Your Privacy Is a Priority at e111

1. Information We Collect

e111 collects personal information from you at various points during your relationship with the platform. The specific categories of data we collect, and the circumstances in which we collect them, are described below.

e111 does not knowingly collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data, or health information. If you voluntarily disclose such information through support interactions, it will be handled with the highest level of care and will not be used for any processing purpose beyond resolving your specific query.

We do not knowingly collect personal data from individuals under the age of 18. If we become aware that a minor has provided us with personal information, we will take immediate steps to delete that data and close the associated account. If you believe a minor has registered on e111, please notify us immediately at [email protected].

2. How We Use Your Information

e111 processes your personal data only where we have a lawful basis for doing so. The primary lawful bases we rely upon are: (a) the performance of our contract with you as a registered player; (b) compliance with legal obligations; (c) our legitimate business interests, where these do not override your fundamental privacy rights; and (d) your explicit consent, in cases where we rely on it.

The specific purposes for which e111 uses your personal information include the following:

• Account Management: Creating, maintaining, and administering your e111 player account, including processing changes to your profile, password, and contact details.
• Transaction Processing: Processing deposits and withdrawals via bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, and other supported payment channels available to players in Bangladesh.
• Identity and Age Verification: Confirming that you meet the minimum age requirement of 18 years and that your identity matches the details held on your account, in line with our Know Your Customer (KYC) obligations.
• Fraud Prevention and Security: Detecting, investigating, and preventing fraudulent transactions, money laundering, multi-accounting, and other prohibited activities that may affect the integrity of the e111 platform.
• Responsible Gaming: Monitoring your gambling patterns to identify potential signs of problem gambling, applying deposit limits or self-exclusion measures where requested, and fulfilling our duty-of-care obligations.
• Customer Support: Responding to your queries, resolving disputes, and communicating essential service information relating to your account activity.
• Platform Improvement: Analysing aggregated usage data to improve the performance, content, and user experience of the e111 platform — including game selection, payment flow, and site navigation.
• Marketing Communications: Sending you promotional offers, bonus notifications, and updates about new games or features on e111 — but only where you have opted in to receive such communications and have not subsequently withdrawn your consent.
• Legal Compliance: Meeting our obligations under applicable anti-money laundering (AML) regulations, data protection law, and any lawful requests from competent authorities.

e111 will not use your personal data for any purpose that is incompatible with those set out above without first notifying you and, where required, obtaining your explicit consent.

3. Sharing and Disclosure of Data

e111 does not sell your personal data to any third party. We may, however, share your information with carefully selected third parties where doing so is necessary to operate the platform, comply with legal obligations, or protect the legitimate interests of e111 and its players. All third parties with whom we share data are contractually required to handle it securely and in accordance with applicable data protection standards.

The categories of third party with whom e111 may share your personal data include:

• Payment Processors: Providers such as bKash, Nagad, Rocket, Upay, Dutch-Bangla Bank, City Bank, BRAC Bank, Visa, and Mastercard receive the minimum financial data required to process your deposit or withdrawal transactions. These providers operate their own privacy policies and are responsible for their own data handling practices.
• Identity Verification Services: Third-party KYC providers who assist e111 in verifying player identity and age documentation. These providers access only the data strictly necessary for verification and are prohibited from using it for any other purpose.
• Game Software Providers: Licensed game studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi may receive anonymised or pseudonymised session data to support game performance and integrity monitoring. These providers do not receive your full identity or financial data.
• Fraud Prevention and AML Partners: Specialist third-party services that assist e111 in detecting suspicious activity, verifying the legitimacy of transactions, and meeting our anti-money laundering obligations.
• Regulatory and Law Enforcement Authorities: Where we are legally required to do so, e111 will disclose personal data to competent authorities in response to a valid legal request, court order, or regulatory investigation. We will, to the extent permitted by law, notify you of such a disclosure.
• IT Infrastructure and Cloud Service Providers: Third-party providers who host or maintain components of the e111 platform. These providers act as data processors on our behalf and are bound by strict data processing agreements.

In the event that e111 undergoes a merger, acquisition, or sale of all or part of its business assets, your personal data may be transferred to the acquiring entity as part of that transaction. We will notify you of any such transfer and the applicable privacy terms before it takes effect.

4. Cookies and Tracking Technologies

e111 uses cookies and similar tracking technologies to operate the platform effectively, personalise your experience, and analyse how players interact with our website. A cookie is a small text file placed on your device when you visit a website. It allows the website to recognise your device on subsequent visits and remember certain information about your preferences and activity.

The types of cookies used by e111 are as follows:

Most web browsers allow you to manage or disable cookies through their settings. Please note that disabling strictly necessary cookies may impair the functionality of the e111 platform, including your ability to log in and access your account. Instructions for managing cookies are available in the help documentation of your browser. Continuing to use the e111 platform without adjusting your browser settings constitutes your acceptance of the cookies described in this section.

e111 does not use cookies to serve third-party advertising on external websites, and we do not participate in cross-site behavioural advertising networks.

