Privacy Policy – c111 Pakistan Online Gaming Platform

c111 operates the online gaming and sports betting platform accessible at c111.click. For the purposes of data protection, c111 is the data controller — meaning we are the organisation that determines why and how your personal data is processed.

Our platform is designed specifically for the Pakistani market. All services are provided in Pakistani Rupees (PKR), and our support team operates in a context familiar to Pakistani players. When we say "c111" in this Policy, we are referring to the platform and the legal entity responsible for operating it.

If you have any questions about how your data is handled, you can reach our team at support@c111.click or via live chat from within your c111 account. We aim to respond to all data-related queries within 5 working days.

c111 collects personal data in several ways: information you provide directly during registration and use, data generated by your activity on the platform, and limited technical data collected automatically when you visit c111.click. Here is a clear breakdown:

c111 does not collect biometric data, sensitive political or religious information, or any data category beyond what is necessary for platform operation and regulatory compliance.

Every piece of data c111 collects is used for a specific, legitimate purpose. We do not collect data speculatively or hold data that serves no function in operating the platform. Here is how your data is used:

• Account Creation & Management: Your name, mobile number, and email are used to create and maintain your c111 account, send account notifications, and verify your identity when you contact support.
• Processing Transactions: Your payment method details are used to process deposits and withdrawals in PKR. Transaction records are maintained for accounting and dispute resolution purposes.
• Platform Security & Fraud Prevention: Device identifiers, IP addresses, and login patterns are used by c111's fraud detection systems to identify suspicious activity, prevent multiple accounts, and protect all players from account compromise.
• Compliance & Verification: CNIC and identity data may be processed when c111 is required to conduct Know Your Customer (KYC) verification — particularly for higher withdrawal thresholds or when required by our payment processing obligations.
• Responsible Gaming: Your gameplay activity data — session lengths, deposit frequency, wagering volume — is monitored to identify patterns that may indicate problematic gaming behaviour. This data is used to trigger responsible gaming interventions where appropriate and to allow you to self-manage via our responsible gaming tools.
• Customer Support: Support communications are used to resolve your queries, improve our service processes, and maintain a record of interactions for dispute reference purposes.
• Promotional Communications: If you have opted in to marketing communications, your contact details are used to send promotional offers, bonus notifications, and platform updates from c111. You can withdraw marketing consent at any time from your account settings.
• Platform Improvement: Anonymised and aggregated usage data — where individual players cannot be identified — is used to understand how players use c111, optimise game performance, and improve the overall user experience.

c111 processes personal data on one or more of the following legal grounds depending on the specific type of processing involved:

• Contractual Necessity: Processing required to fulfil c111's obligations to you as a registered Player — including account management, payment processing, and support services. Without this processing, c111 cannot provide its services to you.
• Legitimate Interests: Processing carried out for c111's legitimate business interests where those interests are not overridden by your privacy rights — including fraud prevention, platform security, and anonymised analytics used to improve c111's services.
• Legal Obligation: Processing required to comply with applicable legal requirements — including anti-money laundering (AML) obligations, identity verification requirements linked to financial transaction processing, and retention of records for regulatory purposes.
• Consent: Processing for purposes where your explicit consent is required and has been given — primarily marketing communications. Consent-based processing can be withdrawn by you at any time without affecting any other use of the platform.

c111 does not sell your personal data to third parties under any circumstances. Your data is not traded, rented, or monetised. Where c111 shares data with external parties, it is done strictly on a need-to-know basis, under contractual data protection obligations, and only for the purposes listed below:

• Payment Processors: Your payment details are shared with the payment provider processing your transaction — such as Easypaisa, JazzCash, NayaPay, SadaPay, or your bank. These providers receive only the data necessary to process the specific transaction and operate under their own data protection obligations.
• Identity Verification Providers: Where c111 uses a third-party KYC verification service to confirm a Player's identity, the required documents and personal details are shared with that provider under a strict data processing agreement. These providers do not retain or use the data for any purpose beyond verification.
• Game & Platform Technology Providers: Certain technical functions of c111 are powered by third-party software providers. These providers may process gameplay or session data as part of delivering the service. They do not have access to your financial or identity data and operate under data processing agreements with c111.
• Fraud Prevention & Security Services: c111 uses third-party fraud detection tools that process device and behavioural data to identify suspicious activity. This processing helps protect all players on the platform.
• Legal & Regulatory Authorities: c111 will disclose personal data to law enforcement, regulatory bodies, or courts where legally required — including in connection with fraud investigations, anti-money laundering reporting, or court orders. c111 will comply with valid legal requests while protecting player rights to the extent permitted by law.

