k1111 Privacy Policy — Your Data, Your Rights

1 Introduction

k1111 ("we", "us", "our", or "the Platform") is Bangladesh's premier online casino and sports betting platform, accessible at k1111.im. We are fully committed to protecting the privacy and personal data of every player who registers, deposits, plays, and withdraws on our platform.

This Privacy Policy sets out in formal, clear terms the basis on which any personal data we collect from you — or that you provide to us — will be processed by k1111. It covers the categories of data collected, the purposes for which that data is used, the conditions under which it may be shared with third parties, and the rights you hold as an individual data subject.

This Policy applies to all players and visitors who access k1111.im, regardless of the device or browser used to access the platform. It applies equally to players located in Dhaka, Chittagong, Sylhet, Khulna, Rajshahi, Barisal, Rangpur, Mymensingh, Cox's Bazar, and all other regions of Bangladesh.

This Privacy Policy should be read alongside the k1111 Terms & Conditions and Responsible Gaming Policy, which together form the complete regulatory framework governing your use of the k1111 platform. In the event of any conflict between this Privacy Policy and the Terms & Conditions on matters relating to data, this Privacy Policy shall prevail.

2 Data Controller

For the purposes of applicable data protection law, k1111 is the data controller in respect of personal data collected through the k1111 platform. As data controller, k1111 determines the purposes and means by which your personal data is processed.

All questions, data subject access requests, correction requests, deletion requests, and complaints relating to the processing of your personal data should be directed to k1111's data support team using the contact details set out in Section 14 of this Policy.

3 Categories of Personal Data We Collect

k1111 collects personal data that falls into the following defined categories. We collect only the minimum data required to provide you with a secure, compliant, and functional gaming experience.

3.1 Identity Data

This includes your full legal name, date of birth, gender, and the details contained in any government-issued identity document you provide during KYC verification (such as a National Identity Card, passport, or driving licence). Identity data is required to confirm your eligibility to use the k1111 platform — specifically to verify that you are a natural person aged 21 years or above.

3.2 Contact Data

This includes your registered email address, mobile phone number, and residential address (including city, postal code, and country). Contact data is used to communicate with you about your account, process transactions, send verification codes, and deliver important account notifications.

3.3 Financial Data

This includes the mobile wallet identifiers associated with your bKash, Nagad, Rocket, or Upay accounts, as well as any bank account details provided for bank transfer withdrawals. k1111 does not store full card numbers, PINs, or mobile banking passwords. Financial data is used solely for the purpose of processing deposits and withdrawals in BDT.

3.4 Account and Gaming Data

This includes your account username, login history, game session records, betting history (sports and casino), deposit and withdrawal transaction records, bonus usage history, and any responsible gaming tools you have activated on your account. This data is retained to provide you with account history, resolve disputes, and meet our regulatory obligations.

3.5 Technical Data

This includes your IP address, device type and model, operating system, browser type and version, screen resolution, and time zone setting. Technical data is collected automatically when you access k1111.im and is used to maintain platform security, detect fraudulent access, and ensure the platform functions correctly on your device.

3.6 Usage and Behavioural Data

This includes data about how you navigate and interact with k1111.im, including pages visited, features used, session duration, click patterns, and game preferences. This data is collected via cookies and similar tracking technologies, as described in Section 8 of this Policy, and is used to improve the platform experience and, where you have provided consent, to personalise promotional content.

3.7 Communications Data

This includes the content of any messages you send to k1111's customer support team, including live chat transcripts, email correspondence, and any attachments or documents you submit in connection with a support query or dispute. Communications data is retained for quality assurance, staff training, and to maintain an accurate record of dispute resolution outcomes.

4 How We Collect Your Data

k1111 collects personal data through the following mechanisms:

• Direct Submission: Data you actively provide when completing the account registration form, uploading KYC documents, entering payment details, submitting a support request, or filling in any other form on k1111.im.
• Automated Technical Collection: Data collected automatically by k1111's servers when you access k1111.im, including IP address, device identifiers, browser information, and session activity logs.
• Cookies and Tracking Technologies: Behavioural and usage data collected via cookies, web beacons, pixel tags, and similar technologies embedded in k1111.im. Full details of k1111's cookie practices are set out in Section 8.
• Third-Party Identity Verification Services: During KYC verification, k1111 may use third-party identity verification providers to cross-reference the documents you submit. These providers return a verification result to k1111 and do not retain your documents independently of k1111's instructions.
• Payment Service Providers: k1111 receives limited transactional confirmation data from bKash, Nagad, Rocket, Upay, and bank transfer services when you initiate a deposit or withdrawal. This data confirms transaction status and reference numbers; k1111 does not receive your full mobile banking credentials.
• Game Providers: k1111's third-party game providers (including Evolution Gaming, Pragmatic Play, NetEnt, Spribe, Ezugi, and others) transmit game session result data to k1111's platform in real time. This data is integrated into your account transaction history and is used for dispute resolution and regulatory record-keeping.