5. Data Security and Storage

e111 takes the security of your personal data seriously and has implemented a range of technical and organisational measures designed to protect your information against unauthorised access, disclosure, alteration, and destruction. These measures include, but are not limited to:

• Transport Layer Security (TLS/SSL) encryption for all data transmitted between your device and the e111 platform.
• Encryption at rest for all sensitive personal and financial data stored on our servers.
• Strict role-based access controls ensuring that personal data is accessible only to authorised e111 personnel who require it for their specific operational function.
• Regular internal security reviews and vulnerability assessments of the e111 platform infrastructure.
• Multi-factor authentication requirements for administrative access to systems that store or process personal data.
• Documented incident response procedures for detecting, investigating, and remediating data security breaches in a timely manner.

In the event of a data security breach that poses a significant risk to your rights or interests, e111 will notify you without undue delay and will provide full details of the nature of the breach, the data affected, the steps we have taken in response, and any actions you should take to protect yourself.

Player data is stored on servers located in secure, access-controlled data centres. e111 applies data residency and transfer safeguards to ensure that personal data transferred outside the jurisdiction of origin is subject to equivalent levels of protection through contractual data processing agreements with all relevant third parties.

6. Your Privacy Rights

As a player on the e111 platform, you have a number of rights with respect to your personal data. e111 is committed to facilitating the exercise of these rights promptly and without undue friction. To submit a data rights request, please contact our support team at [email protected] with the subject line "Data Rights Request" and include sufficient information to allow us to verify your identity.

Your privacy rights include the following:

• Right of Access: You have the right to request a copy of the personal data that e111 holds about you, together with information about how it is being processed and the lawful basis for that processing.
• Right to Rectification: If any of the personal data we hold about you is inaccurate or incomplete, you have the right to request that we correct or update it without undue delay.
• Right to Erasure: You may request that e111 delete your personal data where it is no longer necessary for the purposes for which it was collected, where you have withdrawn your consent, or where you object to processing and there is no overriding legitimate interest. This right is subject to our legal retention obligations — see Section 7 for further details.
• Right to Restrict Processing: In certain circumstances, you may request that e111 suspend or limit its processing of your personal data — for example, while the accuracy of data you have contested is being verified.
• Right to Data Portability: Where processing is based on your consent or the performance of a contract, you have the right to receive a copy of your personal data in a structured, commonly used, machine-readable format.
• Right to Object: You have the right to object to the processing of your personal data where e111 is relying on a legitimate interest as its lawful basis, including where that processing involves profiling. You may also object to the use of your data for direct marketing at any time.
• Right to Withdraw Consent: Where e111 processes your data based on your consent, you may withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing carried out prior to withdrawal.

e111 will respond to all verified data rights requests within 30 days of receipt. Where a request is particularly complex or where a high volume of requests has been received, we may extend this period by a further 60 days, in which case we will notify you of the extension and the reasons for it within the initial 30-day window.

We will not charge a fee for handling data rights requests unless the request is manifestly unfounded, repetitive, or excessive. In such cases, we may charge a reasonable administrative fee or refuse to act on the request, in either case providing you with clear written reasons.

7. Data Retention Policy

e111 retains your personal data only for as long as is necessary to fulfil the purposes described in this Privacy Policy, or as required by applicable law. The specific retention periods applicable to different categories of personal data are set out below.

Upon the expiry of the applicable retention period, personal data will be securely deleted or anonymised in accordance with e111's internal data disposal procedures. Anonymised data, which can no longer be linked to any individual, may be retained indefinitely for statistical and analytical purposes.

Where you exercise your right to erasure before the expiry of the applicable retention period, e111 will evaluate whether deletion is possible in light of our legal obligations. Where deletion is not immediately possible — for example, because the data is subject to a mandatory regulatory retention requirement — we will restrict processing of that data to the minimum necessary extent until deletion becomes permissible.

8. Updates to This Privacy Policy

e111 reserves the right to update or revise this Privacy Policy at any time in response to changes in applicable law, evolving best practice, new platform features, or changes in the ways we process personal data. The effective date displayed at the top of this document will be updated each time a revision is made, and the version number will be incremented accordingly.

Where a revision involves a material change to the ways in which we collect, use, or share your personal data, we will notify you by email to the address registered on your e111 account, or by a prominent notice on the platform, at least 14 days before the change takes effect. Your continued use of the e111 platform after the revised policy takes effect constitutes your acceptance of the updated terms.

If you disagree with any material change to this Privacy Policy, you have the right to close your e111 account before the change takes effect by contacting our support team at [email protected]. Closing your account in this circumstance will not affect any data already lawfully processed by e111 prior to the closure date.

We recommend that you review this Privacy Policy periodically to stay informed of how e111 is protecting your personal information. If you have any questions about this policy or about how your data is handled, please do not hesitate to reach out to our team — we are available 24/7 at Bangladesh Standard Time (UTC+6).