Your Data, Your Rights

x 111 Privacy Policy — How We Handle Your Personal Data

At x 111 we believe Pakistani players deserve to know exactly what happens to their personal information. This policy explains everything — what we collect, why we collect it, how we protect it, and what your rights are.

Last Updated: June 2025 Applies to all x 111 registered accounts
256-Bit SSL Encryption

Every byte of data sent between your device and x 111 travels through 256-bit SSL encryption. Nobody intercepts it in transit — not even theoretically.

We Never Sell Your Data

x 111 does not sell, rent or trade your personal information to third-party marketing companies — ever. Your data is yours, not a product.

Full Control in Your Hands

Access, correct, export or delete your data at any time through your x 111 account settings or by contacting support directly. No hoops to jump through.

Minimal Data Collection

x 111 only collects data that is genuinely necessary to operate your account, process payments and comply with legal requirements. Nothing superfluous.

x 111

1. Who We Are

x 111 is an online gaming and sports betting platform operating at x111.wine. We offer a range of gaming and betting services to Pakistani players, including live casino, PSL betting, football betting, baccarat, card games, esports betting, and crash games. All services are provided in Pakistani Rupees (PKR) and are designed specifically for Pakistani players.

When this Privacy Policy refers to "x 111", "we", "us" or "our", it refers to the platform operating at x111.wine and its associated data processing activities. When it refers to "you", "your" or "the player", it refers to any individual who has registered an account, submitted a query, or visited the x 111 website.

This Privacy Policy explains how x 111 collects, uses, stores and protects your personal data, and what rights you have over that data. It applies to all personal data collected through the x 111 website, mobile-optimised site, live chat function, and email communications. This policy should be read alongside our Terms and Conditions and Responsible Gaming Policy.

Your Consent: By registering an account at x 111, you confirm that you have read and understood this Privacy Policy and consent to the collection and processing of your personal data as described herein. If you do not agree, please do not register or use the x 111 platform.

2. Personal Data We Collect

x 111 collects personal data that is necessary for the purposes described in this policy. We do not collect data gratuitously. The categories of personal data we collect about Pakistani players are set out below.

Category Examples When Collected
Identity Data Full name, date of birth, CNIC number, nationality Account registration and verification
Contact Data Email address, Pakistani mobile number, city of residence Account registration and support
Financial Data Easypaisa / JazzCash number, IBFT account details, Visa/Mastercard last four digits Deposit and withdrawal processing
Transaction Data Deposit amounts, withdrawal amounts, bet history, game session records Ongoing platform use
Technical Data IP address, device type, browser, operating system, session duration Automatic — each site visit
Communication Data Live chat transcripts, email correspondence, support tickets When you contact x 111 support
Verification Documents CNIC copy, passport copy, utility bill or bank statement (for KYC) Identity and address verification

x 111 does not collect sensitive personal data categories such as racial or ethnic origin, political opinions, religious beliefs or biometric data unless required by law for identity verification purposes. We do not collect data about minor children and do not knowingly accept registrations from persons under 18 years of age.

3. How We Collect Your Data

x 111 collects your personal data through the following channels:

  • Direct submission: Data you provide when completing the x 111 registration form, identity verification process, deposit or withdrawal requests, and any support enquiry.
  • Automated collection: Technical data collected automatically when you visit x111.wine, including IP address, device identifiers, browser type and session behaviour, collected via server logs and cookies.
  • Payment processors: Confirmation data returned by Easypaisa, JazzCash, NayaPay, SadaPay and bank systems when a deposit or withdrawal is processed.
  • Third-party verification services: Identity and document verification data returned by the KYC (Know Your Customer) service providers x 111 uses for age and identity checks.
  • Responsible gaming systems: Data generated by your use of x 111's responsible gaming tools, including deposit limit settings, session duration and self-exclusion requests.

Automated Decision-Making: x 111 may use automated systems to detect unusual betting patterns, potential fraud and bonus abuse. These systems flag accounts for manual review — they do not make final account decisions without human oversight.

x 111

4. Why We Use Your Personal Data

x 111 processes your personal data only for purposes that are lawful and proportionate. The legal basis for each processing purpose is identified below so you understand not just what we do with your data, but why we are entitled to do it.

