Privacy Policy for de111 — How We Handle Your Personal Data

1. Information We Collect

de111 collects personal information through multiple touchpoints during your use of the platform. We categorise the data we collect into three broad types: information you provide directly, information generated automatically through your use of the platform, and information we receive from third-party service providers.

1.1 Information You Provide Directly

When you register a de111 account, make a deposit or withdrawal, contact customer support, or participate in a promotion, you provide us with personal information that may include:

• Identity data: Full legal name, date of birth, nationality, and gender.
• Contact data: Mobile phone number, email address, and residential address in Bangladesh (including district, division, and postal code).
• Financial data: Mobile financial service account identifiers (bKash number, Nagad number, Rocket number, Upay number) used for deposits and withdrawals. de111 does not store full payment account credentials — only the account reference needed to process transactions.
• Verification documents: Copies of government-issued photo ID (National ID Card, passport, or driving licence), proof of address documents, and any other KYC materials you submit during the identity verification process.
• Communications data: Records of correspondence between you and de111 via email, live chat, or support ticket systems, including the content of those communications.

1.2 Information Generated Automatically

When you access de111.app, our systems automatically collect technical and behavioural information associated with your session, including:

• Device and technical data: IP address, device type, operating system, browser type and version, screen resolution, and language settings.
• Usage data: Pages visited on de111.app, time spent on each page, game sessions initiated, bet amounts, wager history, win/loss records, and navigation paths through the platform.
• Session data: Login timestamps, session duration, geographic location derived from IP address, and device fingerprint identifiers used for fraud detection.

1.3 Information from Third Parties

de111 may receive supplementary personal data from trusted third-party sources in the following contexts:

• Payment verification: Mobile financial service providers (bKash, Nagad, Rocket, Upay) may confirm transaction status, account registration status, and account ownership details to facilitate payment processing and fraud prevention.
• Identity verification services: Where de111 uses a third-party KYC verification service to authenticate identity documents, that provider may return a verification outcome and risk score associated with your submitted documents.
• Responsible gaming databases: de111 may cross-reference self-exclusion requests against shared responsible gaming registries to ensure that self-excluded players cannot open new accounts.

2. How We Use Your Information

de111 uses the personal data it collects for specific, defined purposes. We do not use your data for any purpose beyond those listed below without first obtaining your consent or where we have a separate legal basis for doing so.

Purpose	Data Used	Legal Basis
Account registration and management	Identity data, contact data	Contractual necessity
Processing deposits and withdrawals	Financial data, identity data	Contractual necessity
KYC and identity verification	Identity data, verification documents	Legal obligation
Fraud detection and prevention	Device data, session data, financial data	Legitimate interest
Responsible gaming monitoring	Usage data, wagering history	Legal obligation / legitimate interest
Customer support	Communications data, identity data	Contractual necessity
Platform analytics and improvement	Usage data, device data (anonymised)	Legitimate interest
Promotional communications (opted-in only)	Contact data, usage data	Consent

Where de111 relies on your consent as the legal basis for processing — primarily for marketing communications — you may withdraw that consent at any time by contacting support or updating your communication preferences in your account settings. Withdrawal of consent does not affect the lawfulness of processing carried out prior to the withdrawal.

3. Sharing and Disclosure of Data

de111 does not sell, rent, or trade your personal data. We share data only in the limited circumstances described below, and only with parties who are bound by appropriate data protection obligations.

3.1 Service Providers and Data Processors

de111 works with a number of third-party service providers who process personal data on our behalf in order to deliver the platform. These include:

• Payment processors: bKash, Nagad, Rocket, and Upay receive transaction-relevant data (such as account identifiers and amounts) to execute deposits and withdrawals.
• Game content providers: Studios including Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Ezugi receive anonymised session identifiers to deliver game content and record round outcomes. They do not receive your full identity or payment data.
• KYC and fraud prevention vendors: Identity verification service providers receive the documents you submit during the KYC process and return a verification outcome.
• Hosting and infrastructure providers: de111's platform is hosted on secure cloud infrastructure. The hosting provider operates under strict data processing agreements and has no independent right to access or use your data.

All third-party data processors engaged by de111 are contractually required to process data only in accordance with de111's instructions, to maintain appropriate security standards, and to refrain from using the data for their own independent purposes.

3.2 Legal and Regulatory Disclosure

de111 may disclose personal data to law enforcement agencies, regulatory authorities, or courts where required to do so by applicable law, a valid legal order, or where de111 believes in good faith that disclosure is necessary to prevent fraud, financial crime, or harm to another person.

3.3 Business Transfers

In the event that de111 undergoes a merger, acquisition, restructuring, or sale of substantially all of its assets, personal data held by de111 may be transferred to the acquiring entity as part of that transaction. de111 will notify affected players via their registered contact details prior to any such transfer taking effect and will ensure that the receiving entity provides equivalent data protection standards.

4. Cookies and Tracking Technologies

de111.app uses cookies and similar technologies to enable core platform functionality, improve the user experience, and support security measures. This section explains the types of cookies we use and how you can manage your preferences.

