Privacy Policy —
How e111 Handles Your Personal Data

1. Who We Are — Data Controller Information

For the purposes of this Privacy Policy, the data controller responsible for your personal information is e111, operating the online betting and live casino platform at e111.app ("e111", "we", "us", "our"). e111 operates under international online gaming licensing arrangements and is the entity responsible for determining how and why your personal data is processed when you use the e111 Platform.

This Privacy Policy applies to all data processing activities conducted by e111 in connection with the following services:

• Account registration, verification, and management on the e111 Platform.
• Processing of deposits, withdrawals, and PKR wallet transactions via JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and 1LINK.
• Cricket betting, sportsbook, and in-play wagering services.
• Live casino and RNG slot gaming products accessible through e111 Casino.
• Bonus, promotional, loyalty, and rewards programmes.
• Customer support, dispute resolution, and responsible gaming management.
• Compliance, fraud prevention, anti-money-laundering, and KYC verification processes.

2. Categories of Personal Data We Collect

e111 collects the minimum personal data necessary for the purposes described in this Privacy Policy. The categories of data we collect are as follows:

2.1 Registration & Identity Data

full legal name date of birth gender registered mobile number email address (where provided) username account password (hashed)

This data is collected at the point of account creation and is used to uniquely identify your account and verify that you meet the minimum age requirement of 21 years.

2.2 KYC & Identity Verification Data

government-issued photo ID (CNIC / passport / driving licence) proof of address documents selfie or biometric verification data source of funds documentation (where required)

KYC data is collected to comply with anti-money-laundering obligations, confirm your identity and age, and enable withdrawal processing. KYC documents are processed by e111's designated identity verification partners under strict data sharing agreements.

2.3 Financial & Transaction Data

deposit amounts and timestamps withdrawal requests and amounts payment method references (JazzCash number, bank account identifiers) PKR wallet balance history bet placement and settlement records bonus claim and wagering history

2.4 Technical & Device Data

IP address device type and model browser type and version operating system session timestamps connection type (4G / Wi-Fi) approximate geographic location (city level)

2.5 Usage & Behavioural Data

pages visited and navigation patterns games played and session durations bet types and frequencies feature usage patterns responsible gaming tool interactions

2.6 Communications Data

support chat transcripts email correspondence complaint and dispute records SMS verification records

3. How We Collect Your Personal Data

e111 collects personal data through the following channels and mechanisms:

• Directly from you: When you register an account on e111, submit KYC documents, make a deposit, request a withdrawal, contact customer support, or interact with any feature of the Platform that requires you to provide information.
• Automatically through Platform use: Technical data including IP addresses, device identifiers, session logs, and usage patterns are collected automatically when you access the Platform through standard web server logging and session management technologies.
• Through cookies and similar technologies: As described in Section 8, e111 uses cookies and similar tracking technologies to maintain session state, remember your preferences, and analyse Platform usage patterns.
• From payment processors: When you make a deposit or withdrawal via JazzCash, EasyPaisa, or bank transfer, e111 receives transaction confirmation data including the amount, timestamp, and a reference identifier associated with your payment account.
• From identity verification partners: When KYC verification is conducted by a third-party identity service provider on e111's behalf, the outcome and relevant verification data are returned to e111 and recorded against your Account.
• From fraud prevention and AML services: e111 works with risk assessment services that may provide supplementary data checks to validate account registration information and detect potentially fraudulent activity.

4. Legal Basis for Processing

e111 processes your personal data on one or more of the following legal bases, depending on the specific processing activity:

5. How We Use Your Personal Data

e111 uses your personal data for the following specific purposes. We do not use your data for purposes that are incompatible with those listed here without obtaining your prior consent or being required to do so by law.

• Account management: Creating, maintaining, verifying, and securing your e111 Account, including processing login requests, managing session security, and handling account settings changes.
• Service delivery: Processing deposits to your PKR wallet, settling bets, paying out casino winnings, executing withdrawal requests through JazzCash, EasyPaisa, and banking channels, and crediting bonus funds.
• Identity and age verification: Confirming that you are aged 21 or above, that your identity matches the details provided at registration, and that your payment methods are registered in your own name.
• Fraud and AML compliance: Monitoring transaction patterns to detect potentially fraudulent deposits or withdrawals, identifying suspicious betting patterns, complying with anti-money-laundering reporting obligations, and maintaining records required by our licensing authority.
• Platform improvement: Analysing aggregated and anonymised usage data to understand how Pakistani users interact with e111, identify technical performance issues, and prioritise new features most relevant to our user base.
• Customer support: Responding to queries, investigating complaints, processing dispute resolutions, and maintaining records of support interactions for quality assurance and compliance purposes.
• Responsible gaming: Monitoring gameplay patterns to identify potential indicators of problem gambling, managing self-exclusion requests, maintaining cooling-off periods, and ensuring deposit limit controls are enforced correctly.
• Marketing communications: Sending promotional offers, bonus notifications, and platform updates to users who have opted in to receive such communications. Marketing recipients in Karachi, Lahore, Islamabad, and other Pakistani cities will receive contextually relevant offers aligned to events such as the PSL season, Eid promotions, and cricket internationals.
• Security and abuse prevention: Detecting and preventing unauthorised account access, bot activity, multi-accounting, and other prohibited conduct as described in the e111 Terms & Conditions.