All third-party data processors used by c111 are contractually bound to process data only for the purposes c111 specifies, to maintain appropriate security, and to not sub-process data without c111's authorisation.

c111 uses cookies and similar lightweight tracking technologies on c111.click to make the platform function correctly, keep you logged in securely, and understand how the site is being used. Here is what is used and why:

• Essential Cookies: These are required for c111 to function. They maintain your login session, keep your account secure, remember your language preference, and manage platform-level security tokens. These cookies cannot be disabled without breaking core platform functionality.
• Functional Cookies: These remember your preferences within c111 — such as game settings, notification preferences, and responsible gaming limits you have set — so you do not have to re-enter them on every visit.
• Analytics Cookies: c111 uses anonymised usage analytics to understand which games are most popular, how players navigate the platform, and where technical issues are most common. This data is aggregated and cannot be traced back to individual players. Analytics data is used to improve c111, not to target advertising.

You can manage cookie preferences through your browser settings. Note that blocking essential cookies will prevent you from logging in to your c111 account. c111 does not use advertising cookies or cross-site tracking cookies that follow you to other websites.

Data security is not treated as a compliance checkbox at c111 — it is an operational priority. The following measures are in place to protect your personal data against unauthorised access, disclosure, alteration, or destruction:

• Encryption in Transit: All data transmitted between your device and c111.click is encrypted using TLS (Transport Layer Security). This means your login credentials, payment information, and account data cannot be intercepted during transmission.
• Encrypted Data Storage: Sensitive stored data — including passwords and payment identifiers — is encrypted at rest using industry-standard encryption algorithms. Passwords are never stored in plain text.
• Access Controls: Personal data is accessible only to c111 staff who have a legitimate operational need for that data. Access is controlled by role-based permissions and logged for audit purposes.
• Fraud Detection Systems: Automated systems monitor platform activity for unusual patterns that could indicate account compromise or fraudulent access. Suspicious activity triggers alerts and, where necessary, temporary account restrictions pending investigation.
• Two-Factor Authentication (2FA): c111 supports optional 2FA for Player accounts. Enabling 2FA adds an additional layer of protection beyond your password and is strongly recommended, particularly if you use the platform on a shared device.
• Regular Security Reviews: c111's technical infrastructure and data handling practices are reviewed periodically to identify and address vulnerabilities. Third-party security assessments are conducted at intervals.

Despite these measures, no online platform can guarantee absolute security. If you suspect your c111 account has been compromised, contact support immediately. We will act swiftly to investigate and secure the account.

c111 retains personal data only for as long as it is genuinely needed. The retention period depends on the type of data and the purpose for which it was collected:

• Active Account Data: Personal data associated with your c111 account is retained throughout the period your account remains active. This includes identity information, contact details, and account preferences.
• Transaction & Financial Records: Records of deposits, withdrawals, and gameplay are retained for a minimum of 5 years from the date of the transaction. This retention period reflects financial record-keeping obligations and the potential need for transaction records in dispute resolution.
• Identity Verification Documents: Where CNIC copies or other verification documents are collected, they are retained for the duration of the account relationship plus a regulatory retention period of up to 5 years following account closure.
• Support Communications: Customer support transcripts and email correspondence are retained for 2 years from the date of the conversation, to provide context for any follow-up queries and for quality review purposes.
• Anonymised Analytics Data: Aggregated, anonymised usage data — where no individual can be identified — may be retained indefinitely for platform improvement purposes. This data has no privacy impact on individual players.
• Closed Account Data: Following account closure, personal data is retained for the minimum period required by our financial and legal obligations — typically 5 years — after which it is securely deleted or anonymised.

As a c111 player, you have meaningful rights over your personal data. Here is what those rights mean in practice:

To exercise any of these rights, contact c111 at support@c111.click with the subject line "Data Rights Request". We will verify your identity before processing the request and will respond within 30 days. In complex cases, we may request an extension of up to an additional 60 days — we will notify you if this applies to your request.

c111 is an adults-only platform. No person under the age of 18 is permitted to register an account, deposit funds, or use any c111 service. This is not merely a terms requirement — it is a principle c111 actively enforces through age verification measures and ongoing account monitoring.

c111 does not knowingly collect personal data from individuals under 18 years of age. If we discover that a player under 18 has registered — whether through self-disclosure, third-party report, or our own verification processes — we will immediately close the account, permanently delete all data associated with it, and refund any deposited funds to the payment method used.

Parents and guardians are encouraged to use device-level parental controls to prevent minors from accessing online gaming platforms. If you have reason to believe a minor has created a c111 account, contact support immediately at support@c111.click. c111 will treat all such reports with urgency and strict confidentiality.

c111 may update this Privacy Policy from time to time to reflect changes in platform functionality, data processing practices, legal requirements, or payment infrastructure. When material changes are made — changes that meaningfully affect how your personal data is processed — c111 will notify registered Players via in-platform notification or email at least 7 days before the changes take effect.

Non-material changes — such as clarifications to existing language, structural reorganisation, or updates to contact details — may take effect immediately upon publication at c111.click/privacy-policy. The "Last updated" date at the top of this Policy will always reflect when the Policy was most recently revised.

Continuing to use c111 after the effective date of any Policy update constitutes your acknowledgement of the revised Policy. If you have questions about any change before it takes effect, contact our support team — we are happy to explain the change in plain terms before you decide whether to continue using the platform.