5 Legal Basis for Processing

k1111 processes your personal data on one or more of the following legal bases, depending on the nature and purpose of the processing activity:

• Performance of a Contract: The majority of data processing by k1111 is necessary for the performance of the contract between you and k1111 — namely, the Terms & Conditions you accepted upon registration. This includes processing your account details, gaming data, and payment information to provide you with the services you have requested.
• Legal Obligation: Certain processing activities are required to enable k1111 to comply with applicable legal and regulatory obligations, including identity verification (KYC), anti-money-laundering (AML) checks, and the retention of transaction records for a prescribed minimum period.
• Legitimate Interests: k1111 processes some data on the basis of its legitimate interests as an online gaming platform, where those interests are not overridden by your fundamental rights and freedoms. This includes fraud prevention, security monitoring, platform improvement, and responsible gaming risk assessments.
• Consent: Where k1111 relies on your consent as the legal basis for processing — particularly in relation to direct marketing communications and non-essential cookies — such consent is obtained explicitly and separately from general terms acceptance. You may withdraw consent at any time without affecting the lawfulness of prior processing.

6 How We Use Your Personal Data

k1111 uses the personal data collected from you for the following specific purposes:

• To create and manage your k1111 player account, including verifying your identity and age in accordance with our 21+ player eligibility policy.
• To process deposits and withdrawals in BDT via your chosen payment method (bKash, Nagad, Rocket, Upay, or bank transfer), and to maintain accurate transaction records.
• To authenticate your identity and detect unauthorised or fraudulent access to your account, including via two-factor authentication and device fingerprinting.
• To deliver platform notifications, account status updates, transaction confirmations, and security alerts to your registered email address or mobile number.
• To conduct ongoing AML screening and to report any suspicious activity to relevant authorities as required by applicable law.
• To administer responsible gaming tools activated on your account, including deposit limits, session reminders, loss limits, and self-exclusion periods.
• To investigate and resolve disputes relating to game outcomes, bonus eligibility, or payment transactions.
• To analyse aggregated, anonymised usage data to improve the k1111 platform's performance, stability, and user experience.
• Where you have provided explicit consent, to deliver personalised promotional offers and marketing communications relating to k1111 products and services.
• To comply with any lawful request from a court, regulatory authority, or law enforcement agency in Bangladesh or any other relevant jurisdiction.

7 Sharing Your Personal Data

k1111 does not sell, rent, or trade your personal data to any third party for commercial gain. Personal data is shared with third parties only in the following defined circumstances, and only to the minimum extent necessary for the stated purpose:

7.1 Payment Service Providers

To process your deposits and withdrawals, k1111 shares the minimum necessary financial and identity data with your selected payment provider (bKash, Nagad, Rocket, Upay, or the relevant bank). These providers process your payment data under their own privacy policies and are independent data controllers in respect of data held on their own systems.

7.2 Identity Verification Providers

To complete KYC verification, k1111 may share your submitted identity documents with a third-party identity verification service. These providers are engaged as data processors acting on k1111's instructions and are contractually prohibited from using your data for any purpose beyond the specific verification task.

7.3 Game Providers

k1111 shares limited player session identifiers with third-party game providers (such as Evolution Gaming, Pragmatic Play, NetEnt, Spribe, and Ezugi) to enable real-time game delivery and result recording. Game providers receive only the session data necessary to operate the specific game and do not receive your full identity or payment details.

7.4 Regulatory and Law Enforcement Authorities

k1111 may be required by law, court order, or regulatory direction to disclose your personal data to governmental or law enforcement bodies. k1111 will comply with all lawful disclosure obligations and will, where legally permissible, notify you of any such disclosure request.

7.5 Fraud Prevention and Security Services

k1111 may share limited technical data (such as IP addresses and device identifiers) with specialist fraud prevention and cybersecurity providers to protect the platform and its players from fraudulent activity, account takeover attacks, and other security threats.

7.6 Business Transfers

In the event of a merger, acquisition, restructuring, or sale of all or part of k1111's business assets, your personal data may be transferred to the acquiring entity as part of that transaction. k1111 will notify affected players of any such transfer and the privacy practices of the successor entity prior to the transfer taking effect.