  • Account operation (Contract): Processing your registration, login, deposits, withdrawals and game participation is necessary to deliver the x 111 service you signed up for. Without this, we cannot operate your account.
  • Identity verification (Legal obligation): Verifying your age and identity using CNIC or passport data is a legal requirement under anti-money laundering and know-your-customer standards applicable to online gaming platforms.
  • Fraud prevention and security (Legitimate interest): Monitoring transactions, login patterns and gameplay for signs of fraud, money laundering, bonus abuse or account compromise protects both x 111 and genuine Pakistani players from financial crime.
  • Customer support (Contract + Legitimate interest): Handling support queries, resolving disputes and processing complaints requires us to access account history, transaction records and communication logs relevant to the issue raised.
  • Responsible gaming (Legal obligation + Legitimate interest): Tracking betting patterns for signs of problematic gambling behaviour and operating responsible gaming tools on your account are both a platform obligation and a genuine service to players.
  • Marketing communications (Consent): Sending promotional emails or SMS messages about bonuses and offers is only done where you have explicitly opted in. You can withdraw consent at any time through your account notification settings or by contacting support.
  • Platform improvement (Legitimate interest): Aggregated, anonymised usage data helps x 111 understand how players use the platform and where improvements are needed. This data cannot identify individual players.

5. Sharing Your Personal Data

x 111 does not sell, rent or trade your personal data to third parties. However, there are specific circumstances in which we share data with carefully selected third parties, as described below. In each case, the third party is bound by contractual data protection obligations consistent with this policy.

  • Payment processors: Easypaisa, JazzCash, NayaPay, SadaPay, bank partners and card processors receive the minimum financial data necessary to process your deposit or withdrawal. x 111 does not store full card numbers.
  • KYC and identity verification providers: Your CNIC or passport data is submitted to our verification partner to confirm age and identity. This is a one-time verification process and the data is not used for any other purpose.
  • Game software providers: Some x 111 game titles are operated by third-party studios whose software runs within the x 111 platform. These providers receive anonymised session data (bet amounts, round results) but do not receive personally identifiable information.
  • Fraud detection services: Anonymised technical and behavioural data may be shared with fraud detection services to identify suspicious patterns across platforms.
  • Legal and regulatory authorities: x 111 will disclose personal data to law enforcement, financial intelligence units or regulatory bodies when required by law, court order or valid legal process. We cannot notify you in advance of such disclosures where legally prohibited from doing so.

x 111 will never share your personal data with third-party marketing companies, advertising networks, data brokers or any entity that intends to use it for commercial purposes unrelated to the direct operation of your x 111 account.

6. How Long We Keep Your Data

x 111 retains personal data only for as long as is necessary for the purpose for which it was collected, or as required by applicable legal and regulatory obligations. The following retention periods apply:

  • Account data (name, contact, login): Retained for the duration of your active account plus 5 years after account closure, to meet anti-money laundering retention requirements.
  • Transaction records (deposits, withdrawals, bet history): Retained for 7 years from the date of each transaction, in line with financial record-keeping standards.
  • KYC and verification documents: Retained for 5 years after account closure or the end of the business relationship, whichever is later.
  • Support communications: Retained for 3 years from the date of the communication, for dispute resolution and quality assurance purposes.
  • Marketing preferences and consent records: Retained for the lifetime of the account plus 1 year, to demonstrate compliance with consent requirements.
  • Technical and log data: Retained for 12 months from collection, after which it is aggregated and anonymised for analytical purposes.

When the applicable retention period expires, x 111 securely deletes or anonymises the data so it can no longer be linked to an individual player. If you request deletion of your account, x 111 will delete all non-legally-required data within 30 days of the request.

7. How We Protect Your Data

Data security is a core operational priority at x 111. The following technical and organisational measures are in place to protect your personal data from unauthorised access, loss, destruction or disclosure:

1
256-Bit SSL Encryption

All data transmitted between your browser or app and x 111 servers is protected by TLS 1.3 with 256-bit AES encryption. This applies to login, registration, deposit, withdrawal and all game sessions.

2
Encrypted Data Storage

Personal data stored in x 111 databases is encrypted at rest. Financial data such as account numbers is tokenised — the actual numbers are replaced with non-reversible tokens so they cannot be retrieved even in the event of a database breach.

3
Two-Factor Authentication

x 111 offers two-factor authentication via SMS OTP for all logins and withdrawal requests. We strongly recommend all Pakistani players activate 2FA in their account security settings.

4
Access Controls

Only x 111 staff with a specific operational need can access player data. Access is role-based, logged and audited. Support agents see only the data they need to resolve your query — not your full account history.

5
Regular Security Testing

x 111 conducts regular penetration testing and vulnerability assessments of the platform. Any identified vulnerabilities are prioritised and remediated before they can be exploited.

6
Incident Response

In the event of a data breach affecting your personal data, x 111 will notify affected players within 72 hours of becoming aware of the breach, detailing what data was affected and what steps we are taking to address it.

x 111

8. Your Data Rights

As an x 111 player, you have the following rights over your personal data. These rights can be exercised at any time by contacting us at support@x111.wine or through your account settings where the relevant tool is available.

Right of Access

Request a full copy of the personal data x 111 holds about you. We will provide it within 30 days in a readable format — typically CSV or PDF.

Right to Correction

If any personal data x 111 holds about you is inaccurate or outdated, you can request correction at any time through your account profile or by contacting support.