6. Data Sharing — Who We Share Your Data With

e111 may share your personal data with the following categories of third parties:

• Payment processors: JazzCash, EasyPaisa, HBL, UBL, Meezan Bank, Raast, and 1LINK receive transaction data necessary to process your deposits and withdrawals. Each payment provider operates under its own privacy policy and data protection obligations as a separately regulated financial entity.
• Identity verification providers: Third-party KYC and AML service providers process your identity documents on e111's behalf. These providers are contractually prohibited from using your data for any purpose other than verifying your identity for e111.
• Game studio providers: Live casino and slot game providers (including Evolution Gaming, Pragmatic Play, PG Soft, Habanero, and Ezugi) receive minimum session data necessary to operate the games you play, including your player session token and wagering activity within their products. Game providers do not receive your financial account details or identity documents.
• Fraud prevention and risk services: Specialised fraud detection and AML screening services may receive transaction data and account metadata for risk assessment purposes under strict data processing agreements.
• Regulatory and licensing authorities: e111's operating licence requires certain reporting to our licensing authority. This may include aggregate transaction data, responsible gaming metrics, and in specific circumstances, individual account data where required for regulatory compliance or investigation.
• Law enforcement and legal process: e111 will disclose personal data to law enforcement agencies, courts, or regulatory bodies when required to do so by applicable law, court order, or valid legal process. Where legally permitted, e111 will notify you of such a disclosure.
• Professional advisers: Legal, accounting, audit, and insurance advisers engaged by e111 may access personal data where necessary for the services they provide, subject to professional confidentiality obligations.

7. Payment Data & Financial Information

The security and handling of payment data requires specific treatment beyond the general data processing described elsewhere in this Policy. The following principles govern how e111 manages your financial information:

• e111 does not store full payment credentials for mobile wallets or bank accounts. Payment authentication is handled directly by your JazzCash or EasyPaisa mobile wallet application or your internet banking session, with only a transaction reference token returned to e111.
• Bank account identifiers used for withdrawal processing are stored in encrypted form and are accessible only to authorised e111 finance operations personnel for the specific purpose of processing your withdrawal request.
• Transaction records — including deposit timestamps, amounts, and references — are retained for the duration required by e111's licensing obligations and applicable financial record-keeping requirements. See Section 9 for retention periods.
• e111 maintains full compliance with its PKR wallet processing obligations. No currency conversion is applied to your balance, and no hidden charges are deducted from your stored funds.
• Where source of funds documentation is requested as part of an enhanced due diligence review, those documents are processed solely for AML compliance purposes and are not used for any commercial profiling.

8. Cookies & Tracking Technologies

e111 uses cookies and similar technologies to operate the Platform, maintain your session state, and analyse usage patterns. A cookie is a small text file stored on your device by your browser when you visit a website. e111 uses the following categories of cookies:

You may manage cookie preferences through your browser settings at any time. Blocking all cookies will prevent you from logging in to your e111 Account, as session authentication requires strictly necessary cookies to function.

9. Data Retention

e111 retains your personal data for the minimum period necessary for the purposes for which it was collected, subject to longer retention where required by law or our operating licence. The following retention periods apply:

After the applicable retention period expires, your data will be securely deleted or irreversibly anonymised. Where anonymisation is applied, the resulting aggregated statistical data may be retained indefinitely for platform improvement purposes as it no longer constitutes personal data.

10. Data Security Measures

e111 implements layered technical and organisational security measures to protect your personal data against unauthorised access, disclosure, alteration, or destruction. Our security framework includes:

• Encryption in transit: All data transmitted between your device and e111's servers is encrypted using TLS 1.3 with 256-bit AES encryption. This applies to all Platform pages including login, deposit, withdrawal, and game sessions.
• Encryption at rest: Sensitive data fields — including identity document references, payment identifiers, and KYC outcomes — are encrypted in e111's database using AES-256 encryption with separate key management.
• Password security: Account passwords are processed using bcrypt hashing with randomised per-user salts. e111 does not store retrievable passwords. Even in the event of a database compromise, plaintext passwords cannot be extracted.
• Access control: Internal access to personal data is restricted on a strict need-to-know basis. Employee access is logged, role-based, and subject to regular access reviews. No e111 employee has unrestricted access to all personal data categories simultaneously.
• Infrastructure security: e111's server infrastructure operates behind firewalls, intrusion detection systems, and DDoS protection layers. Regular penetration testing and vulnerability scanning are conducted by qualified third-party security specialists.
• Data breach response: e111 maintains a documented data breach response procedure. In the event of a breach affecting your personal data, e111 will assess the risk, take immediate containment action, and where required by applicable law, notify affected users and relevant authorities within the legally prescribed timeframe.