8 Cookies & Tracking Technologies

k1111.im uses cookies and similar tracking technologies to maintain platform functionality, enhance security, and — where you have provided consent — to analyse usage patterns and personalise your experience. The following categories of cookies are used on k1111.im:

8.1 Strictly Necessary Cookies

These cookies are essential for the operation of k1111.im and cannot be disabled. They include session authentication cookies that keep you logged in during an active session, security tokens that protect against cross-site request forgery attacks, and load-balancing cookies that distribute platform traffic. No consent is required for strictly necessary cookies as they are required for the basic functioning of the service.

8.2 Functional Cookies

Functional cookies enable k1111.im to remember your preferences, such as your selected language setting, preferred game categories, and responsible gaming display options. These cookies improve your experience by retaining your customisations between sessions. Functional cookies are activated with your implicit consent upon use of the platform.

8.3 Analytics Cookies

Analytics cookies collect aggregated, anonymised data about how visitors use k1111.im, including which pages are visited most frequently, how long sessions last, and where users exit the platform. This data is used by k1111's internal development team to improve platform performance and user experience. Analytics cookies are only activated where you have provided explicit consent.

8.4 Marketing and Personalisation Cookies

Where you have provided explicit consent, k1111 may use cookies to record your game preferences and betting interests in order to display relevant promotional offers and personalised content during your sessions. These cookies are strictly opt-in and will not be activated without your affirmative agreement. You may withdraw consent for marketing cookies at any time by contacting [email protected].

9 Data Retention

k1111 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 and regulatory obligations. The following retention principles apply:

• Active Accounts: Personal data associated with an active k1111 account is retained for the full duration of the account's active status, plus a minimum of five years following account closure. This extended retention period is required to satisfy anti-money-laundering obligations, regulatory audit requirements, and potential legal proceedings.
• KYC Documents: Identity verification documents submitted during KYC are retained for a minimum of five years from the date of submission, or five years from the date of account closure, whichever is later.
• Transaction Records: Full records of all deposits, withdrawals, and game wagers are retained for a minimum of five years from the date of each transaction. These records are maintained in a secure, access-controlled database and are accessible only to authorised k1111 compliance personnel.
• Support Correspondence: Customer support communications, including email threads and live chat transcripts, are retained for three years from the date of the most recent interaction in each case.
• Technical and Log Data: Server logs and technical access records (including IP logs) are retained on a rolling 12-month basis and are then permanently deleted, unless a specific log entry has been flagged as relevant to an active security investigation or legal proceeding.
• Marketing Data: Where you have consented to marketing communications, the personal data used to deliver those communications is retained until you withdraw your consent. Upon withdrawal, marketing data is deleted within 30 days, subject to any legal retention obligations.

Upon the expiry of the applicable retention period, k1111 will securely delete or anonymise your personal data in accordance with our internal data destruction procedures. Anonymised data — from which individual identity cannot reasonably be reconstructed — may be retained indefinitely for aggregate statistical analysis.

10 Your Data Subject Rights

As an individual whose personal data is processed by k1111, you hold the following data subject rights. k1111 will respond to all valid rights requests within five Business Days of receipt. Requests may be submitted to [email protected] with the subject line "Data Rights Request — [Your Account Username]".

• Right of Access: You have the right to request a copy of all personal data that k1111 holds about you, together with information about how that data is being used, on what legal basis, and with whom it has been shared. k1111 will provide this information in a structured, commonly used electronic format within five Business Days.
• Right to Rectification: If any personal data held by k1111 about you is inaccurate or incomplete, you have the right to request that it be corrected or updated. Corrections to account-critical data (such as your legal name or date of birth) may require supporting documentary evidence before the change is applied.
• Right to Erasure ("Right to Be Forgotten"): You may request that k1111 delete your personal data. k1111 will comply with erasure requests to the fullest extent permitted by law. Please note that k1111 is legally required to retain certain categories of data — including KYC records and transaction histories — for a minimum period regardless of an erasure request.
• Right to Restriction: You have the right to request that k1111 restrict the processing of your personal data in certain circumstances, for example where you contest the accuracy of the data or where you have objected to processing and a determination is pending.
• Right to Data Portability: Where data is processed on the basis of your consent or the performance of a contract, and the processing is carried out by automated means, you have the right to receive your personal data in a structured, machine-readable format and to request its transfer to another service provider where technically feasible.
• Right to Object: You have the right to object to the processing of your personal data where that processing is based on k1111's legitimate interests. k1111 will cease such processing unless it can demonstrate compelling legitimate grounds that override your interests and rights.
• Right to Withdraw Consent: Where processing is based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

11 Data Security

k1111 implements a comprehensive set of technical and organisational security measures to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. These measures are reviewed and updated on a regular basis to reflect the current threat landscape and best practices in information security.

