t111 Privacy Policy — How We Collect, Use, and Protect Your Personal Data

Section 1

Information We Collect

t111 collects personal information from players through three primary channels: information you provide directly, information generated automatically through your use of the Platform, and information obtained from trusted third-party service providers. The specific categories of data we collect are detailed below.

Information You Provide Directly

Information Collected Automatically

When you visit t111.club or access the Platform via a mobile browser, we automatically collect certain technical and behavioural data. This data is necessary for the Platform to function correctly, to detect fraud, and to maintain security:

• Device and technical data: IP address, device type (mobile/desktop), operating system, browser type and version, screen resolution, and unique device identifiers.
• Session and usage data: Pages visited, time spent on each page, game sessions initiated, bet amounts placed, game outcomes, click patterns, and navigation paths.
• Location data: General geographic location derived from your IP address (country and city level). t111 does not collect precise GPS-level location data.
• Log data: Server-side access logs recording request timestamps, HTTP status codes, referral URLs, and session identifiers.

Information from Third Parties

t111 may receive personal data about you from the following third-party sources, strictly for the purposes of KYC compliance, fraud prevention, and payment verification:

• Payment service providers (e.g., bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, BRAC Bank): transaction confirmation data, wallet verification status.
• Identity verification partners: result of document authenticity checks and watchlist screening results.
• Game content providers (e.g., Evolution Gaming, Pragmatic Play): game session records, including session start/end times and wager amounts, for reconciliation purposes.

Section 2

How We Use Your Data

t111 uses the personal data we collect for a defined set of operational, legal, and service-improvement purposes. We do not use your data for any purpose that is incompatible with the purpose for which it was originally collected without obtaining your prior consent.

Core Operational Purposes

• Account creation and management: To register your t111 account, verify your identity, maintain your account profile, and enable secure login from your registered devices.
• Platform delivery: To provide access to casino games, cricket betting, slots, and all other features available on t111.club, including personalising your in-platform experience based on game history and stated preferences.
• Payment processing: To process BDT deposits and withdrawals through your selected payment method (bKash, Nagad, Rocket, Upay, bank transfer, Visa, Mastercard), reconcile transactions, and maintain accurate wallet balances.
• Bonus and promotion administration: To calculate wagering requirements, apply promotional credits, verify bonus eligibility, and prevent multi-account bonus abuse.
• Customer support: To respond to your enquiries, process complaints, and maintain records of support interactions for quality assurance and dispute resolution.

Compliance and Security Purposes

• KYC and identity verification: To comply with anti-money laundering (AML) obligations, verify that players meet the 18+ age requirement, and screen against watchlists.
• Fraud and abuse prevention: To detect and prevent fraudulent account activity, collusion between players, unauthorised access, payment fraud, and exploitation of game vulnerabilities.
• Responsible gaming monitoring: To identify patterns of potentially harmful gambling behaviour and, where appropriate, proactively reach out to affected players with responsible gaming resources, or enforce account limits consistent with player-set restrictions.
• Legal compliance: To fulfil t111's obligations under applicable law, respond to lawful requests from competent Bangladesh authorities, and maintain records required by financial regulations.

Service Improvement Purposes

• Platform analytics: To analyse aggregated and anonymised usage patterns to improve game selection, page performance, and user experience on t111.club across Dhaka, Chittagong, Sylhet, and other Bangladesh regions with varying network conditions.
• Marketing communications: Where you have expressly opted in to receive marketing, we may send you promotional emails or SMS messages regarding new games, seasonal bonuses (e.g., Eid promotions, BPL campaigns), and platform updates. You may opt out at any time by contacting [email protected].

Section 3

Legal Basis for Processing

t111 processes your personal data only where a valid legal basis exists for doing so. The applicable legal basis depends on the specific processing activity and is summarised in the table below.

Where t111 relies on legitimate interests as the legal basis for processing, we have carried out a balancing assessment to confirm that our interests do not override your fundamental privacy rights and freedoms. You may request a copy of any legitimate interests assessment by contacting [email protected].

Section 4

Data Sharing & Disclosure

t111 does not sell, rent, or otherwise transfer your personal data to third parties for their own independent commercial purposes. We share data with third parties only where strictly necessary and only under one of the following conditions:

Service Providers and Data Processors

t111 engages a limited number of carefully vetted third-party service providers who process personal data on our behalf, strictly under t111's instructions and pursuant to written data processing agreements. These include:

• Payment processors: bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Visa, and Mastercard — for the purpose of processing BDT deposits and withdrawals.
• Identity verification providers: Third-party KYC partners used to verify National ID cards, passports, and conduct AML watchlist screening.
• Game content suppliers: Evolution Gaming, Pragmatic Play, Spribe, NetEnt, Microgaming, and Ezugi — who receive the minimum session data necessary to render and record game outcomes.
• Cloud hosting and infrastructure providers: Who host the t111.club platform and associated databases under strict contractual security obligations.
• Customer support tooling providers: Who operate the live chat and ticketing infrastructure used to manage player support enquiries.

Disclosure to Authorities

t111 may disclose personal data to competent Bangladesh governmental, judicial, or regulatory authorities where required to do so by law, court order, or binding regulatory directive. In all such cases, t111 will disclose only the minimum data necessary to comply with the specific legal requirement and will, where legally permissible, notify the affected player of the disclosure.

Business Transfers

In the event that t111 undergoes a merger, acquisition, or sale of all or substantially all of its assets, player personal data may form part of the transferred assets. In such circumstances, t111 will notify affected players in advance and ensure that the receiving entity is bound by privacy obligations no less protective than those set out in this Privacy Policy.