While e111 takes all reasonable technical precautions, no internet-based platform can guarantee absolute security. You are responsible for maintaining the security of your own device, browser, and Account credentials. Use of strong, unique passwords and enabling device-level security for your mobile device (particularly given the JazzCash and EasyPaisa login features on e111) is strongly encouraged.

11. Your Data Rights

You have the following rights in relation to the personal data e111 holds about you. To exercise any of these rights, contact e111 support as described in Section 16:

12. Children's Privacy & Age Restriction

If e111 discovers that personal data has been collected from a user who is under 21 years of age, we will:

1. Immediately suspend the Account and restrict access to all Platform features.
2. Notify relevant responsible gaming and licensing authorities where required.
3. Reverse deposits to the extent operationally possible.
4. Permanently close the Account and delete or anonymise the associated personal data, subject to any legal record-keeping obligations that may require retention for audit purposes.

If you believe a person under 21 has created or is using an e111 Account, please report this immediately to e111 support via the contact details in Section 16. e111 treats reports of underage access as a priority compliance matter.

13. Marketing Communications

e111 may send you marketing communications about promotions, bonuses, new games, seasonal campaigns (including PSL season offers, Eid promotions, and cricket event specials), and platform updates. The following rules govern our marketing activities:

• Opt-in basis: Marketing communications are sent only to users who have affirmatively opted in during account registration or subsequently through Account settings. We will not send unsolicited promotional messages.
• Channels used: e111 sends marketing via SMS to registered Pakistani mobile numbers and, where an email address is provided, by email. We do not make outbound marketing telephone calls.
• Content: Marketing messages will relate exclusively to e111's own products, promotions, and services. e111 does not use your contact details to promote third-party products.
• Withdrawal of consent: You may opt out of marketing communications at any time by adjusting your preferences in Account settings, replying STOP to any e111 marketing SMS, or contacting e111 support. Opt-out requests are processed within two (2) business days. Withdrawing marketing consent does not affect your ability to use the Platform or receive transactional communications about your Account.
• Responsible gaming in marketing: All e111 marketing communications include responsible gaming messaging and are not targeted at users who have active self-exclusion periods, deposit limits at maximum, or loss limits that have been triggered within the preceding 30 days.

14. Third-Party Links & Services

The e111 Platform may contain references to payment partners (JazzCash, EasyPaisa, HBL, UBL, Meezan Bank), game studios, or other third-party service names. e111's Privacy Policy applies exclusively to the data processing activities of e111 itself and does not extend to the privacy practices of any third party.

Where you interact directly with a third-party service — such as authenticating through your JazzCash application or completing a bank transfer through your HBL internet banking portal — you are subject to that provider's own privacy policy and terms of service. e111 is not responsible for the privacy practices or data security of these independently operated services.

e111 recommends reviewing the privacy policies of all payment services and financial institutions you use in connection with your e111 Account, particularly as those policies govern how your mobile wallet and banking credentials are stored and processed.

15. Changes to This Privacy Policy

e111 reviews this Privacy Policy periodically and will update it to reflect changes in our data processing activities, legal requirements, or regulatory guidance. The following process applies to material updates:

• Material changes — those that significantly affect how we collect or use your personal data — will be notified to registered Account holders via SMS to their registered Pakistani mobile number at least seven (7) days before the updated Policy takes effect.
• The updated Policy will be published at e111.app/privacy-policy with a revised effective date and version number. Continued use of the Platform after the effective date constitutes acceptance of the revised Policy.
• Where a change requires your fresh consent — for example, if we wish to use your data for a new purpose that was not covered by the original basis of collection — we will seek that consent explicitly before processing your data in the new way. You will not be disadvantaged for declining consent.
• Minor changes — including clarifications, corrections, and updates to contact information — will be reflected in the Policy without formal notification, but will be visible through the updated version number and review date at the top of this page.

16. Contact Us & Data Protection Enquiries

For all privacy-related queries, requests to exercise your data rights, complaints about data handling, or general data protection questions, please contact e111 through the following channels:

This Privacy Policy was last reviewed on 01 January 2026 and is Version 2.4. All previous versions of this Policy are available on request from our support team.