w111 Privacy Policy – How We Handle Your Personal Data

w111 collects personal data in several categories depending on how you interact with the platform. Below is a complete breakdown of the types of information we may hold about you.

Your data reaches us through several routes, all of which are described here so there are no surprises.

• Directly from you: When you complete the w111 registration form, submit KYC documents, make a deposit or withdrawal request, contact our support team, or participate in a promotion.
• Automatically through the platform: When you visit or use w111, our servers automatically record technical information including your IP address, device identifiers, and browsing activity within the platform. This happens through cookies, server logs, and similar technologies.
• From payment providers: When you initiate a transaction via Easypaisa, JazzCash, or another payment method, the payment provider shares transaction confirmation data with w111 to credit your account or process your withdrawal.
• From fraud prevention and identity verification services: w111 may use third-party services to verify the authenticity of your identity documents and cross-check information against fraud databases. These services share only the outcome of their checks (verified / not verified) rather than raw data.
• From the w111 referral programme: If a friend refers you to w111, your referral code and the referring player's identifier are passed to our system when you register. No personal data about the referring player is shared with you or vice versa beyond what is needed to credit the referral reward.

Every piece of data w111 collects has a specific reason behind it. We do not collect anything we do not have a genuine need for. The purposes are listed below.

• Account registration and management: We need your name, email, and mobile number to create and maintain your w111 account, send you account notifications, and allow you to log in securely.
• Age and identity verification (KYC): Pakistani law and responsible gaming best practices require us to confirm that you are at least 18 years old and that the person depositing and withdrawing is genuinely the account holder. This is why we collect CNIC details and identity documents.
• Payment processing: We need your payment account details to credit your deposits to your w111 wallet and to send your withdrawal funds to the right mobile wallet or bank account.
• Fraud prevention and anti-money-laundering: We monitor transaction patterns and account activity to detect and prevent fraud, unauthorised access, and money laundering. This is a legal obligation as well as a platform security necessity.
• Customer support: When you contact w111 support, we use your account data and communication history to resolve your query efficiently.
• Platform improvement: Aggregated, anonymised usage data helps us understand how players interact with w111, which features are most useful, and where we can improve the experience.
• Responsible gaming: We monitor gaming behaviour patterns to identify players who may be showing signs of problem gambling, so we can proactively offer responsible gaming tools.
• Marketing communications: With your consent, we may send you promotional emails or SMS messages about w111 bonuses, new games, and special offers. You can opt out of these at any time.

w111 processes your personal data on the following legal grounds:

• Contractual necessity: Most data processing at w111 is necessary to provide you with the services you signed up for — your account, your deposits, your bets, and your withdrawals. Without this data, we cannot deliver the service.
• Legal obligation: KYC/AML procedures, age verification, and financial record-keeping are legal obligations that w111 must comply with regardless of your preferences.
• Legitimate interests: Fraud prevention, platform security, and platform improvement are processed under w111's legitimate business interests, provided those interests are not overridden by your rights.
• Consent: Marketing communications and optional analytics are processed only with your explicit consent, which you can withdraw at any time without affecting your account.

w111 does not sell your personal data to any third party. However, certain data sharing is necessary to operate the platform. Here is exactly who may receive your data and why.

Data security is not a side note at w111 — it is a core part of how the platform was built. The following security measures are in place to protect your personal data.

• SSL Encryption in Transit: All data transmitted between your browser or app and w111's servers is encrypted using TLS/SSL protocols. The padlock symbol in your browser confirms this is active.
• Encrypted Storage: Sensitive data including your CNIC information and payment account details is stored in encrypted form in our databases. Even if the database were somehow accessed, this data would be unreadable without the encryption keys.
• Access Controls: Access to personal data within w111 is restricted on a need-to-know basis. Support agents, for example, can see the information they need to resolve your query but cannot see your full payment account numbers.
• Two-Factor Authentication (2FA): w111 offers two-factor authentication for player accounts. We strongly recommend enabling this in your account settings to add an additional layer of protection against unauthorised login.
• Regular Security Audits: w111 conducts periodic security reviews and penetration testing to identify and address any vulnerabilities before they can be exploited.
• Incident Response: In the unlikely event of a data breach that poses a risk to your personal data, w111 will notify affected players promptly and take immediate corrective action.

w111 uses cookies and similar tracking technologies to operate the platform, improve your experience, and ensure security. Here is what we use and why.

You can manage cookie preferences through your browser settings. Disabling non-essential cookies will not prevent you from using w111, though some convenience features may not work as smoothly.

w111 retains your personal data only for as long as necessary for the purposes it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply.

• Active account data: Retained for the full duration of your account being active on w111, and for a period of 5 years after account closure to meet financial record-keeping and AML obligations.
• KYC and identity verification documents: Retained for a minimum of 5 years from the date of your last transaction, as required under anti-money-laundering regulations.
• Transaction records: Retained for 7 years from the date of each transaction to comply with financial record-keeping requirements.
• Customer support communications: Retained for 3 years from the date of the last communication to allow us to reference the history of any ongoing matter.
• Marketing consent records: Retained for 3 years from the date consent was given or withdrawn, to evidence our compliance with consent obligations.
• Technical logs: Typically retained for 90 days, used primarily for security monitoring and incident investigation.

When data is no longer needed and no legal retention obligation applies, w111 will securely delete or anonymise it.

As a player on w111, you have meaningful rights over your own personal data. These rights are available to all players regardless of location.

w111 is strictly an 18+ platform. We do not knowingly collect personal data from anyone under the age of 18. If you are a parent or guardian and you believe that a minor has registered an account on w111 using your details or their own, please contact us immediately at support@w111.im. We will investigate and, if confirmed, close the account and delete the associated data without delay.

Age verification is a mandatory step in the w111 KYC process. Accounts that cannot verify they belong to an adult will be suspended pending verification and closed if verification cannot be completed satisfactorily.

Some of the third-party service providers used by w111 — including certain technology partners, cloud hosting providers, and fraud prevention services — may process or store data outside Pakistan. Where this occurs, w111 ensures that appropriate safeguards are in place to protect your data to a standard equivalent to what would be expected under best-practice data protection principles. These safeguards include contractual data protection clauses with all international data processors and a preference for processors that operate under recognised data protection frameworks.

Your core account data and PKR payment records are processed and primarily stored on servers that serve the Pakistani market. w111 does not transfer payment data internationally beyond what is strictly necessary to complete the transaction with the payment provider you have chosen.

w111 may update this Privacy Policy from time to time to reflect changes in our data practices, new features, or evolving legal requirements. When material changes are made, we will notify registered players by email and display a notice on the w111 platform before the changes take effect.

• The "Last Updated" date at the top of this page will always reflect when the most recent changes were made.
• We encourage you to review this page periodically. It is available at w111.im/privacy-policy at all times.
• Continued use of w111 after a policy update constitutes your acceptance of the revised policy. If you disagree with any changes, you may close your account by contacting support.

If you have any questions about this Privacy Policy, want to exercise your data rights, or have a complaint about how w111 has handled your personal data, our team is available to help.

We aim to acknowledge all privacy-related queries within 24 hours and provide a full response within 30 days. For formal complaints, please mark your message with "Privacy Complaint" so it is directed to the appropriate team member. If you are not satisfied with our response, you have the right to escalate your complaint to the relevant regulatory authority.