Section 5

Cookies & Tracking Technologies

t111.club uses cookies and similar tracking technologies to ensure the Platform functions correctly and securely, and to collect anonymised analytics data that helps us improve your experience. This section explains what types of cookies we use and the purpose each serves.

Managing Cookies

You may control or disable cookies through your browser settings. However, please note that disabling essential or authentication cookies will prevent you from logging into your t111 account and using core Platform features. Disabling analytics or preference cookies will not impair core functionality but may result in a less personalised experience. Instructions for managing cookies are available in your browser's help documentation.

Section 6

Data Retention

t111 retains personal data only for as long as is necessary to fulfil the purpose for which it was collected, unless a longer retention period is required or permitted by applicable law. The following retention schedule sets out our standard data-holding periods:

Upon expiry of the applicable retention period, personal data is securely deleted or irreversibly anonymised. Where anonymisation is not technically feasible, data is placed in a restricted archive accessible only to the t111 Compliance team for the purposes of responding to legal requests.

Dormant Accounts

Accounts with no login activity for 12 consecutive months are classified as dormant. Dormant account data is retained under the same retention schedule as active accounts. t111 will send a reminder notification to the registered email address before classifying an account as dormant, and again before any scheduled data deletion event occurs.

Section 7

Your Data Rights

As a player on the t111 Platform, you hold a comprehensive set of rights over your personal data. t111 is committed to honouring these rights promptly and without undue burden. The following rights are available to all t111 account holders:

• Right of Access: You have the right to request a copy of all personal data that t111 holds about you. t111 will provide this in a structured, machine-readable format within 30 days of a verified request.
• Right to Rectification: If any personal data held by t111 is inaccurate or incomplete, you have the right to request that it be corrected. You may update most profile information directly through your account settings; for KYC-related corrections, contact [email protected].
• Right to Erasure: You may request the deletion of your personal data where it is no longer necessary for the purpose for which it was collected, or where you withdraw consent and no other legal basis applies. Note that t111 may be required to retain certain data for legal compliance purposes even following an erasure request.
• Right to Restriction: You may request that t111 restricts the processing of your personal data in certain circumstances — for example, while the accuracy of the data is contested, or where you have objected to processing pending verification of t111's legitimate grounds.
• Right to Data Portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to have that data transmitted to another controller where technically feasible, where processing is based on consent or contract.
• Right to Object: You have the right to object to processing of your personal data where t111 relies on legitimate interests as the legal basis, including profiling based on legitimate interests. You also have an absolute right to object to processing for direct marketing purposes at any time.
• Right to Withdraw Consent: Where t111 processes your data based on your consent (e.g., marketing communications), you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal.

How to Exercise Your Rights

To exercise any of the rights listed above, submit a written request to [email protected] with the subject line "Data Rights Request", including your full registered name, your t111 account username, and a description of the right you wish to exercise. t111 will acknowledge your request within 5 business days and will provide a substantive response within 30 calendar days. For complex or multiple requests, this period may be extended by a further 30 days, in which case t111 will notify you of the extension and the reason for it.

Section 8

Data Security Measures

t111 implements a multi-layered technical and organisational security framework designed to protect your personal data against unauthorised access, accidental loss, destruction, or disclosure. The key elements of this framework are described below.

Technical Safeguards

• 256-bit SSL/TLS encryption: All data in transit between your device and t111.club is protected by HTTPS with TLS 1.2 or higher. Connections using older, insecure protocols are rejected at the server level.
• Encryption at rest: Sensitive personal data stored in t111 databases — including identity document images, financial account references, and KYC records — is encrypted at rest using AES-256.
• Access controls: Access to systems containing personal data is restricted on a strict need-to-know basis. All t111 staff with data access operate under individually authenticated accounts with role-based permissions. Privileged access is subject to multi-factor authentication.
• Intrusion detection and monitoring: t111's infrastructure is subject to continuous automated monitoring for anomalous access patterns, DDoS activity, and attempted intrusions. Security events trigger immediate alerts to the t111 security team.
• Regular security assessments: t111 conducts periodic vulnerability assessments and penetration testing of its Platform and data infrastructure to identify and remediate security weaknesses proactively.

Organisational Safeguards

• Staff training: All t111 staff who handle personal data receive mandatory data protection and information security training upon onboarding and at least annually thereafter.
• Data processing agreements: All third-party service providers who process personal data on t111's behalf are required to sign formal data processing agreements that impose security and confidentiality obligations consistent with this Privacy Policy.
• Incident response plan: t111 maintains a documented data breach incident response plan. In the event of a personal data breach that is likely to pose a risk to affected players, t111 will notify affected individuals without undue delay and will take immediate steps to contain and remediate the breach.

Your Role in Security

While t111 takes all reasonable steps to protect your data, the security of your account also depends on the precautions you take. t111 strongly recommends that you use a strong, unique password for your t111 account, enable OTP-based two-factor authentication, never share your login credentials with any third party, and log out of your account after each session, particularly when accessing t111.club from a shared or public device. If you suspect that your account has been compromised, contact t111 immediately at [email protected].

Changes to This Privacy Policy

t111 reserves the right to update this Privacy Policy at any time to reflect changes in applicable law, regulatory guidance, or t111's data processing practices. Material changes will be communicated to registered players via email to their registered address and via an in-platform notification. The effective date at the top of this document will be updated accordingly. Continued use of the t111 Platform following notification of a material change constitutes acceptance of the updated Privacy Policy. If you do not accept the revised terms, you should close your account before the changes take effect.