfulness of processing carried out prior to withdrawal.

5 Data Sharing & Disclosure

x111me does not sell your personal data. We share your data only in the specific circumstances described below, and only to the extent necessary for the stated purpose.

• Payment Processors: Your Financial Data is shared with the relevant payment service provider (e.g., JazzCash, EasyPaisa, HBL, USDT processing partners) solely for the purpose of completing your deposit or withdrawal transaction. Each provider is bound by its own privacy policy and applicable financial regulations.
• KYC Verification Providers: Your Identity Data, including CNIC details and photographs, is shared with our third-party KYC verification partner to conduct identity verification checks required under our gaming licence. This partner is contractually prohibited from using your data for any purpose other than completing the verification.
• Game Content Providers: Where you play games developed by third-party studios (e.g., live casino games, slots), your Usage Data related to those games may be shared with the relevant game provider as necessary for game operation, fairness certification, and technical support. Game providers do not receive your identity or financial data.
• Regulatory Authorities: x111me is required by its gaming licence to report certain information to its licensing regulator, including suspicious transaction reports, player complaint records, and periodic compliance submissions. We will also disclose data to law enforcement or government authorities where required to do so by applicable law or court order.
• Fraud Prevention Networks: Where x111me detects patterns of fraud, multi-accounting, or money laundering, relevant data may be shared with industry fraud prevention networks in which x111me participates, for the purpose of protecting all users.
• Professional Advisers: x111me may share data with its legal advisers, auditors, or insurers where necessary for the conduct of legal proceedings, financial audits, or insurance claims, subject to strict confidentiality obligations.
• Business Transfers: In the event of a merger, acquisition, or sale of substantially all of x111me's assets, your personal data may be transferred to the successor entity. You will be notified of any such transfer and your rights under this Policy will continue to apply.

6 Cookies & Tracking Technologies

x111me uses cookies and similar technologies on the platform to ensure it functions correctly, to maintain the security of your session, and to understand how users interact with the platform so we can improve it.

x111me does not use advertising or behavioural tracking cookies. Third-party social media pixels and retargeting scripts are not deployed on this platform.

You can manage or delete cookies through your browser settings at any time. Disabling strictly necessary cookies will prevent you from logging into your x111me Account.

7 Data Retention

x111me retains your personal data for the minimum period necessary to fulfil the purpose for which it was collected, or as required by our regulatory obligations. The following retention periods apply:

• Account and Identity Data: Retained for the duration of your Account and for a minimum of five (5) years following permanent Account closure, as required by our gaming licence's AML compliance obligations.
• Financial Transaction Data: Retained for a minimum of seven (7) years from the date of the relevant transaction, in compliance with anti-money laundering record-keeping requirements.
• KYC Documentation: Retained for the duration of your Account and for five (5) years following Account closure. Physical document copies are not retained beyond what is required for digital verification records.
• Technical and Usage Data: Retained for up to two (2) years from the date of collection, after which it is aggregated and anonymised. Anonymised data may be retained indefinitely for platform analytics purposes.
• Communications Data (support chat logs and emails): Retained for three (3) years from the date of the interaction, to support dispute resolution and quality assurance processes.
• Marketing Preference Records: Retained for the duration of your Account plus two (2) years, to maintain an accurate record of consent and opt-out history.

At the end of each applicable retention period, personal data is permanently deleted from x111me's live systems or irreversibly anonymised. Backup copies are purged on a rolling schedule aligned with our backup rotation policy.

8 Data Security

x111me implements a multi-layered security architecture to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our key security measures include:

• Encryption at Rest: All personal data stored on x111me servers is encrypted using AES-256 encryption. Database encryption keys are managed separately from the data they protect.
• Encryption in Transit: All data transmitted between your device and the x111me platform is protected using TLS 1.3. Connections over older, less secure protocols are refused.
• Access Controls: Access to personal data is restricted on a strict need-to-know basis. Staff with access to personal data are subject to background checks, confidentiality agreements, and regular security training.
• Two-Factor Authentication: x111me staff accessing internal systems containing personal data are required to use hardware-based two-factor authentication. We strongly encourage you to enable 2FA on your user Account as well.
• Penetration Testing: The x111me platform undergoes regular third-party penetration testing and security audits to identify and remediate vulnerabilities.
• Incident Response: x111me maintains a documented data breach incident response plan. In the event of a breach affecting your personal data, we will notify you and the relevant regulatory authority within the timeframe required by our licence obligations.

9 Your Data Rights

As an x111me user, you hold the following rights in respect of your personal data. These rights may be exercised by contacting our support team via 24/7 live chat or by emailing [email protected]. We will respond to all valid requests within 30 days.

10 Children & Minors

The x111me Platform is strictly intended for users aged 21 and above. x111me does not knowingly collect personal data from any individual under the age of 21. Age verification via CNIC is a mandatory step in the x111me registration and KYC process, specifically to prevent access by minors.

If x111me discovers that a user who has registered on the platform is under 21 years of age, the following actions will be taken immediately:

• The Account will be permanently suspended without notice
• All Bonus Funds associated with the Account will be forfeited
• Any remaining real-money PKR balance will be returned to the payment method used for deposit, after deduction of any withdrawals already processed
• All personal data associated with the Account will be deleted, except where retention is required for AML or regulatory compliance purposes

11 International Data Transfers

x111me is operated under an international gaming licence and, as such, your personal data may be transferred to, stored, or processed in jurisdictions outside Pakistan where our servers, licensing authority, KYC providers, or game content partners are located.

Where personal data is transferred internationally, x111me takes the following steps to ensure an adequate level of protection is maintained:

• We rely on standard contractual clauses or equivalent data transfer mechanisms approved by our licensing jurisdiction's data protection framework
• We conduct due diligence on all third-party data processors to verify they maintain security standards equivalent to or exceeding those applied by x111me
• Data transfers to payment processors in Pakistan (JazzCash, EasyPaisa, HBL, etc.) are governed by the respective institution's own regulatory obligations under Pakistani financial law

By registering on the x111me Platform and accepting this Privacy Policy, you acknowledge and consent to the international transfer of your personal data under the safeguards described above.

12 Policy Updates

x111me reserves the right to update this Privacy Policy at any time to reflect changes in our data processing practices, regulatory requirements, or platform features. When we make material changes to this Policy, we will:

• Update the "Effective Date" displayed at the top of this page
• Notify registered users by email or SMS at least 14 days before the revised Policy takes effect, where the change materially affects your rights
• Display a prominent notice on the x111me Platform for a period of at least 30 days following a material update

Your continued use of the x111me Platform following the effective date of any revision constitutes your acceptance of the updated Privacy Policy. If you do not agree to the revised Policy, you must stop using the Platform and may request Account closure in accordance with our Terms and Conditions.

We encourage you to review this Privacy Policy periodically. The current version is always available at x111me.com/privacy-policy.

13 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way x111me handles your personal data, please reach out through the following channels:

• 24/7 Live Chat: Available directly within the x111me Platform — the fastest channel for data rights requests and urgent privacy concerns
• Email: [email protected] — for formal data subject access requests, erasure requests, and written complaints regarding data handling
• Response Commitment: We acknowledge all privacy-related queries within 48 hours and provide a substantive response to formal requests within 30 days

When submitting a data rights request, please include your registered email address and the last four digits of your CNIC to allow us to locate your Account securely and efficiently.