Right to Deletion

Request deletion of your personal data ("right to be forgotten"). We will delete all non-legally-required data within 30 days. Legally retained data is deleted once the retention period expires.

Right to Data Portability

Request your personal data in a structured, machine-readable format (CSV) so you can transfer it to another service. Available for data you have provided directly to x 111.

Right to Restrict Processing

In certain circumstances, you can request that x 111 restricts processing of your data — for example, while a dispute about accuracy is being resolved.

Right to Withdraw Consent

Where processing is based on consent (e.g. marketing communications), you can withdraw consent at any time through your notification settings or by contacting support. Withdrawal does not affect prior lawful processing.

How to Exercise Your Rights: Email support@x111.wine with the subject line "Data Request" and include your x 111 username and registered mobile number. We will acknowledge your request within 2 hours and respond substantively within 30 days.

9. Cookies and Tracking Technologies

x 111 uses cookies and similar tracking technologies on x111.wine to ensure the platform functions correctly and to understand how Pakistani players use the site. The following types of cookies are used:

You can control cookie preferences through your browser settings. Note that disabling strictly necessary cookies will prevent the x 111 platform from functioning correctly — login and game functionality depend on session cookies. Marketing cookies at x 111 are opt-in only and are not activated without your explicit consent.

x 111 does not use cross-site tracking cookies that follow you across other websites. All cookies set by x 111 are scoped to x111.wine only.

10. Minors — Under 18s

x 111 is an adult platform. We do not knowingly collect personal data from any person under 18 years of age. All x 111 registrations require confirmation that the applicant is at least 18 years old, and identity verification is used to confirm this.

If x 111 becomes aware that a registered account belongs to a person under 18 — whether through age verification, a parental complaint or any other means — the account will be suspended immediately, all deposits returned, and all associated winnings voided. Any personal data collected in relation to that account will be securely deleted.

Parental Notice: If you believe your child has registered an account at x 111 without your knowledge, please contact support@x111.wine immediately. We will take immediate action and ensure all data is deleted. x 111 supports and recommends the use of parental control software on devices accessible to minors.

11. International Data Transfers

As an international online platform, x 111 may transfer your personal data to servers or service providers located outside Pakistan. Such transfers occur in connection with our payment processing, KYC verification, fraud detection and game software provision.

Wherever your data is transferred internationally, x 111 ensures that appropriate safeguards are in place. These include contractual data protection clauses binding the receiving party to data protection standards equivalent to those described in this policy. x 111 does not transfer personal data to jurisdictions with no data protection framework without specific safeguards in place.

The primary server infrastructure for x 111 player account data uses data centres with South Asian routing to minimise latency for Pakistani users and to keep data geographically close to the player population it serves wherever commercially and technically practical.

12. Updates to This Privacy Policy

x 111 may update this Privacy Policy from time to time to reflect changes in our data processing activities, legal requirements or platform features. The "Last Updated" date at the top of this page will always show the date of the most recent revision.

For material changes — those that significantly affect how we use your data or reduce your rights — x 111 will send a notification to your registered email address at least 7 days before the revised policy takes effect. For minor clarifications or corrections that do not affect your rights, the policy may be updated without direct notification, but the change will always be visible in the updated document.

Continued use of x 111 after the effective date of any updated Privacy Policy constitutes acceptance of the revised terms. If you do not agree with an update, please stop using the platform and request account closure before the change takes effect.

Recommendation: Bookmark this page at x111.wine/privacy-policy and check it periodically. The version published here is always the current, operative version of the x 111 Privacy Policy.

13. Contact — Data and Privacy Queries

If you have any questions about this Privacy Policy, wish to exercise any of your data rights, want to make a complaint about how x 111 has handled your personal data, or need to report a potential data breach, please contact us through the following channels:

  • Email: support@x111.wine — subject line "Privacy / Data Request"
  • Live Chat: Available 24/7 in English and Urdu at x111.wine
  • Response Time: Data access and deletion requests are acknowledged within 2 hours and actioned within 30 days

Please include your x 111 username and registered Pakistani mobile number in any data-related email so we can locate your account without delay. For security reasons, we cannot discuss account-specific data over live chat without identity verification.

Related policies at x 111: Terms and Conditions  |  Responsible Gaming  |  FAQ

YOUR DATA IS SAFE WITH US

Ready to Play at x 111? Your Privacy Is Protected From Day One

256-bit encryption, no data selling, full player control and 24/7 support in Urdu and English. x 111 takes your privacy as seriously as your winnings. Register in under 2 minutes and claim your 200% welcome bonus up to Rs 50,000.

256-Bit SSL Encryption Data Never Sold Delete Anytime

Questions About How x 111 Uses Your Data?

Our support team is available 24/7 in Urdu and English. Privacy questions get the same priority as gameplay support — email support@x111.wine or use live chat on the platform.