11.1 Encryption

All data transmitted between your device and k1111's servers is protected using 256-bit SSL (Secure Sockets Layer) encryption. Sensitive data stored on k1111's servers — including identity documents, financial data, and account credentials — is encrypted at rest using AES-256 encryption. Passwords are stored using a one-way cryptographic hash function and are never stored in plaintext.

11.2 Access Controls

Access to personal data within k1111's internal systems is restricted on a strict need-to-know basis. Only authorised personnel with a defined operational requirement are granted access to identifiable player data. All internal access is logged and subject to periodic audit.

11.3 Two-Factor Authentication

k1111 offers two-factor authentication (2FA) for player accounts and requires 2FA for all internal staff accessing k1111's administrative systems. Players are strongly encouraged to enable 2FA on their accounts to provide an additional layer of protection against unauthorised account access.

11.4 Security Incident Response

In the event of a data security incident that poses a risk to the rights and freedoms of affected players, k1111 will notify the affected individuals within 72 hours of becoming aware of the incident, where technically feasible. Notifications will describe the nature of the incident, the categories of data affected, the likely consequences, and the steps k1111 has taken or proposes to take to mitigate the impact.

Despite k1111's best efforts, no data transmission over the internet or data storage system can be guaranteed to be 100% secure. k1111 cannot warrant the absolute security of any data you transmit to the platform. Players are encouraged to use strong, unique passwords and to enable 2FA to reduce the risk of unauthorised account access from their side.

12 Children's Privacy

The k1111 platform is strictly intended for adults aged 21 years and above. k1111 does not knowingly collect, process, or retain personal data from any individual under the age of 21. The 21+ age requirement is enforced through our KYC identity verification process, which requires all players to submit a government-issued identity document confirming their date of birth before any withdrawal is processed.

If k1111 discovers or reasonably suspects that personal data has been submitted by or on behalf of an individual under the age of 21, the associated account will be immediately suspended, all pending transactions will be reversed, and the data will be permanently deleted as soon as reasonably practicable. Any real-money deposits made by an underage account will be returned to the payment source.

If you have reason to believe that a person under the age of 21 has registered or is using a k1111 account, please notify us immediately at [email protected] with the subject line "Underage Account Report". k1111 takes all such reports seriously and will investigate promptly.

13 Changes to This Privacy Policy

k1111 reserves the right to update or amend this Privacy Policy at any time to reflect changes in our data processing practices, applicable law, or platform functionality. When material changes are made to this Policy, k1111 will provide affected players with at least seven (7) days' advance notice via email to the registered account address and/or by displaying a prominent notice on k1111.im.

Minor amendments — including corrections of typographical errors, clarifications that do not affect the substance of the Policy, or updates necessitated by minor operational changes — may take effect immediately without advance notice. The "Last Updated" date at the top of this document and in the table of contents reflects the date of the most recent amendment.

Your continued use of the k1111 platform following the effective date of any amendment to this Privacy Policy constitutes your acknowledgement of and agreement to the updated terms. If you do not accept the amended Privacy Policy, you must cease using the k1111 platform and may request account closure in accordance with Section 12 of the Terms & Conditions. A full archive of prior versions of this Privacy Policy is available upon request.

14 Contact Us

If you have any questions, concerns, or requests relating to this Privacy Policy or the way in which k1111 processes your personal data, please contact our dedicated support team using the details below. All privacy-related requests are treated as a priority and handled in strict confidence.

• Email: [email protected]
• Subject Line Format: "Privacy Request — [Your Account Username]"
• Support Hours: 24/7, including all Bangladesh public holidays
• Acknowledgement Time: Within two Business Days of receipt
• Full Response Time: Within five Business Days for standard requests

For data subject rights requests — including access requests, rectification requests, erasure requests, and objections to processing — please include "Data Rights Request" in the subject line of your email, together with your account username and a brief description of your request. k1111 will verify your identity before processing any rights request, as described in Section 10 of this Policy.

k1111 is committed to resolving all privacy concerns directly and promptly. If you feel that your concern has not been addressed satisfactorily, you retain the right to escalate your complaint to the relevant data protection authority or seek independent legal advice.