4.1 Types of Cookies Used

• Strictly necessary cookies: These are essential for the platform to function. They maintain your session state, keep you logged in between page loads, and protect against cross-site request forgery attacks. These cookies cannot be disabled without severely impairing your ability to use de111.
• Functional cookies: These remember your preferences — such as your preferred language, display settings, and last-used payment method — so you do not need to re-enter them on each visit.
• Analytics cookies: de111 uses anonymised analytics data to understand how players navigate the platform, which game categories are most popular, and where technical issues occur. This data is aggregated and not linked to your personal identity.
• Security cookies: These are used to detect and prevent fraudulent login attempts, bot activity, and other abusive behaviour. They may collect device fingerprint information associated with your session.

4.2 Managing Cookie Preferences

You may control non-essential cookies through your browser settings. Most modern browsers allow you to block or delete cookies, or to be notified before a cookie is placed. Please note that disabling strictly necessary cookies will prevent you from logging in and using core platform features. Instructions for managing cookies vary by browser — refer to your browser's help documentation for guidance specific to your setup.

de111 does not use third-party advertising cookies or cross-site tracking pixels. The only third-party cookies present on de111.app are those set by our game content providers (Pragmatic Play, Evolution, etc.) to maintain individual game session state — these do not track your activity across other websites.

5. Data Security Measures

de111 implements a layered security architecture designed to protect your personal data against unauthorised access, disclosure, alteration, and destruction. Our security measures include:

• Transport layer security: All data transmitted between your device and de111.app is encrypted using TLS 1.2 or higher. Our SSL certificate is maintained and renewed regularly.
• Data at rest encryption: Personal data stored in de111's databases is encrypted at rest. Encryption keys are managed separately from the encrypted data and are rotated on a scheduled basis.
• Access controls: Access to personal data within de111's internal systems is restricted on a strict need-to-know basis. All internal access is logged, audited, and subject to multi-factor authentication.
• Penetration testing: de111's platform undergoes periodic security assessments and penetration tests conducted by independent security specialists. Critical findings are remediated within defined SLA timeframes.
• Fraud detection systems: de111 operates real-time fraud detection systems that monitor transaction patterns, login behaviour, and device usage to identify and respond to potential security incidents.
• Incident response: de111 maintains a documented data breach response procedure. In the event of a confirmed breach affecting your personal data, de111 will notify affected players as promptly as reasonably practicable and will take all necessary steps to contain the incident.

6. Data Retention Periods

de111 retains personal data for as long as is necessary to fulfil the purposes for which it was collected, subject to any longer retention periods required by applicable law. The following table summarises our standard retention schedule:

Data Category	Retention Period	Reason
Account registration data	Duration of account + 5 years post-closure	Legal and regulatory obligation
Transaction and wagering records	7 years from transaction date	Financial record-keeping requirements
KYC verification documents	5 years post-account closure	Anti-money laundering obligations
Customer support communications	3 years from last interaction	Dispute resolution and quality assurance
Session and device logs	12 months from session date	Fraud detection and security
Marketing preference records	Duration of consent + 1 year	Evidence of consent basis

Upon expiry of the applicable retention period, de111 will securely delete or anonymise the relevant personal data. Anonymised data (where your identity cannot be recovered) may be retained indefinitely for aggregate statistical and platform improvement purposes.

7. Your Privacy Rights

As a de111 player based in Bangladesh, you hold the following rights with respect to your personal data. To exercise any of these rights, please contact us at support at de111.app from the email address or mobile number registered to your account.

• Right of access: You may request a copy of all personal data de111 holds about you. We will provide this in a clear, readable format within a reasonable timeframe at no charge.
• Right to rectification: If any personal data de111 holds about you is inaccurate or incomplete, you have the right to request that it be corrected. Please note that corrections to identity data may require re-submission of verification documents.
• Right to erasure: You may request that de111 delete your personal data where it is no longer necessary for the purpose it was collected, where you have withdrawn consent, or where you believe the data was processed unlawfully. Note that erasure requests may not be fulfilled where de111 has a legal obligation to retain the data.
• Right to restrict processing: You may request that de111 pause the processing of your personal data in certain circumstances — for example, while a rectification request is being assessed.
• Right to data portability: You may request a copy of the personal data you have provided to de111 in a structured, machine-readable format, suitable for transfer to another service provider.
• Right to withdraw consent: Where processing is based on your consent (primarily for marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.
• Right to object: You may object to processing of your personal data carried out on the basis of de111's legitimate interests where you believe your rights outweigh those interests. de111 will assess each objection on its individual merits.

8. Updates to This Policy

de111 reviews this Privacy Policy periodically and reserves the right to update it to reflect changes in our data practices, applicable laws, or the services we offer. The effective date displayed at the top of this page reflects when the most recent version came into force.

Where an update to this Privacy Policy involves a material change to how we process your personal data — particularly any change to the categories of data collected, the purposes for which it is used, or the parties with whom it is shared — de111 will notify registered players via their registered contact details at least 7 days before the change takes effect. For minor updates (such as clarifications of existing language, correction of typographic errors, or addition of detail that does not change the substance of the policy), the updated version will be published without individual notice.

Your continued use of de111 following the effective date of any update to this Privacy Policy constitutes your acceptance of the revised policy. If you disagree with any material change, you should cease using the platform and contact us to exercise your right to erasure where applicable.

If you have any questions about this Privacy Policy, or about any aspect of how de111 handles your personal data, please do not hesitate to contact the de111 data team at support at de111.app. We are committed to providing clear, honest answers to all privacy-related enquiries.